Allocate the land for residential use within the RLDP.

1 General Description
1.1 This LDP Representation relates to the potential inclusion of a new
site allocation for residential development in the Carmarthenshire
Revised Local Development Plan 2018 – 2033.
2 LDP Representation
2.1 The statement has been prepared by Ceri Davies BA Hons, Dip UP,
MRTPI, (Director of Ceri Davies Planning Ltd). The statement is
based on information provided by the client and other consultants.
All stated dimensions and distances are approximates and based on
the best information available at the time. Please refer to the
submission plans for detailed information.
2.2 The LDP Representation details include:
• 2
nd Deposit Revised LDP Representation Form
• Integrated Sustainability Appraisal
• Location & Site Plans
• Planning Statement
3 Client Details
3.1 The clients are Owain Ennis of Llaindelyn, Llaindelyn Rd, St Clears,
Carmarthen, SA33 4BB; Anne Birt of Egypt House, Queens Parade,
Tenby, SA70 7EH; Hugh Booth Meller-Haley of Millside Studio,
Llanddowror, Carmarthen, SA33 4HR.
4 The Site
4.1 The site is an irregular shaped piece of land forming part of three
separate field enclosure on the outskirts of St Clears. The fields in
question are currently used for grazing and keeping of horses. The
fields front onto Heol Llaindelyn and lie north-west of St Clears
Roundabout.
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4.2 Access to the site would be gained directly off Heol Llaindelyn,
which comes off the A477 Trunk Road, via the Old Tenby Road. The
site is bounded by mature hedgerows along its southern and
eastern boundaries.
4.3 The site lies just north of a grouping of dwellings at the western end
of St Clears. There is a residential dwelling directly opposite and a
small cluster of dwellings at the end of Heol Llaindelyn. The location
of the site and its proximity to the settlement of St Clears is
illustrated on the map extract below (Figure i).
Figure i – Location Map

4.3 Whilst the site currently occupies an open countryside location, it
lies in close proximity to a predominantly residential area within the
settlement of St Clears. The proximity of the site to the settlement
is shown on the aerial photograph below (Figure ii).
Figure ii – Aerial Photograph
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4.4 Vehicular access into the site is currently gained via the existing field
entrances which come directly off the adjacent public highway.
5 The Development
5.1 The aim of this proposal would be to develop the site for residential
purposes. The site would be able to clearly accommodate 5+ plots,
as such would be an additional housing allocation that could
potentially contribute towards the future housing needs for St
Clears.
5.2 The plan extract below (Figure iii) illustrates the scale of the site.
6 Policy Context
6.1 A review of the planning policy context associated with the site and
the proposed development (at national and local level) is provided
within this section of the Statement.
National Planning Policy
6.2 Well-Being of Future Generations (Wales) Act (2015)
6.2.1 The Act places a duty upon public bodies to produce well-being
objectives that contribute to achieving a set of overarching wellbeing goals:
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• A Prosperous Wales;
• A Resilient Wales;
• A Healthier Wales;
• A More Equal Wales;
• A Wales of Cohesive Communities;
• A Wales of Vibrant Culture and Thriving Welsh Language; and
• A Globally Responsible Wales.
6.2.2 Each public body is then required to take reasonable steps to meet
their objectives in the context of the principle of sustainable
development and whilst following a set of five ways of working.
6.2.3 The 'Resilient Wales' and 'Healthier Wales' goals are the key goals
that open space and greenspace, as part of the planning process will
contribute towards delivering.
6.3 Planning Policy Wales : Edition 11 (February 2021)
6.3.1 Planning Policy Wales (PPW) forms the overarching national
planning policy document for Wales and sets out the land use
planning policies of the Welsh Government. It is supplemented by a
suite of Technical Advice Notes (TANs), Welsh Government
Circulars, and policy clarification letters which together with PPW
provide the national planning policy framework for Wales. The main
objective of PPW is to promote place-making and sustainable forms
of development.
