Remove HOM1 housing allocation PrC2/h1 from the Plan.

We are instructed by Mr D. Gravell to make a formal representation with regards to the
above land and the Second Deposit Draft of the Carmarthenshire Local Development Plan.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/0116/006, seeking the inclusion of their land within the development limits of
Mynyddygarreg as part of the Replacement Local Development Plan.

The Candidate Site comprises an irregular-shaped grazing paddock set off the western flank
of Llangadog Road that runs north to south from the centre of the village of Mynyddygarreg.
The proposals seek inclusion of the well-defined enclosure to provide a modest development
of detached and semi-detached houses to complement established properties which lie
directly alongside the road off the eastern flank of the road. It therefore represented a logical
opportunity for infilling within the settlement and providing a much-need and deliverable
residential opportunity which can generate 11 dwellings. Its extents are illustrated by the site
edged in red, being a site location plan, at Figure 1 below.

The Council published a First Deposit Draft of the Replacement Local Development Plan in
January 2020. At that time, the Council revealed its analysis of each submitted Candidate
Site within a “Site Assessment Table” (January 2020) We noted at that time that our Clients
land was considered as part of this process and as a result the Authority concluded that the
site had successfully passed through all four Assessment Stages, being Stage 1 (site
compatible against the location of future growth presented in the Preferred Strategy), Stage
2A (Initial Detailed Site Assessment), Stage 2b (Further Detailed Site Assessment) and
Stage 3 (Sustainability Appraisal and Habitat Regulation Assessment) of the Council’s site
assessment. Accordingly at Stage 4 the Council reported “Site to be allocated within the
revised LDP reference SuV22/h3”
Figure 1 – Location plan of Candidate Site at Mynyddygarreg
As a result of the above Council assessment, Figure 2 presents an extract of the First Deposit LDP Proposals Map for Mynyddygarreg, which clearly identified part of our clients’ land as within the defined development limits and allocated for Residential Development.
Figure 2 – Extract of Proposals Map for Mynyddygarreg with site included within settlement limits as shown by a red arrow

Our clients are therefore astonished to discover that upon publication of the Second Deposit Draft of the LDP, the Council have sought to amend the draft settlement limits, to exclude all the field frontage from within the proposed settlement limits. That new Draft Plan for this southern part of Mynyddygarreg is reproduced as Figure 3 below.
A new Site Assessment Table, dated January 2023, now indicates that the Council conclude that “The site includes High Grade Agricultural Land (Grade 2), whilst there are other opportunities to develop within the village.”
Figure 3 – Second Deposit Draft extract of Mynyddygarreg limits at Llangadog Road

Our clients consider the LDP is “unsound” and should be changed, as it fails to meet the tests for “soundness”, in that the Plan “is not appropriate”, and “will not deliver”, as defined by the Planning Inspectorate’s LDP Examinations Procedural Guidance.
Specifically, our clients consider that the draft settlement limits for Mynyddygarreg, as defined under Policy SD1 “Settlement Limits”, should be amended to include the land as edged in red upon the extract of the Proposals Map for Mynyddygarreg, as reproduced below in Figure 4. The land should be appropriately allocated for housing under Policy HOM1 “Housing Allocations.”
Figure 4 – Extent of Representation Site edged in red
This formal representation letter supplements the following documents which comprise a complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits

1.0 Overall Housing Supply at Mynyddygarreg and Cluster 2 within Deposit Draft

1.1 The Council consider that there are two reasons for the Candidate Site at Llangadog Road as not being included within the draft Plan as a Residential Allocation. One reason is that they believe that there are sufficient residential sites allocated elsewhere in the settlement. The second reason relates to the grading of agricultural land and that the Council now there years later from assessing and presenting matters in a First Deposit Draft, consider that constructing residential properties Grade 2 Agricultural Land in Mynyddygarreg is unacceptable? We will respond to that reason in the Section 3 of this Representation.

1.2 On this basis, it must be accepted that the form of the Candidate Site set as an infill opportunity between established properties which front the minor road running through this part of Mynyddygarreg, together with the proposals to create new vehicular accesses onto Llangadog Road is deemed acceptable, and in accord with the spatial form and character of the settlement.

