Amend Policy

This representation is made in response to the ‘Carmarthenshire County Council Second Deposit Revised
Local Development Plan’ (“the LDP”) consultation and is submitted on behalf of Mr James George.
Mr George owns “Llwyndu” Land at Milo, Llandybie (‘the site’) which has been considered in the Candidate
Sites Register Assessment for potential inclusion within the LDP. The site can be seen, outlined in red, on
the plan found at Appendix 1.
It is respectfully suggested that the site should be allocated in the LDP, to provide confidence that houses
can be delivered to meet local needs in Milo. Alternatively, the site is capable of meeting the criteria set out
in the proposed policy framework of the LDP to allow its development for new homes, so long as some
flexibility and judgment can be applied.
THE SCALE OF PROPOSED GROWTH
We support the ambition and principle of the LDP, and specifically the targets set out in Policy SP1:
Strategic Policy - SP1: Strategic Growth
The LDP will provide for the future growth of a sustainable economy and housing
requirement through the provision of:
a. 9,704 new homes to meet the identified housing requirement of 8,822.
b. A minimum of 71.21ha of allocated employment land.
The focus on regeneration and growth reflects the Council's core strategic ambitions with
development distributed in a sustainable manner consistent with the spatial strategy and
settlement framework.
It is clear that the Council has taken seriously its responsibility to support he delivery of the homes and jobs
which are needed in Carmarthenshire. The targets appear aspirational, but realistic. What should not be
overlooked in these strategic targets however is the very real need to support the more rural parts of the
community and meeting their needs.
Sites like “Llwyndu” Land at Milo, Llandybie provide a valuable opportunity to deliver new homes in a rural
hinterland which supports an overall network of social and economic growth. This growth is set out in the
LDP, and the site could be delivered through an allocation, or as a windfall – and either way, it would
contribute to the overall housing target set by the Council.
MILO AS A LOCATION FOR GROWTH
Introduced in chapter 10 of the LDP is the concept of “Clusters” and Milo falls within the settlements grouped
in “Cluster 3: Amman and Upper Gwendraeth.”
We note with interest the way in which Cluster 3 is described in the LDP. In particular, we note the following
elements of the spatial portrait, and that the cluster:
“…is characterised by a series of interrelated settlements; [and]
…has grown as a centre with a focus for investment in jobs, homes, and services.”
And specifically, that:
“Ammanford …plays an important service centre role by providing localised retail, employment,
education, and leisure facilities.”
We also note that:
Cross Hands as a former mining community has developed over recent decades through its position
on the A48 strategic transport route.
Regarding Cross Hands, it is exciting to see a range of significant economic growth is planned to include:
• PrC3/E1 – Employment allocation of some 8.31 Ha
• PrC3/E3 - 4.76 Ha extension to business park
• SG2/3 – reserved expansion area for large scale employment uses.
This growth will also be accompanied by:
TRA1: Transport and Highways Infrastructural Improvements
Transport routes, improvements and associated infrastructural facilities which deliver the objectives
and priorities of the Joint Transport Plan for South West Wales (2015 – 2020) will be supported.
The improvements to the highway infrastructure as part of the Cross Hands Economic Link Road will
be safeguarded with the route identified on the proposals map.
Proposals which maintain and enhance an integrated sustainable transport network will also be
supported where they accord with the policies and provisions of this Plan. Development proposals
which do not prejudice the efficient implementation of any identified improvement or scheme will be
permitted.
Land at Milo, Llandybie is approximately 4 miles from Cross Hands via the A476 and the new Cross Hands
relief road, avoiding additional traffic on the congestion pinch points of the Cross Hands roundabout and
Gorslas.
These points suggest that each settlement in the cluster has a role to play in supporting the successful social
and economic activity in the area, and that the services and facilities of the larger settlements, support a
hinterland of slightly dispersed but nonetheless connected communities.
To maintain this success, and to ensure the continued vitality of the more rural communities it is vital that
development is allowed to happen at all tiers (and sizes) of settlement in the cluster.
We note that potential development in Milo is proposed to be manged primarily through two policies: SP3:
Sustainable Distribution, and HOM3: Homes in Rural Villages.
Therefore, taking each of these policies in turn:
STRATEGIC POLICY – SP3: SUSTAINABLE DISTRIBUTION – SETTLEMENT FRAMEWORK
We generally support the principle of this policy. Settlement hierarchies are a well-recognised way of
managing growth and directing it to the most sustainable locations, and it is important that the role of smaller
settlements such as Milo is not over looked, and that the needs of people who live in these more rural
locations are also met.
We note that Milo is listed as a “Tier 4 – Rural Villages (No development limits).” On the face of it, given the
size of Milo this is reasonable, and the fact that the village is a well-connected part of the ‘cluster’ is also
recognised.
Furthermore, we read with interest in the supporting text to Policy SP3 that in “Rural Villages (No
Development Limits)” the following scale of development will be acceptable:
• Small sites – housing through infill or logical extensions/rounding off.
• Small Scale Rural Exceptions Schemes for Affordable Housing
We respectfully suggest that Land at Milo, Llandybie represents a small infill site as presented in the
supporting text to Policy SP3. The site should be allocated as such in the LDP to provide confidence that it
will be delivered in the plan period to help meet both the strategic needs of Carmarthenshire and specifically
the local housing needs in “Cluster 3: Amman and Upper Gwendraeth” and Milo.
HOM3: HOMES IN RURAL VILLAGES
Should the Council decide that Land at Milo, Llandybie does not need to be allocated for development, the
site has the potential to be delivered as ‘windfall,’ broadly in conformity with proposed Policy HOM3.
There are, however, some element of this proposed policy which are somewhat arbitrary, and we suggest
that some flexibility and planning judgement is allowed, to ensure the most appropriate development
opportunities are delivered, and the most efficient use is made of land.
