Include the site within the Plan

With the Carmarthen Town (Cluster 1) being only area than affects myself I have only focused this
representation on that locality in relation to the 2nd Deposit LDP. I’m in support of the 2nd deposit
LDP proposals, however I do have concerns (certain 'Sound of Testiness' not being met – ie will the
plan deliver) that there are not enough smaller sites to compliment the larger development, for the
reasons giving below.
1. Relies heavily on the larger sites to meet a significant proportion of its housing supply
requirements.
The 2nd deposit LDP relies heavily on the larger sites to meet a significant proportion of its housing
supply requirement during the LDP period. There is a strong case that more smaller sites should
be allocated to minimise the risk for the Local Authority, thus ensuring that supply is maintained
throughout the plan period, in-case these larger sites, in particular the Carmarthen West and
Pibwrlwyd projects do not deliver, due to the scale and complex nature that these large
developments entail.
If we take Carmarthen Town for example the following have been allocated for housing:-
Carmarthen West 700 homes; Pibwrlwyd 245 Homes; Remaining 336 homes. As can be seen the
2 larger developments account for 74% of Carmarthen Town’s housing allocation. As can be seen in
Appendix 7 - Housing Trajectories (Allocations) of the LDP, there is some planning requirements for
both the larger sites in Carmarthen - West Carmarthen & Pibwrlwyd. It should be noted that their
build projection state that they do not come onto site until towards the end of the LDP period.
With this being the case there is little margin for any delay caused by any planning issue, build rate,
or from an economical or financial perspective. Should the Local Authority allocate more smaller
sites then this would reduce this risk for the authority and provide some contingency, ensuring that
supply is maintained throughout the plan period.
A report 'Start to Finish - How Quickly do Large Scale Housing Sites Deliver' (Nov 2016) by Nathaniel
Lichfield & Partner states " allocating more sites rather than less, with a good mix of types and
sizes, and then being realistic about how fast they will deliver so that supply is maintained
throughout the plan period". "There is a growing recognition that large-scale housing
development can and should play a large role in meeting housing need. However, what looks good
on paper needs to deliver in practice. Plans putting forward large sites to meet need must have a
justification for the assumptions they make about how quickly sites can start providing new
homes, and be reasonable about the rate of development. That way, a local authority can decide
how far it needs to complement its large-scale release with other sites – large or small – elsewhere
in its district."
To provide some context I have also extracted some further quotes from this report which can be
found towards the end of this representation.
2. Effects on the Economy having on the release of housing.
The probable recession, slow growth rate, high cost that seems inevitable after the Covid 19
pandemic and Ukraine conflict, will have a significant effect on developers being able to release
housing to meet what supply is required within the LDP period. Not every planning permission
granted will translate into the development of homes. This could mean an entire site does not
come forward, or delivery on a site can be slower than originally envisaged. It is thus not realistic
to assume 100% of planning permission granted in any given location will deliver homes. Planning
permissions can lapse for a number of reasons ie:- landowner cannot get the price for the site that
they want; a developer cannot secure finance or meet the terms of an option; the development
approved is not considered to be financially worthwhile etc. There is a strong case that more
smaller sites should be allocated, to minimise the risk for the Local Authority, thus ensuring that
supply is maintained throughout the plan period. More smaller sites will also benefit the local
economy with smaller contractors / developers being brought on, which will in turn benefit the local
supply chain and the environment.
3. Have current living trends been taken into account?
It is unclear whether the population and household numbers that have been projected in the LDP
have taken into account current living trends ie - young adults still having to live with parents due
to costs and increased percent of older people living alone due to maybe divorce etc. These current
living trends will require further housing allocations being required to try to tackle and overcome
this new issue. The following statistics / statements were published an article written in the
Independent 8th November 2017, which refers to Data released by Office for National Statistics
(ONS): -
‘Data released by the ONS shows that the percentage of young adults living with their
parents in the UK has risen from just over a fifth (21 per cent) in 1996 to 26 per cent in
2017, rising from 2.7 million to 3.4 million in the past two decades.’
‘Concerns over house prices for young adults were raised in research published by
Homeless Charity Shelter in 2014. The study predicted that the proportion of young
adults still living with their parents would pass 50 per cent within a generation unless
radical action was taken to tackle Britain’s housing shortage.
‘‘The ONS data shows that the number of people aged 45 to 64 who lived alone
increased by 53 per cent between 1996 and 2017 – a statistically significant increase.
This is partly due to the increasing population age 45 to 64 years in the UK over this
period, but the increase could also be due to a rise in the proportion of the population
aged 45 to 64 who are divorced or single and never married.’
‘Those aged 65 to 74 years living alone also saw a statistically significant increase of 15
per cent over the two decades. The number living alone aged 75 and over also
increased over the two decades to 2017, by a larger percentage of 24 per cent.’
