Allocate the site for housing within the Revised LDP.

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Card Property Developments to
prepare and submit an Alternative Allocation Report for the allocation of land off
Cwmamman Road, Glanaman for the purposes of residential development in the
forthcoming replacement Carmarthenshire Local Development Plan (LDP).
1.2 This report has been prepared in line with the Authority’s published site assessment
and selection documents. The contents of this report therefore address each point
raised within these documents as well as ensuring that it complies with regards to the
guidance and requirements of Planning Policy Wales (Edition 11) when it comes to
the preparation of development plans and the allocation of land for residential
purposes as part of them.
1.3 The contents of this report therefore provide a comprehensive case for the allocation
of the land for residential development purposes, and it should also be read in
conjunction with the accompanying information and indicative drawing package, as
well as a sustainability assessment undertaken in-line with the Authority’s
requirements.
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman

2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Alternative Site relates to a parcel of land measuring approximately 11 acres in
area in total, edged red on the plan and the photograph below.
Plan A
Photograph 1
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman
2.1.2 As can be seen, the Site consists largely of two parcels of land, both of which consist
of areas of semi-improved grassland, as illustrated below.
Photograph 2 Photograph 3
2.1.3 As can be seen from the above photographs, the site slopes gently downwards in
south to north direction. In addition, all its boundaries are clearly and well defined, the
majority of which are mature tree lines or hedgerows. The exception is the northern
boundary, which is defined by post and wire stock proof fencing that borders with
Cwmamman Road.
2.1.4 Access to the site is currently gained via an existing field entrance off a private
access lane that runs along the western boundary of the site. However, any future
development would gain access directly off Cwmamman Road, due to the excellent
visibility in both directions from this point, as established in a previous planning
appeal for residential development on the site.
2.1.5 Under the provisions of the current Carmarthenshire LDP, part of the Alternative Site
is currently allocated for residential development (shaded brown in Plan B).
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman
Plan B
2.1.6 Following a positive pre-application enquiry with the Authority (LPA Ref. No.
PRE/01244), our Clients (the new owners of the site) are now progressing with a
planning application for the current allocation area. However, due to the level of
demand for new housing in the area, this submission as part of the 2nd Deposit LDP
consultation process therefore seeks allocation of the remainder of the land
ownership for residential development purposes.
2.2 THE ADJOINING SETTLEMENT
2.2.1 As detailed above, the Alternative Site adjoins the existing built form of the settlement
of Glanaman and is in fact bordered by it on much of its three sides. The Site is also
located a short distance from the settlement’s core to the north east and within
walking distance of a number of its community facilities and local services.
2.2.2 Access to further facilities in adjoining settlements and those areas adjoining the
County can then be gained by regular bus services (including numbers 64, 124, 145
and 146), a number of stops for which are within a short walk of the Alternative Site.
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman
The strong sustainable position of the urban area should therefore be given full
consideration when considering potential future growth options.
2.2.3 In terms of planned growth for Glanaman/Garnant, the 2nd Deposit LDP currently
contains only two small housing allocations (amounting to only 20 units) for the Plan
period. This in itself is surprising, considering the sustainable qualities of the
settlement and in particular the current land owners commitment to the development
of the Site in question.
2.2.4 In addition to the above, the proposed Alternative Site lies in close proximity and is
well related to one of the 3 identified Principal Centres within the 2nd Deposit LDP
Within these areas, the majority of the County’s growth (particularly with regards to
housing) is expected to be accommodated within the Plan period. However, having
undertaken a comprehensive review of the proposed allocations put forward by the
2nd Deposit LDP for the Principal Centre in question, it has been identified that a
number have significant questions over their ability to be delivered within the Plan
period, including the following:
Ref. No. Site Name Units
PrC3/h4 Tirychen Farm 150
PrC3/h36 Betws Colliery 60
PrC3/h14 Nantydderwen, Tumble 33
PrC3/h22 Adj. to Pant y Blodau, Penygroes 79
PrC3/h2 Heol Gelynen, Brynamman 8
Table 1
2.2.5 As a result of the above, separate objections have been made in relation to the above
allocations and it is therefore important that alternative more deliverable sites should
be identified, to ensure the Plan can be regarded as being ‘sound’.
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman

3.0 THE PROPOSAL
3.0.1 As part of the requirements for the promotion of sites for residential development, this
Statement is accompanied by an indicative layout for a potential residential scheme
that could be developed on the site. It should be emphasised that the accompanying
layout is for illustrative purposes and that other design solutions for the site could also
be reached. Notwithstanding this, the accompanying layout drawing has taken
account of all the potential assets and constraints of the site, as well as current
Authority design guidance, and demonstrates that it is capable of delivering 84 units
in a deliverable and sustainable manner. The following information therefore expands
on this principle.
3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Candidate Site be allocated in the forthcoming replacement
LDP for the purposes of 84 residential units. As detailed above, the accompanying
illustrative layout (reproduced below) demonstrates that the site is capable of
accommodating this number in a deliverable and sustainable manner.
Plan C
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman
3.1.2 As illustrated above, the site is potentially capable of accommodating a mix of unit
sizes and types, with the associated density – 84 units – having therefore taken into
consideration this potential mix. Such a mix would also include a proportion of
affordable units.
3.1.3 With regards then to access, it is proposed that the Alternative Site would be served
be a new access point (following that approved previously) directly off Cwmamman
Road, running along the Site’s northern boundary. The Site would then be served by
a new public highway designed to adoptable standards, as well as a series of private
shared drives where required.
3.1.4 The Alternative Site proposal would also retain and strengthen existing boundary
treatments, as well as accommodating further biodiversity enhancements within a
detailed scheme for the site.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Any development of the Alternative Site for residential units would be served by
mains water, public sewer and electricity, connections to which we understand lie
within or in close proximity to the Site.
3.2.2 With regards then to surface water, it is considered that as a result of on-site
features, there would be a number of options available to any development of the site
in terms of its disposal, ensuring its development adheres to current regulatory
requirements.
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman

4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 Any potential biodiversity assets the Site may include have been given full
consideration with regards to exploring its potential for residential development. This
has included the proposed retention and management of existing site boundary
features, together then with the provision of mitigation measures where required as
part of any detailed design solution prepared for the Site as part of any future
planning application.
4.1.2 The Alternative Site has been assessed against data held on the “Magic Map”
website which details statutory and non-statutory National and Local sites of
ecological importance. Plan D below provides an extract of those records applied to
the Glanaman locality, with the red star denoting the position of the Alternative Site.
Plan D
4.1.3 As can be seen from the above, the Alternative Site does not form part of and neither
is it near any national or local designations. Although a number are within 2-4km of
the site, due to the intervening distance and topography, the development of the
Alternative Site will not have any detrimental impact on these features.
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman
4.2 HISTORICAL ASSETS
4.2.1 Below is an extract from the ‘Archwilio’ website that represents a resource for the
Historic Environment Records of Wales, with the Alternative Site indicated by a red
star.
Plan E
4.2.2 As can be seen, neither the Alternative Site nor immediately adjoining element of the
settlement includes any Scheduled Ancient Monuments, Listed Buildings or
Conservation Area’s. As a result, the development of the Site would not have any
detrimental impact on the setting or interest of any nearby historical asset.
4.3 ENVIRONMENTAL CONSTRAINTS
4.3.1 The Candidate Site is not categorised as being at risk of flooding in terms of the
Development Advice Maps or those produced by Natural Resources Wales, as
illustrated by the plans below (Alternative Site indicated by the red star).
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman
Plan F
(Development Advice Maps)
Plan G
(Flood Maps for Planning)
4.3.2 Due to its greenfield nature, the Candidate Site has no ground contamination related
constraints.
4.3.3 Much of the Amman Valley has a history of previous coal mining activity and the area
around the Alternative Site is no exception, as illustrated by the accompanying Coal
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman
Minin Risk Assessment report prepared for the soon to be submitted planning
application. However, as can be seen from the accompanying report, there are no
fundamental attributes associated with the areas mining history that would prevent
the delivery of the Alternative Site.
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman

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 these aspects is to then risk that the Plan may be unsound and so in turn fail 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 such appraisals at a strategic or in-principle level.
The following therefore represents such a process and is fit-for-purpose in providing
confidence with regards to both the viability and deliverability of the Alternative Site at
this stage, but it should be noted, that more detailed analysis at a planning
application stage may result in some variance.
5.1 VIABILITY APPRAISAL
5.1.1 The following provides an indication of the viability of delivering the proposed 6 units
on the Alternative Site in question. It is based very much on its greenfield status and
uses figures 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 value
for the scheme, prior to ascertaining an indicative land value.
Costs
 Dwelling construction costs are based on £1,250 per metre (allowing for
ground conditions)
 Adoptable road construction cost based on £1200 per metre
 Connections for all utilities include water, foul water and electric
 Developer’s Profit based on RICS guidelines (18%)
 Professional Fees include planning application fee, associated professional
fees, estate agency fees (1%) and LABC Warranty fee.
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman
Sales
 Sale Prices based on LPAs Affordable Housing SPG, market research and
ACG figures where relevant.
5.1.2 Using the above, the following represents a strategic viability appraisal for the
proposed 84 units, with 16 units being made available on an affordable basis (based
on 16 three bed units).
Costs Cost Per Unit/Metre No. Units/Metres Total
2 Bed Det House (88 sq.
m.) 110000 38 4180000
3 Bed House (115 sq. m.) 143750 30 4312500
3 bed bungalow (120sq m) 150000 5 750000
4 Bed (144 sq m) 180000 11 1980000
Road Construction 1200 800 960000
Utility Connections 5000 84 420000
Professional Fees - 1758548
Sprinklers 3500 84 294000
Parks and Education Cont. 5000 84 420000
Total 5832548
Sales
3 Bed semi(115 sqm) (Aff.) 78380 16 1254080
2 Bed Det House (88 sq.
m.) 165000 38 6270000
3 Bed House (115 sq. m.) 200000 14 2800000
3 bed bungalow (120sq m) 230000 5 1150000
4 Bed (144 sq m) 265000 11 2915000
Total 14389080
Developers Profit Total 2590034.4
Residual Land Value 5966497.6
Table 2
5.1.3 Although the above figures have not been able to take into account any future
changes to construction costs as a result of other external factors (e.g. changes to
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman
Building Regulations), it is considered that in-principle, the development of the site
would be financially viable.
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, it is envisaged that the site could be capable of being
completed within 4-5 years from the adoption of the Replacement Local Development
Plan.
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman

6.0 NATIONAL PLANNING POLICY CONSIDERATIONS
6.0.1 In the preparation of any development plan, consideration must be given to national
policy and guidance. At present, this takes the form of Planning Policy Wales (PPW)
(Edition 11) and a series of Technical Advice Notes (TAN) that deal with a range of
topic areas.
6.1 HOUSING SUPPLY
6.1.1 With regards to the provision of housing, Paragraph 4.2.2 of PPW gives the following
requirements the planning system must fulfil:
 Identify a supply of land to support the delivery of the housing requirement to
meet the differing needs of communities across all tenures;
 Enable the provision of a range of well designed, energy efficient, good quality
market and affordable housing that will contribute to the creations of sustainable
places; and
 Focus on the delivery of the identified housing requirement and the related land
supply
6.1.2 In addition to the above, Paragraph 4.2.10 of PPW states “the supply of land to meet
the housing requirement proposed in a development plan must be deliverable”. As
detailed previously, it is considered that the LPA has to date failed to accomplish this
requirement under the provisions of the current LDP and will continue to do so under
the provisions of the proposed allocations of the 2nd Deposit LDP.
6.1.3 In order therefore to re-dress this deficiency in provision, and provide a more robust
approach to housing provision through a mixed site-scale approach, there is an
urgent need to identify alternative deliverable housing allocations in the replacement
Plan. Based on the accompanying information, it is clear that the Alternative Site
represents one such example.
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman

7.0 CONCLUSION
7.1 Although currently undeveloped, the Alternative Site forms a logical existing element
and extension to an existing settlement, being well related to it and being positioned
at a location within the wider landscape to not form a prominent or logical part of the
surrounding open countryside.
7.2 In addition to the above, the Site lies within close proximity and walking distance of
the existing community services and local facilities of the adjoining settlement, as well
as an element of the larger conurbation of Ammanford to the west. This will then
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 adjoining larger conurbation of Ammanford and indeed beyond,
together with other locations within and adjoining the County, further increasing the
facilities and services available to future residents of the Site via sustainable transport
means.
7.4 In tandem to the above, the development of the Site will in turn ensure a viable and
so deliverable source of future housing for the area it forms part of, which has seen a
dangerous level of under supply prior to and 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 closely scrutinises those sites currently proposed for
allocation in the 2nd Deposit LDP in terms of their suitability and deliverability.
National planning policy however would suggest that in view of the uncertainty in
relation to their delivery, such sites should not form part of the replacement LDP.
7.5 With the Alternative Site having no access, ground condition, flood risk, hydrological,
ecological, archaeological or land ownership related constraints, its delivery if
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman
19
allocated is assured. Combined therefore with its locational characteristics, the Site in
question represents a sustainable candidate for future housing development.
7.6 In view of the above and information provided in this Statement, it is respectfully
requested that the Alternative Site in question be designated for residential
development.