1.3 The proposals under this Representation merely seek the addition of 11 residential units to the overall housing supply of Mynyddygarreg, which is regarded as a Tier 3 Sustainable Village, identified within the Llanelli within the draft LDP. Figure 5 below provides an extract of the indicative site layout plan for this Representation site. The proposals can provide a mix of 3 and 4 bed detached and semi-detached dwellinghouses all fronting the Llangadog Road frontage and allowing a safe buffer zone from the rear elevations of the proposed dwellings to an existing Welsh Water sewer apparatus that transverses the field enclosure.
Figure 5 – Proposed Indicative Site Layout Plan for Representation Site

1.4 The Llanelli Cluster (Cluster 2) aims to provide an additional 3039 residential units over the Plan period to 2033, with Mynyddygarreg (Settlement SuV22) providing two allocated sites at expected to provide a combined total of 31 units to that overall Cluster total (reproduced at Figure 6 below). We would submit in the first instance that the addition of an additional allocated site of 11 units will not lead to an over-supply of dwellinghouses within the Cluster, nor the defined Mynyddygarreg settlement supply.
Figure 6 – Extract from Policy HOM1 for Mynyddygarreg

1.5 We have examined and researched sites which have been brought forward as Residential Allocations with the Deposit Draft. In Mynyddygarreg, we consider reference should be made to the current adopted (2014) Local Development Plan to enable a comparison to be made as to the Council’s aspirations for the future growth of housing in that settlement. Great emphasis within the Draft Plan has been placed upon the continued allocation of the Gwenllian Gardens housing site, which was allocated from the 2008-21 Local Development Plan. The above table indicates that
the Council expect that site to be delivered to the market between LDP years 1-5 and 6-10, being 2018 to 2028. Indeed, construction works are at an advance stage on the site and we consider that it is reasonable to continue the allocation of this site.

1.6 However, we note that in the case of the other proposed allocation at “Land adjacent to Ty Newydd, Meinciau Road,” it is a new allocation having appeared as outside settlement limits in the 2014-adopted LDP, as reproduced at Figure 7 below.
Figure 7 - Extract of Current LDP Proposal Map for Mynyddygarreg
and Residential Allocations for Period 2008-21

1.7 The current Development Plan Map for Mynyddygarreg reveals the success of residential allocations in the village. Sites SC17/h1, h2 and h3 have all been completed, and site SC17/h4 is the Gwenllian Gardens site, which as referred to above, is under construction.

1.8 The draft allocation of “Land adjacent to Ty Newydd at Meinciau Road” for 8 dwellings is a new allocation in the Replacement LDP. We note that it was included in the First Consultation Draft in 2020, along with our client’s site at Llangadog Road as new allocations. It is immediately apparent that whilst Meinciau Road has been retained in the Second Draft Plan, our client’s draft allocation at Llangadog Road has been sacrificed. One of the grounds relates to our client’s land being classified as High-Grade Agricultural Land, but we have discovered that the Meinciau Road site is also classified under such a similar designation, and yet it remains in the Second Draft Plan.

1.9 We understand that the Meinciau Road site is under the ownership of Kidwelly Town Council, and yet no explanation has been given as to how that Candidate Site being brought forward by a non-private body is being preferred to a private individual’s Candidate Site which clearly through the absence of any regulatory controls is able to offer his allocated site to the market is a far more streamlined and practical manner.

2.0 Llanelli, Burry Port, Kidwelly and remainder of Cluster 2

2.1 We have examined and researched sites which have been brought forward as Residential Allocations with the Deposit Draft. Mynyddygarreg falls under the Llanelli Cluster which extends along the Burry Estuary coast from Kidwelly in the west to Bynea in the east, and north to Llangennech and Hendy about the M4 corridor.
Great emphasis within the Draft Plan has been placed upon the continued allocation of proposed housing sites still left allocated from the 2014-21 Local Development Plan. Figure 8 below provides an extract of such sites.
Figure 8 – Selection of Deposit Draft Housing Schedule in Llanelli Cluster

2.2 We note that within the Proposals Map for Burry Port, it included for three sites, two of which have been completed at Goodig and Glanmor Terrace leaving just one proposed site, which being the Harbourside site for 364 dwellings. The site has been marketed by the County Council for many years, and despite its coastal position, has failed to receive firm interest and any form of detailed planning application. Ground conditions require extensive remediation of former historic uses.

2.3 The Llanelli suburbs of Llwynhendy / Cefncaeau and Dafen, where four of the above allocations are identified, has not altered since the 2014 adopted LDP and remain undeveloped but re-allocated in the Deposit Draft.
Cwm-y-Nant (PrC2/h22) and Dafen East Gateway (h/23) were both sites allocated within the Carmarthenshire Unitary Development Plan (2006) and as mentioned above, within the Local Development Plan (2014) as sites GA2/h27 and h/30 & h/31.
They have a combined total of 352 dwellings, although neither site has been the subject of any detailed planning application, let alone market interest.
The locality is riddled with historic coal mining activity, with low lying coal seams, together with multiple mine entries across all Dafen sites. Clearly, any residential development upon either site will have to overcome ground remediation to stabilise the ground for residential foundations. The abnormal costs of which are likely to be significant, and hence present the development costs as leading to unviable and undeliverable sites.