6.3.2 The primary objective of PPW is to ensure that the planning system
contributes towards the delivery of sustainable development and
improves the social, economic, environmental and cultural wellbeing of Wales, as required by the Planning (Wales) Act 2015,
the Well-being of Future Generations (Wales) Act 2015 and other
key legislation. PPW and National Development Framework (NDF)
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set out how the planning system at a national. Regional and local
level can assist in delivering these requirements through strategic
Development Plans(SDPs) and Local development Plans (LDPs).
6.3.3 There are a number of key planning principles indicated within
Planning Policy Wales (PPW) to achieve the right development in
the right place.
6.3.4 Paragraph 1.18 emphasises that the legislation secures a
presumption in favour of sustainable development in accordance
with the development plan, unless material considerations indicate
otherwise. The principles of sustainable development are defined in
the Well-being of Future Generations Act.
6.3.5 Paragraph 1.22 of PPW states that up-to-date development plans
are the basis of the planning system and that these set the context
for rational and consistent decision making, where they have been
prepared in accordance with up to date national planning policies.
6.3.6 These key planning principles are set out with a view to achieve a
number of national sustainable placemaking outcomes, as
explained in paragraphs 2.15-2.20 and outlined in Figure 4. The
national sustainable placemaking outcomes are:
People and Places: Achieving Well-being Through Placemaking
• Growing our economy in a sustainable manner
• Making best use of resources
• Maximising environmental protection and limiting environmental
impact
• Creating and sustaining communities
• Facilitating accessible and healthy environments
6.3.7 Paragraph 2.17 states “In responding to the key principles for the
planning system, the creation of sustainable places and in
recognition of the need to contribute to the well-being of future
generations in Wales through placemaking, development plans and
development proposals must seek to deliver development that
address the national sustainable placemaking outcomes”.
6.3.8 Sustainable development forms a key consideration central to all
policies contained within Planning Policy Wales (PPW). Paragraph
1.2 states: “The primary objective of PPW is to ensure that the
planning system contributes towards the delivery of sustainable
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development and improves the social, economic, environmental
and cultural well-being of Wales, as required by the Planning
(Wales) Act 2015, the Wellbeing of Future Generations (Wales) Act
2015 and other key legislation.”
6.3.9 Paragraph 2.27 sets out how to assess the sustainable benefits of
development: “Planning authorities should ensure that social,
economic, environmental and cultural benefits are considered in
the decision-making process and assessed in accordance with the
five ways of working to ensure a balanced assessment is carried out
to implement the Well-being of Future Generations Act and the
Sustainable Development Principle. There may be occasions when
one benefit of a development proposal or site allocation outweighs
others, and in such cases robust evidence should be presented to
support these decisions, whilst seeking to maximise contributions
against all the well-being goals.”
6.3.10 Paragraph 2.17 states that “in responding to the key principles for
the planning system, the creation of sustainable places and in
recognition of the need to contribute to the well-being of future
generations in Wales through placemaking, development plans and
development proposals must seek to deliver developments that
address the national sustainable placemaking outcomes.”
6.4 Future Wales: The National Plan 2040
6.4.1 Future Wales – The National Plan 2040 is Wales’ national
development framework which sets out the direction for
development in Wales to 2040. It is a development plan that sets
out a strategy for addressing key national priorities including
sustaining and developing a vibrant economy, achieving
decarbonisation and climate-resilience, developing strong
ecosystems and improving the health and wellbeing of our
communities.
6.4.2 The spatial strategy is a guiding framework which sets out the key
national policies that will guide and encourage development which
supports sustainable growth in both urban and rural areas across
Wales.
Policy 1 – Where Wales will grow
6.4.3 Policy 1 is the overarching policy which sets out where sustainable
growth will take place in Wales. Three National Growth Areas have
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been established where there will be growth in employment and
housing opportunities and investment in infrastructure. The
National Growth Areas are:
• Cardiff, Newport and the Valleys;
• Swansea Bat and Llanelli; and
• Wrexham and Deeside.
6.3.4 These National Growth Areas are complemented by Regional
Growth Areas, which will grow, develop and offer a variety of public
and commercial services at regional scale. There are Regional
Growth Areas in three regions:
• The South West;
• Mid Wales; and
• The North.
