Amend Plan to include the site.

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
• Location & Site Plans
• Planning Statement
3 Client Details
3.1 The client is Mrs Molly John of Parc Gilfach, Llangynog, Carmarthen,
SA33 5DH.
4 The Site
4.1 The site consists of a rectangular shaped parcel of land which
currently forms part of a field enclosure. The parcel of land fronts
onto the C2081 and is located to the west of the settlement of
Llangynog.
4.2 The site lies on the northern flank of the C2081 and is located
between a number of road frontage dwellings at this stretch of
highway.
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4.3 The site fronts directly onto the adjacent highway and is located in
close proximity to a predominantly residential area at the northwestern end of the settlement. The site lies approximately 300
metres west of the village settlement.
4.4 The proximity of the site to nearby dwellings along with its proximity
to the existing built form associated with the village of Llangynog is
illustrated on the map extract below (Figure i).
Figure i – Location Map of Llangynog
4.5 Whilst the site currently occupies an open countryside location, it
lies between a number of sporadic dwellings and within a
reasonable walking distance of the settlement development limits
associated with Llangynog. The actual proximity of the site to the
remainder of the village, which is predominantly residential in
nature, is clearly shown on the aerial photograph below (Figure ii).
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Figure ii – Aerial Photograph
4.6 The site is essentially a greenfield site, nevertheless, given the
residential dwellings immediately east, along the C2081, it clearly
represents a site in close proximity to the edge of the village. Access
into the field enclosure is currently gained via existing field
entrances which come directly off the adjacent public highway.
5 The Development
5.1 The aim of the development advanced as part of this LDP
representation would be to provide a single residential plot,
fronting directly onto the adjacent highway.
5.2 Both the Location plan and Site plan below (Figures iii/iv) illustrate
the configuration of the site and extent of the site boundaries in
relation to the immediate environs and surrounding area.
Fig iii
The Site
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5.3 The site plan extract below (Figure iv) illustrates the positioning of
the plot in relation to the adjacent built form. The scale of the plot
takes into full account the configuration of the site as well as the
approximate plot sizes of nearby residential properties.
Figure iv – Site Plan
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:
• 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.
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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)
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.
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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
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
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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
been established where there will 14 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
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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 Llangynog in the current Local Development Plan 2006-
2021 (LDP) is illustrated in the map extract below, Figure (v).
Figure v – Proposals Map (LDP 2006-2021)

6.5 The proximity of the site to the defined settlement development
limits for Llangynog in the 2
nd Deposit Revised Carmarthenshire
Local Development Plan (LDP) is illustrated in the map extract
below, Figure (vi).
6.6 It is evident from the revised proposals map that the settlement
development limits have been altered and reconfigured to include
additional land at the edges of the settlement.
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Figure vi – Proposals Map (Revised LDP 2018-2033)
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7 Detailed Consideration
7.1 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 siting in close proximity to the settlement of Llangynog,
which is classed as a Tier 3 Sustainable Village, and, its proximity to
nearby villages such as Bancyfelin and Llanybri, ISA Objective 1
(Sustainable Development) is satisfied in this instance.
7.3 As illustrated on the aforementioned site plan, the site can
potentially accommodate a single residential dwelling which would
be sited between a number of road frontage dwellings along this
part of the highway.
7.4 Whilst the site is not considered to be directly related to the
identified settlement of Llangynog, there are a number of dwellings
beyond the site to the north/west. As already highlighted, the site
represents a very sustainable location given its close proximity to
Llangynog. In addition, it is only 3 miles from the service centre of
St Clears and less than 5 miles from the market town of Carmarthen
ancffosfelen, which is classed as a Principal 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
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.
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Figure vii – DAM Map (NRW)
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). The Flood Risk Map below
demonstrates that apart from a small section of the site frontage,
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.
Figure viii – FMfP
7.9 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
The Site
The Site
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Wales). As such, ISA Objective 4 (Climatic Factors) and ISA Objective
5 (Water) are both satisfied in this instance.
7.10 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.
7.11 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.
7.12 The proposed development is deemed appropriate at this location
in that it would not impact on any core planning principles. The
proposed development would be sited between a number of
dispersed residential dwellings along this stretch of highway. As
such, it would not be extending beyond existing dwellings to the
west and it would not represent an inappropriate intrusion into the
open countryside. On that basis, it would not be seen as an
unacceptable extension of the built form into the rural landscape.