On merit alone and case for more allocation of smaller sites – Candidate Site SR/021/021 (Land
off Trevaughan Road) to be included within LDP 2018 - 2033
I am writing this representation response, admittedly and primarily due to the reason that the
Candidate Site that I submitted, wasn’t chosen to be included in the new LDP 2018 -2033. I believe
that it there is merit in its own right to include this site going forward, so that it forms part of the
residential allocation within Carmarthenshire LDP 2018 -2033. I would kindly encourage the
Planning Inspector to read the Candidate Site Submission which was submitted and visit this site in
relation to the other sites that have been allocated in the LDP. To add further reasons, should it
be deemed that additional sites are required due to some of the points that I have mentioned in
this representation, I would be grateful if this site could be considered. The site -SR/021/021
(Land off Trevaughan Road) passed all the of the Candidates Sites Assessment Stages (Stages 1, 2a,
2b and 3), however it was not put forward due to the reason “there is sufficient and more suitable
land available”. In the Carmarthen Town area, there were only 2 sites, mine being one of them
that passed all the Candidate Site Assessments but didn’t get through to be allocated.
The candidate site submission document for my site (SR/021/021) was very comprehensive and
proves that a development could be delivered on the site. The candidate site submission
demonstrates that the site is viable and is deliverable for residential purpose. It addresses all the
issues of deliverability such as ecology, highways, drainage, utilities, flooding etc. The candidate
site is solely owned (freehold) by ourselves, with there being no impediment to bring forward this
parcel of land for residential development, and for it to be completed within the LDP period 2018
– 2033.
The ’Site Allocation Assessment – Reasonable Alternatives’ Report by Carmarthenshire County
Council contained in the 2nd Deposit LDP submission marked my site down on 3 aspects, namely:-
(1)no re-use of previously developed land/buildings, (2) within a mineral buffer zone and (3) on
quality agricultural land.
However we would argue the following in relation to those points in that assessment namely:-
(1) No reuse of previously land/building - Part of the application site (towards the north) sits
of the land that has previously been developed. Not only does the site house an existing
shed, but also there are remains of stone walls where once stood a house as evidence of
its existence. The presence of a building can also be confirmed on historical maps which a
copy is shown in the Candidate Site Submission. The possible re-use/ conversion of the
shed / buildings was suggested as part of the Candidate Site Submission. The existing
shed was built in the early 1990's and is constructed out of metal corrugated sheeting which
is supported by a steel portal frame. This building has now deteriorated and could be
considered an eyesore from an aesthetics perspective. This existing shed could be
converted, providing a high quality contemporary architectural approach, using a palette
of quality natural materials. The existing shed could be converted into a Community Hall
which would enhance the local community or into a small enterprise which would
contribute to the authority’s employment objectives.
(2) Within a mineral buffer zone - The site currently lies in a Sand and Gravel Minerals
Safeguarding Zone. However as stated in my Candidate Site Submission if reserves were
proved to be viable any future extraction would need to be at least 250 metres from existing
housing. As such the triangular nature of the site, bounded by existing housing (Derwen
Fechan Housing Development) on one side and with emergency services, fire station etc on
the other, this would restrict works. Therefore the current designation within the LDP
should not present a major constraint given that the site represents a logical extension to
the settlement pattern
(3) On quality Agricultural ground – As part of the Candidate Site Submission we submitted a
Preliminary Ecology Report carried out by Bay Ecology in May 2018. The finding were as
follows :
 The site was comprised of a limited range of habitat types predominantly comprised of an
improved grassland pastoral field bordered by species poor hedgerows and a short treeline.
 In terms of the ecological importance of the site the large improved grassland pastoral field
was of low intrinsic ecological value and represented the most suitable area of the site to
support the development.
With the site being of low ecological value, it is considered that the site is deliverable for
residential development and should not present a major constraint, given that the site
represents a logical extension to the settlement pattern.
The candidate site is right on the outskirts of the current development plan, and the site represents
a logical extension to the settlement pattern, in a sustainable location, adjacent to a key settlement
in a marketable location. With the recent the Charles Church development north of College Road,
and the development of Derwen Fechan directly opposite, the candidate site represents a logical
extension to the settlement pattern.
The recent housing development of Derwen Fechan directly opposite and the presence of the
existing Fire station to the south, would establish that the site is not isolated and is within the built
form. The site is relatively flat and has good containment with established boundaries with its
hedgerow and tree line surrounding the site. The scale and density of the proposed development
shown within the drawings that accompanied the Candidate Site Submission document, reflects
that of existing residential development in the area and is considered to be appropriate, while
addressing the opportunities and constraints of the site.