2.4 Beech Grove at Pwll (PrC2/h1) has remained allocated for 10 units for the last 10 years in Development Plans. No application for planning permission has even been lodged at the site.

2.5 Cae Linda in Trimsaran (SeC8/h2) for 20 units has been in Development Plans stretching back to the Llanelli Borough Local Plan in 1995. It has only been developed with 5 houses, and thus its continued allocation for twenty more units in the draft LDP must surely come under question?

2.6 Consequently, at least twenty years of Development Plan allocations have elapsed without any signs of wholesale delivery of these sites. Clearly, there is no historic demand for sites of these scales in parts of the Llanelli, Trimsaran and Burry Port / Pembrey areas. All are certainly physically challenging sites, many of which have historic industrial or coal mining legacy issues, which may require significant abnormal costs to achieve developable areas for residential use.
We submit that the above draft allocations be omitted from the Plan, and that housing allocation be redistributed to Alternative Sites, of circa 10 units such as that proposed at Llangadog Road in Mynyddygarreg. There is clear evidence that such modestly sized sites are far more likely to be brought forward and developed in full by regional and local housebuilders given that construction and development costs are more likely to be viable in relation to house sales and the general housing market in this part of Carmarthenshire.

3.0 Alleged Loss of Grade 2 Agricultural Land

3.1 The Council originally included the Candidate Site at Llangadog Road as a new Residential Allocation in the 2020 First Deposit Draft. They now have concluded that the development of the site should not proceed forward as the land is classified as Grade 2 High Grade Agricultural Land. We have researched such a land classification using Welsh Government’s “Data Map Wales” service, and the map extract for this part of Mynyddygarreg is reproduced below as Figure 9, with the Candidate Site highlighted by a red arrow.
Figure 9 – Data Map Wales Agricultural Land Classification at Llangadog Road

3.2 It is noted that Grade 2 “High Grade” agricultural land is coloured a light blue colour, however, the accuracy of the map base and therefore whole premise of identifying such classifications must be called into question as the Grade 2 tone includes a modern housing site located directly opposite the Candidate Site. That site was previously brownfield land, being the site of the Optical Factory at Mynyddygarreg, and thus never formerly agricultural land of high substance?

3.3 We also note that the classification of land as Grade 2 Agricultural Land has not prevented the Council from allocating land for future residential development in this Replacement and former LDPs. Indeed some of those sites have been developed, one locally by the Council itself, and one now has the benefit of planning permission. Figures 10 and 11 below illustrate three such examples at Pembrey and Hendy.
Figure 10 below illustrates that allocated site SeC5/h1 at Garreglwyd in Pembrey for 14 units has been developed by the Council on Grade 2 Agricultural Land. Planning permission has now been granted at Awel-y-Mynydd at Pembrey (SeC5/h2) for 100 units.
Figure 11 below illustrates that Allocated Site SeC6/h1 at Llwyngwern at Hendy is allocated for 20 units.
Figure 10 – DMW extract for Pembrey and two allocated sites in Grade 2 Land
Figure 10 – DMW extract for Hendy and an allocated and partly completed site is identified upon Grade 2 Land

3.4 We would therefore submit that not only can the Land Classification Map not be relied upon as an accurate guide as to the grade of agricultural land, even if it is broadly accurate, the Council has saw fit to develop its houses upon it, and also grant planning permission to Applicants to develop multiple residential properties thereon, without any apparent agricultural compensation for that activity and construction.
In conclusion, this Representation to the Second Deposit Draft of the Revised LDP has sought to examine the Council’s reasons for non-inclusion of a Candidate Site.

Our clients have illustrated that their indicative proposals to construct 11 dwellinghouses will not appear at odds to the prevailing spatial pattern of development in Mynyddygarreg. The proposals will provide a modern frontage development, mirroring modern estate development at the former Optical Factory site, and thus being respectful to the character and setting of the locality.

We respectfully request that this Representation be given careful examination, and consequently the defined settlement limits of this part of Mynyddygarreg realigned to include the Representation Site, as a Residential Allocation in the Proposals Map of the adopted Local Development Plan.