6.3.5 In addition to the above growth areas, there are a mix of smaller
towns and villages and large areas of countryside. The policy states
that ‘development in towns and villages in rural areas will support
local aspirations and need, complementing rather than competing
with efforts to grow our cities and towns.’
Local Planning Policy
6.4 The proximity of the site to the defined settlement development
limits for St Clears in the current Local Development Plan (LDP) is
illustrated in the map extract below, Figure (iv).
Figure iv – Current LDP Proposal Map

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6.5 The proximity of the site to the defined settlement development
limits for St Clears in the 2
nd Deposit Revised Carmarthenshire Local
Development Plan (LDP) is illustrated in the map extract below,
Figure (v).
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7 Detailed Consideration
7.1 As highlighted in the Integrated Sustainability Appraisal (ISA), it is
asserted that the site is deemed compatible with Strategic Policy
SP3 of the revised LDP which seeks to ensure the provision of
growth and development is directed to sustainable locations in
accordance with the spatial framework.
7.2 Given its proximity to St Clears, which is identified as a Cluster 6,
Tier 2 – Service Centre within the Settlement Framework, ISA
Objective 1 (Sustainable Development) is satisfied in this instance.
7.3 As illustrated on the plan below (Figure vi), the site represents a
sustainable location given its close proximity to St Clears.
Figure vi – Location Plan
7.4 The site clearly relates well to the settlement of St Clears which is
classed as a Service Centre in Strategic Policy SP3 of the LDP.
7.5 Natural Resources Wales Development Advice Maps indicate that
the site does not lie within a Zone C1 or C2 flood area as defined by
the development advice maps referred to in Technical Advice Note
15, Development and Flood Risk (TAN 15), as illustrated in the DAM
extract below (Figure vii).
7.6 TAN15 states that new development should be directed away from
Zone C and towards zone A, otherwise to zone B, where river or
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coastal flooding will be less of an issue. The site is not considered to
be at risk of flooding during at least the 1 in 1000 year event.
7.7 The development advice maps supplemented by sediment data,
held by the British Geological Survey (BGS), of historical flooding.
The maps adopt a precautionary principle and are based on the best
known information available at the time. It is noted that the NRW
flood maps show the site as being flood free during the Q100 event
and Q1000 event.
Figure vii – DAM Map
7.8 The Flood Map for Planning Wales also indicates that the site is not
at risk from localised or surface water flooding; this is illustrated on
the FMfP extract below (Figure viii).
Figure viii - FMfP
The Site
The Site
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7.9 The Flood Risk Map demonstratesthat the site falls outside of Flood
Zone 2 and Flood Zone 3, as such falls within and an area deemed
at low flood risk from rivers. The site will not be affected during the
1 in 1000 fluvial (Q1000 event or 0.1% event) and would also be
flood free during the 1 in 100 (Q100) flood event.
7.10 The site does not fall within a C1 or C2 flood risk zone as delineated
by TAN15 DAM flood maps. Neither does it fall within a Flood Zone
2 or Flood Zone 3 as delineated by FMfP (Flood Map for Planning
Wales). As such, ISA Objective 4 (Climatic Factors) and ISA Objective
5 (Water) are both satisfied in this instance.
7.11 The site is not located within or immediately any of the following
designated sites:
• Sites of Special Scientific Interest (SSSI)
• Special Areas of Conservation (SAC)
• Special Protection Areas (SPA)
• National Nature Reserves (NNR)
• Local Nature Reserves (LNR)
• Common Land or registered village green
As such, ISA Objective 2 (Biodiversity) is satisfied in this instance.
7.12 The site is not located within or immediately adjacent to any
Scheduled Monuments. As such, ISA Objective 8 (Cultural Heritage
and Historic Environment) is satisfied in this instance.
7.13 The proposed housing allocation is deemed appropriate at this
location in that it would not impact on any core planning principles.
The development would be sited immediately adjacent and
opposite existing residential dwellings and also in close proximity to
the edge of the existing settlement. The map extract below (Figure
ix) illustrates the existing pattern of development at this part of the
village, and the proximity of the site to the existing built form
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7.14 Clearly the development would not lead to unacceptable ribbon
development; it would not be deemed tandem development. It
would not lead to unacceptable coalescence of settlements and
given its siting between existing properties it would be classed as a
form of infill, as such, cannot be described as unacceptable sporadic
development or an unacceptable extension to the settlement.