From a highway and access perspective the land is situated directly off Trevaughan Road so there
is no third party approval required to provide access into the site. It has been demonstrated that
a new road access can be provided into the site allowing for good visibility at the junction. There
are good established links via nearby bus stops, public footpaths and pavement provision to the
Carmarthen Town and the wider areas of the community. In terms of highways and accessibility
it is considered that the site is deliverable for residential development
Existing utilities are present along Trevaughan Road which runs parallel to the sites eastern
boundary, again with no third party approval required (over any other land) to bring these
infrastructure to access into the site.
The candidate site that I put forward is located in close proximity to numerous primary schools but
is also within the 3 mile walking distance of both the English and Welsh Secondary schools. The
site is in walking distance to town with it being only 700 metres away from its centre.
The site offers an opportunity to develop a high quality sustainable neighbourhood, provide a
positive impact upon the Welsh language or any local communities and thus providing a positive
new settlement edge to Carmarthen Town. It is considered that the site can provide a range of
both open market and affordable homes along with high quality open space supporting the wider
Green Infrastructure strategy of Carmarthenshire County Council, creating a highly desirable and
attractive place to live.
In light of the above and to serve future local needs, myself (the land owner and applicant), kindly
requests that the Land off Trevaughan Road, Carmarthen (Candidate Site - SR/021/021) be
designated for Housing Land Allocation, within Carmarthenshire Local Development Plan (2018 -
2033).
Reference Quotes to provide context to this Representation
A resent research report has been written which looked at evidence on speed and rate of delivery
of large scale housing based on a large number of sites across England and Wales (outside London).
The report is 'Start to Finish - How Quickly do Large Scale Housing Sites Deliver' (Nov 2016) by
Nathaniel Lichfield & Partners (Planning Consultancy of the Year 2011 - 2014). Below are a few
extracts of the main findings (in italics) from that report, which provide some context to this
representation:-
"Planned housing trajectories should be realistic, accounting and responding to lapse
rates, lead-in times and sensible build rates. This is likely to mean allocating more sites
rather than less, with a good mix of types and sizes, and then being realistic about
how fast they will deliver so that supply is maintained throughout the plan period.
Because no one site is the same – and with significant variations from the average in
terms of lead-in time and build rates – a sensible approach to evidence and justification
is required."
"Spatial strategies should reflect that building homes is a complex and risky business.
Stronger local markets have higher annual delivery rates, and where there are
variations within districts, this should be factored into spatial strategy choices.
Further, although large sites can deliver more homes per year over a longer time period,
they also have longer lead-in times."
"Large-scale sites can be an attractive proposition for plan-makers. With just one
allocation of several thousand homes, a district can – at least on paper – meet a
significant proportion of its housing requirement over a sustained period."
"But large-scale sites are not a silver bullet. Their scale, complexity and (in some cases)
up-front infrastructure costs means they are not always easy to kick start. And once
up and running, there is a need to be realistic about how quickly they can deliver new
homes. Past decades have seen too many large-scale developments failing to deliver
as quickly as expected, and gaps in housing land supply have opened up as a result."
"This research provides insights to this topic – which has become a perennial discussion
at Local Plan examinations and Section 78 appeals in recent years – by focusing on two
key questions:
 what are realistic lead-in times for large-scale housing developments?; and
 once the scheme starts delivering, what is a realistic annual build rate? "
"On average, larger sites take longer to complete the planning application and lead-in
processes than do smaller sites. This is because they inevitably give rise to complex
planning issues related to both the principle of development and the detail of
implementation."
"Not every planning permission granted will translate into the development of homes.
This could mean an entire site does not come forward, or delivery on a site can be
slower than originally envisaged. It is thus not realistic to assume 100% of planning
permission granted in any given location will deliver homes. Planning permissions can
lapse for a number of reasons:"
 The landowner cannot get the price for the site that they want;
 A developer cannot secure finance or meet the terms of an option;
 The development approved is not considered to be financially worthwhile;
 Pre-commencement conditions take longer than anticipated to discharge;
 There are supply chain constraints hindering a start; or
 An alternative permission is sought for the scheme after approval, perhaps when a
housebuilder seeks to implement a scheme where the first permission was secured by a
land promoter.
"If more homes are to be built, more land needs to be released and more planning
permissions granted. Confidence in the planning system relies on this being achieved
through local plans that must be sufficiently ambitious and robust to meet housing
needs across their housing market areas. But where plans are not coming forward as
they should, there needs to be a fall-back mechanism that can release land for
development when it is required. "
"Spatial strategies should reflect that building homes is a complex and risky business. Stronger
local markets have higher annual delivery rates, and where there are variations within districts,
this should be factored into spatial strategy choices. Further, although large sites can deliver
more homes per year over a longer time period, they also have longer lead-in times. To secure
short-term immediate boosts in supply – as is required in many areas – a good mix of smaller
sites will be necessary. "