In particular we note that proposed Policy HOM3, suggests the following:
In those settlements identified as rural villages under Policy SP3, proposals for 1 to 4 dwellings will be
permitted for the following:
• minor infill of a small gap between the existing built form; or,
• logical extensions and/or rounding off of the development pattern that fits in with the character of the
village form and landscape; or
• conversion or the sub-division of large dwellings.
Such proposals will be subject to other detailed planning considerations set out within LDP policies.
As we have explained in response to proposed Policy SP3, and is elaborated upon in our site specific
comments - Land at Milo, Llandybie is a sensible and logical infill site. However, because the most logical
infill is for 6 new homes the potential to develop the site would – in principle – be contrary to proposed Policy
HOM3, but the 1 to 4 dwellings requirement is entirely arbitrary and does not appear to be justified in the
supporting text to the policy, or in any supporting evidence.
We suggest therefore that the reference to 1 to 4 dwellings is removed from the policy text, and this would
have a limited effect on how the policy operates. There is still sufficient scope for a ‘case by case’
assessment of the acceptability of infill sites, and for some flexibility to be applied where perhaps 6 houses
might be more appropriate and in character with a site’s surrounds, but equally importantly it makes an
efficient use of land.
The final paragraph of proposed Policy HOM3 is also arbitrary and not justified in evidence that we have
been able to identify. The following part of the pollciy is not necessary, and should be removed:
Proposals which exceed the 10% cap above the number of existing homes in the settlement, as at
the LDP base date, will not be permitted except where they conform to Policy AHOM1 in relation to
the provision of affordable homes.
By way of an example, there are currently 50 homes in Milo, and Land at Milo, Llandybie can deliver 6 infill
homes, but this would be apparently contrary to proposed policy HOM3 (by a factor of a single house) for no
reason other than it breaches an arbitrary 10% cap. This risks both the viability of schemes, and the efficient
use of land.
“LLWYNDU” LAND AT MILO, LLANDYBIE
Turning to the site which we are proposing should be allocated for development. This submission
commends to the Council, Land at Milo, Llandybie (‘the site’) which has been considered in the Candidate
Sites Register Assessment for potential inclusion within the LDP.
The site address is as follows:
Llwyndu
Milo
Llandybie
Ammanford
SA18 3NQ
The site has been assessed by the Council and the site reference is SR/114/001. The assessment of the
site states
“The site may comply with the provisions of the Preferred Strategy, however each individual site will
require assessment at application stage to ensure it complies with the relevant specific policy. In
respect of this settlement, the Preferred Strategy identifies it as a Tier 4 with no development limits”
We support the general assessment of the site and suggest that it should be allocated for development to
provide confidence in its delivery.
However, should the Council disagree with this position, we remain confident that the site is acceptable, and
achievable as infill development.
Site Context
The site comprises 4.64 acres of agricultural fields within the settlement of Milo, which is identified in Policy
proposed policy SP3 as a sustainable community. A site location plan, which was submitted with our initial
submissions to the candidate sites register is included again for completeness (Appendix 1).
The site benefits from an existing access with good visibility onto the main road running through Milo, as
shown in Figure 1 below.
Figure 1 – Access to the site from the main road through Milo (Google Street View - 2011)
The site is bound by agricultural fields to the south west, residential properties to the south east and a chapel
to the North West. The site is bounded by the road to the north east, whilst two and three storey residential
properties lie on the opposite side of the road.
There are two listed buildings to the north of the site: Capel Milo (ID: 22200) and Hen Gapel Milo (ID:
22199).
The village of Milo contains around 50 homes. Milo is approximately 4.5 miles north of Ammanford, which is
recognised as a growth area in proposed Policy SP3 and the heart of a cluster or network of connected
communities. Milo is approximately 5 miles south west of Llandeilo which is also identified as a service
centre. There is a bus service from Milo to Llandeilo.
Proposed Development
It is considered that the site could be developed along the road following the existing linear patter of built
form in Milo. In this case, it is considered that the site could comfortably accommodate approximately six
dwellings and utilise the existing access, as shown in Figure 1 above. Such development would mirror the
existing settlement and would constitute ‘infill’ development, as supported in proposed Policies SP3 and
HOM3.
As highlighted within our initial submission, an alternative option is to develop the whole of the site, again
utilising the existing access, which could accommodate approximately 15 dwellings, thus triggering the need
for affordable housing which would provide additional benefits to the locality.
Two broad indicative layouts were provided within our initial submission and have been included again for
completeness (see Appendix 2).
The site also lies within a sustainable location within Milo itself, located approximately 140m to the local bus
stops from the existing access into the site shown in Figure 1 above.

CONCLUSION
We are pleased to have had the opportunity to comment on the ‘Carmarthenshire County Council Second
Deposit Revised Local Development Plan.’ We support the general vision, and approach of the LDP but
suggest that some flexibility and room for judgement must be retained to allow for the continued vitality of
some of the more rural parts of the county.
“Llwyndu” Land at Milo should be allocated for development to provide some confidence that local housing
needs will be met. However, failing that the site is capable of providing a reasonable ‘windfall’ development
as infill.
As has been demonstrated above, the site (SR/114/001) constitutes a suitable and sustainable form of
development within the settlement of Milo.
Overall, it is considered that the site (SR/114/001) constitutes the only suitable and sustainable Candidate
Site within Milo for residential development. The site is capable of mirroring the linear form of development
that exists along the main road through Milo, and would therefore be a logical means of increasing housing
within this sustainable community (as promoted through proposed Policy SP3 Local Development Plan).
I trust the information provided in this submission is sufficient. Should you require any further information,
please do not hesitate to contact me.