7.15 In addition it would not result in the loss of areas of public open
space and formal recreational land. Given the aforementioned, it is
asserted that the development would not be contrary to general
planning principles.
7.16 The development would sit comfortably at this location without
having any detrimental impact whatsoever on the character or
setting of the settlement. Furthermore, the development would not
have any detrimental impact on any features of the settlement such
as landscapes, townscapes or buildings of importance as a result of
its scale, density and prominence. As such, ISA Objective 8 (Cultural
Heritage and Historic Environment) along with ISA Objective 9
(Landscape) are both satisfied in this instance.
7.17 The proposal will not involve the re-use of suitable previously
developed land, hence, it is acknowledged that the site is a
greenfield site, as such, ISA Objective 7 (Soil) is not entirely satisfied
in this instance. The site has a road frontage boundary that fronts
onto an Heol Llaindelyn. As such, the site is readily accessible from
the existing public highway. The site has a number of existing and
established field entrances with adequate visibility splays, which
allows direct access into the site.
7.18 Heol Llaindelyn is not a through-road, and is a relatively quiet road
which primarily serves 3-4 residential properties. Heol Llaindelyn
does not access directly onto the A477 Trunk Road, but is accessed
via the Old Tenby Road. The junction onto the A477 Trunk Road, also
known as Tenby Road is served by adequate visibility splays.
7.19 The map below (Figure x) illustrates the number of crashes in the
immediate vicinity of the site.
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Figure x (Source:Crashmap.co.uk)
7.20 Data obtained from Crashmap.co.uk confirms that in the last 10
years, there have been no slight, serious or fatal crash incidents
along Heol Llaindelyn or the Old Tenby Road, and, only one slight
accident on close to the A477 road junction. This would suggest that
there are no highway issues relating to the site or the public road(s)
which serve the site.
7.21 The site lies in close proximity to National Cycle Network Route 4,
which is approximately ½ mile away. This is illustrated on the
Sustrans National Cycle Network Map extract below (Figure xi).
Figure xi (Source Sustrans)
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7.22 In addition, the site would be very accessible to a number of
footpaths as identified on the Active Travel Network Map,
annotated in green on the plan extract below (Figure xii).
Figure xii – Source: Active Travel Network Map
7.23 The site is readily accessible to a local bus services with the nearest
bus stop less than a 5 minute walk away.
7.24 It is considered the site has suitable access to public transport as
well as identified active travel routes, as such, satisfies the following
ISA Objectives; ISA 3 (Air Quality), ISA 4 (Climatic Factors), ISA 6
(Material Assets), ISA 12 (Health & Well-being), ISA 13 (Education
s& Skills), ISA 15 (Social Fabric).
7.25 Given its location within a field enclosure, the site lies immediately
adjacent to an accessible green space. In addition, the site is very
accessible to a number of identified play areas in the settlement of
St Clears. The nearest play space identified on the LDP Proposals
Map is approximately 600 metres away which represents a
reasonable walking distance. As such, it is considered the site
satisfies ISA Objective 12 (Health & Well-being) and ISA Objective 15
(Social Fabric) .
7.26 The site is within a reasonable walking distance of the service centre
which has a wide range of employment/retail provisions, services
and facilities. Whilst the site clearly occupies a rural location, it
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represents a very sustainable location given its close proximity to
the service centre.
7.27 It is considered the site is within a reasonable distance of a number
of employment and retail provisions as well as other local services
and facilities, given its proximity to St Clears. As such, the site
satisfies the following ISA Objectives; ISA 6 (Material Assets), ISA 10
(Population), ISA 14 (Economy), ISA 15 (Social Fabric).
7.28 The site represents a sustainable location in terms of its proximity
to nearby nursery schools. The site is also within a reasonable
distance of Whitland Secondary School (7.5km) and St Clears
Primary School (0.5km). As such, ISA Objective 13 (Education &
Skills) is satisfied in this instance.
7.29 The site is not located within or adjacent to a mineral buffer zone,
as such, ISA Objective 6 (Material Assets) is satisfied in this instance.