7.13 As already emphasised, given that the development would not
extend beyond existing dwellings along this highway, the proposal
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 immediately
adjacent to an existing residential property, it cannot be described
as unacceptable sporadic development or an unacceptable
extension to the settlement. In addition it would not result in the
loss of areas of public open space or formal recreational land. Given
the aforementioned, it is asserted that the development would not
be contrary to general planning principles.
7.14 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
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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.
7.15 The proposal would not involve the re-use of suitable previously
developed land, hence it is acknowledged that the land is a
greenfield site, as such, ISA Objective 7 (Soil) is not satisfied in this
instance.
7.16 The site has a road frontage boundary that fronts onto the C20818.
As such, the site is readily accessible from the existing public
highway. The site has an existing and established entrance with
adequate visibility splays, which allows direct access into the site
from the adjacent highway.
7.17 The C2081 is a relatively quiet road which serves primarily as access
from the A40 to the village of Llangynog. The map below (Figure ix)
illustrates the number of crashes in the immediate vicinity of the
site.
Figure ix (Source:Crashmap.co.uk)
7.18 Data obtained from Crashmap.co.uk confirms that in the last 20
years, there have been no slight, serious or fatal crash incidents
along this part of the C2081 classified road, this would suggest that
there are no highway issues relating to the site or the public road(s)
which serve the site.
7.19 The site lies in very close proximity to National Cycle Network Route
4, which is approximately 150 metres away. This proximity of the
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site to this cycle route is illustrated on the Sustrans National Cycle
Network Map extract below (Figure x).
Figure x (Source:Sustrans)
7.20 The site is readily accessible to local bus services with the nearest
bus stop less than a 5 minute walk away. There’s a regular bus
service which links the village to the commercial centres of
Carmarthen and St Clears.
7.21 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).
7.22 Given its location, the site lies immediately adjacent to an accessible
green space. In addition, the site is very accessible to an identified
recreation play area in the village of Llangynog. As such, it is
considered the site satisfies ISA Objective 12 (Health & Well-being)
and ISA Objective 15 (Social Fabric) .
7.23 The site is within a reasonable driving distance of a number of retail
and employment provisions; and services and facilities, that can be
found in Bancyfelin and Llangain. Other provisions / services /
facilities within a reasonable driving distance (approx. 10 minutes)
can be found in the service centre of St Clears and of course the
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Principal Centre of Carmarthen, which has a wide range of
employment/retail provisions, services and facilities. Whilst the site
occupies a rural location, it represents a very sustainable location
given its close proximity to the service centre.
7.24 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 and Carmarthen. As
such, the site satisfies the following ISA Objectives; ISA 6 (Material
Assets), ISA 10 (Population), ISA 14 (Economy), ISA 15 (Social Fabric).
7.25 The site represents a sustainable location in terms of its proximity
to Bancyfelin Primary School. The site is also within a reasonable
distance of Ysgol Gyfyn Bro Myrddin and QE High secondary schools.
As such, ISA Objective 13 (Education & Skills) is satisfied in this
instance.
7.26 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 not located within a Mineral Safeguarding Area, as such,
ISA Objective 6 (Material Assets) is 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.
7.27 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.
7.28 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.
7.29 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.
7.30 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).
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7.31 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.
7.32 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.
7.33 It is asserted that owing to the nature of the development proposal
being advanced i.e. single dwelling, 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
proposed layout to ensure the relationship between the proposed
dwelling and existing development in close proximity is acceptable.
It is considered that a modestly sized residential dwelling would
conform with the character and appearance of the immediate area
in terms of siting and land use.
7.34 It is not disputed that the siting of a residential dwelling at this
location would introduce built form at an otherwise undeveloped
site. However, the dwelling 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.
7.35 The development would not be readily visible from the wider area;
and would represent a logical extension to the existing built form
along this highway. 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 or surrounding
area.
7.36 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.
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7.37 Overall, the proposed development would satisfy PPW’s objective
of achieving sustainable development both by ensuring that the
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 Molly
John and provides planning support for the inclusion of additional
land in the revised Local Development Plan to accommodate
potential residential development at land adjacent to Eithinduon,
Llangynog.
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 ‘infill’ 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 plan.