Include site within the Plan.

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Mr A Hughes to prepare and
submit an Alternative Allocation Report for the allocation of land off Llannon Road,
Upper Tumble 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 April 2023
Land off Llannon Road, Upper Tumble

2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Alternative Site relates to two parcels of land measuring approximately 1.4 acres
in area in total, edged red on the plan and the photograph below.
Plan A
Photograph 1
Alternative Allocation Report April 2023
Land off Llannon Road, Upper Tumble
2.1.2 As can be seen from Photograph 1, the Site currently consists of two parcels of poor
quality agricultural land, with all their boundaries well defined by a mix of mature
hedgerows and stock proof fencing (east and west), together with domestic and
commercial fencing (north and south).
2.1.3 Access to the Site is currently gained via an adjoining agricultural enclosure to its
west. However, any development of the Site would gain access directly off Llannon
Road, which has excellent levels of visibility as illustrated below.
Photograph 2 Photograph 3
2.1.4 Under the provisions of the current Carmarthenshire LDP, the Site presently lies
outside of the defined Development Limits of the settlement of Upper Tumble.
However, as the extract of the Proposals Map below illustrates, the Site (outlined in
red) not only adjoins the current built form of the urban area, but is in fact almost
entirely encapsulated by it.
Alternative Allocation Report April 2023
Land off Llannon Road, Upper Tumble
Plan B
2.1.5 As can be seen, the Alternative Site is therefore well related to the existing defined
Development Limits for Upper Tumble and the settlement’s built form as a whole
when existing development is taken into consideration. Its position and proposed use
therefore represents a natural and logical location for the settlement’s expansion.
2.2 THE ADJOINING SETTLEMENT
2.2.1 As detailed above, the Alternative Site adjoins the existing built form of the settlement
of Upper Tumble. Upper Tumble is a nucleated settlement in form, with its core
positioned just to the north of the Alternative Site. From this then it has evolved and
grown along the three roads of Llety Road, Llannon Road (A476) and the B4310, in a
both linear and in-depth fashion.
2.2.2 In terms of community facilities and local services, the settlement of Upper Tumble
and adjoining Tumble contains a wide range, including dental and doctor surgeries,
primary school, a range of retail units, public houses, takeaway establishments,
community halls and places of worship. The settlement is also well served by a
number of bus services – Nos. 128 and 166 (two bus stops for which are within 200m
of the Site) - providing regular access to the larger settlements of Cross Hands,
Llanelli and Carmarthen. The strong sustainable position of the Alternative Site
should therefore be given full consideration when considering potential future growth
options.
Alternative Allocation Report April 2023
Land off Llannon Road, Upper Tumble
2.2.3 In terms of planned growth for Upper Tumble, the 2nd Deposit LDP classifies the
settlement as forming part of the greater Cross Hands urban area and so categorises
it as a Principal Centre under its proposed Settlement Framework. 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
2.2.4 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 April 2023
Land off Llannon Road, Upper Tumble

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 20 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 20 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 D
Alternative Allocation Report April 2023
Land off Llannon Road, Upper Tumble
3.1.2 As illustrated above, the site is potentially capable of accommodating a mix of unit
sizes and types, with the associated density – 20 units – having therefore taken into
consideration this potential mix. The form of development for the Alternative Site is
also capable of following the current development pattern established by similar
developments along Llannon Road, such as Troed y Bryn, Llys Ifan and Banc y Gors,
therefore maximising the use of the Site.
3.1.3 With regards then to access, it is proposed that the Alternative Site would be served
by a single point of access directly off Llannon Road. As can be seen in the
Photographs at Section 2, the required level of visibility is achievable in both
directions.
3.1.4 The Alternative Site proposal can retain and enhance 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 April 2023
Land off Llannon Road, Upper Tumble

4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 The Site does not contain any protected flora or fauna, or signs of their presence.
Notwithstanding this, 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.
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 E below provides an extract of those records applied to
the Upper Tumble locality, with the red star denoting the position of the Alternative
Site.
Plan E
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 April 2023
Land off Llannon Road, Upper Tumble
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 F
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 April 2023
Land off Llannon Road, Upper Tumble
Plan G
(Development Advice Maps)
Plan H
(Flood Maps for Planning)
4.3.2 Due to its greenfield nature, the Candidate Site has no ground contamination related
constraints.
Alternative Allocation Report April 2023
Land off Llannon Road, Upper Tumble

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 £1,150 per metre
 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 April 2023
Land off Llannon Road, Upper Tumble
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 20 units, with 3 units being made available on an affordable basis (based
on 3 three bed units).
Costs Cost Per Unit/Metre No. Units/Metres Total
3 Bed Det. (110 sqm) 126500 2 253000
3 Bed Semi (90 sqm) 103500 12 1242000
2 Bed Link (70 sq m) 80500 6 483000
Utility Connections 5000 20 100000
Road and Access 1200 150 180000
Professional Fees - 92632
Sprinklers 3500 20 70000
Parks and Education
Cont. 5000 20 100000
Total 2520632
Sales
3 Bed Semi (130 sqm)
(Aff) 77762 3 233286
3 Bed Det. (160 sqm) 260000 2 520000
3 Bed Semi (130 sqm) 210000 9 1890000
2 Bed Link (90 sq m) 150000 6 900000
Total 3543286
Developers Profit Total 637791.48
Residual Land Value 384862.52
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
Building Regulations), it is considered that in-principle, the development of the site
would be financially viable.
Alternative Allocation Report April 2023
Land off Llannon Road, Upper Tumble
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 2-3 years from the adoption of the Replacement Local Development
Plan.
Alternative Allocation Report April 2023
Land off Llannon Road, Upper Tumble

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 April 2023
Land off Llannon Road, Upper Tumble

7.0 CONCLUSION
7.1 Although currently undeveloped, the Alternative Site forms a logical 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. As has been demonstrated by this report, the Site in fact represents a
logical infill site within the existing urban form of Upper Tumble.
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. 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 Cross Hands and indeed Llanelli
and Carmarthen, 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 allocated in the
LDP in terms of their suitability and deliverability if it is to continue to allocate them.
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 April 2023
Land off Llannon Road, Upper Tumble
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.