The site is partly located within a Mineral Safeguarding Area, as
such, ISA Objective 6 (Material Assets) is not entirely satisfied in this
instance. The site is not located within or immediately adjacent to
an a Air Quality Management Area (AQMA), as such, ISA Objective
3 (Air Quality) is satisfied in this instance.
7.30 The site does not contain high carbon e.g. peatlands, as such, ISA
Objective 7 (Soil) is satisfied in this instance. The site does not
contain high quality agricultural land (grades 1,2 or 3A, as identified
within the Agricultural Land Classification Maps). As such, ISA
Objective 7 (Soil) is satisfied in this instance.
7.31 The site is not located within or immediately adjacent to any
Regionally Important Geological or Geomorphological Sites. As
such, ISA Objective 9 (Landscape) is satisfied in this instance.
7.32 The site is located within close proximity to a viable water
connection and is also located within close proximity to other viable
infrastructure requirements such as electricity and main sewer.
7.33 The site is not located within or adjacent to a phosphate sensitive
SAC catchment. A such, As such, the site satisfies the following ISA
Objectives; ISA 2 (Biodiversity), ISA 5 (Water) & ISA 7 (Soil).
7.34 The site by virtue of its scale and location, would not have the
potential to have a detrimental impact on the Welsh Language. As
such, ISA Objective 11 (Welsh Language) is satisfied in this instance.
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7.35 The traffic movements associated with the development proposal
will be marginal and the development could be accommodated on
the highway network and will not have a detrimental impact on the
free flow of traffic due to the existing volumes of traffic using the
local highway network. There are no access or transport constraints
to prevent the development of the site for residential purposes.
7.36 It is asserted that owing to the nature of the development proposal
i.e. residential, the development has due regard to the existing built
form and also character and appearance of the surrounding area.
Careful consideration has been given to the site selection to ensure
the relationship between the proposed dwellings and existing
development in close proximity is acceptable. It is considered that a
housing site at this location would conform with the character and
appearance of the immediate area in terms of siting and land use.
7.37 It is not disputed that the siting of residential dwellings at this
location would introduce built form at an otherwise undeveloped
site. However, the dwellings would not represent a prominent or
conspicuous form of development. While the proposed
development would inevitably change the character of the site
itself, the proposed changes would not be to the extent that would
result in an unacceptable impact on the surrounding landscape.
7.38 The development would not be readily visible from the wider area;
the mature trees and vegetation along the site boundaries would,
to a degree, mitigate any visual impact.
7.39 Given the aforementioned, it is considered that any resulting
development would not be inappropriate or disproportionate in
scale. It is on this basis that it is considered that the proposal would
represent a sensitive form of development, commensurate with the
existing built form, hence would not adversely affect the spatial
character of the village.
7.40 The development would not have a significant impact on the
amenity of adjacent land uses, properties, residents or the
community. The impact on the amenity of nearby residents has
been fully considered and duly discounted, particularly given the
separation distance between the site and the nearest residential
properties.
7.41 Overall, the proposed development would satisfy PPW’s objective
of achieving sustainable development both by ensuring that the
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local community has access to sufficient housing and affordable
options whilst also working to facilitate a modal shift to more
sustainable methods of transport and reducing car borne journeys.
8 Summary and Conclusion
8.1 This Planning Statement has been completed on behalf of Owain
Ennis, Anne Birt and Hugh Booth Meller-Haley and provides
planning support for the inclusion of additional land in the revised
Local Development Plan to accommodate potential residential
development adjacent to Heol Llaindelyn, St Clears.
8.2 It has been established that the principle of residential development
is compliant with both national and local policy and represents an
acceptable form of development at this location. The development
would assist with the housing land supply situation in the county.
8.3 While residential development at this location would inevitably
change the character of the site itself, the proposed changes would
not result in an unacceptable impact on the surrounding landscape
nor would they have an adverse impact on the existing neighbouring
development, highway network or local infrastructure.
8.4 In conclusion, it has been demonstrated that there are significant material considerations weighing in favour of the inclusion of this site for residential development in the upcoming revised local development plan.