Change as set out in the summary.

1 General Description
1.1 This LDP Representation relates to the potential revision of the
defined settlement limits to include a new site 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 Gwyn Lewis of Gilfach Stables, Broadway, Laugharne,
Carmarthenshire, SA33 4NS.
4 The Site
4.1 The site consists of broadly rectangular shaped piece of land which
is currently used for grazing and keeping of horses. The site lies
immediately adjacent to existing dwellings in Broadway, just west
of Laugharne.
4.2 The block of land lies on the northern flank of the A4066, between
an established row of road frontage dwellings to the east, fronting
onto the adjacent highway and a caravan park to the west. The site
represents part of a wider gap between the row of houses and the
caravan site.
4
4.3 The site fronts directly onto the A4066 and is occupies a position
below the road level. Directly opposite is arow of more recently built
dwellings on the southern flank of the A4066. There are a number
of dwellings beyond the block of land to the west.
4.5 The proximity of the site to neighbouring dwellings and its proximity
to the existing built form associated with this part of the village of
Broadway, particularly along the highway is illustrated on the map
extract below (Figure i).
Figure i – Location Plan
4.6 Whilst the site currently occupies an open countryside location, it
lies immediately adjacent to and opposite existing houses and in
close proximity to the heart of the rural village.
4.7 The actual proximity of the site to the predominantly residential
area within the village is clearly shown on the aerial photograph
below (Figure ii).
5
Figure ii – Aerial Photograph
4.7 Vehicular access into the site is currently gained via the existing field
entrance which serves the stable-block and come directly off the
adjacent public highway.
5 The Development
5.1 The aim of this representation is to challenge the removal of the
defined settlement development limits associated with Broadway
and also to challenge its designation as a Tier 4 Rural Village within
Cluster 6, as outlined in the draft Strategic Policy SP3: Sustainable
Distribution – Settlement Framework. In re-introducing the
settlement limits to Broadway and re-designating it as a Tier 3 –
Sustainable Village, this representation also seeks to incorporate
the aforementioned site, edged in red, in the said defined limits.
5.2 Both the Location and Site plans below (Figures iii and iv) illustrate
the extent of land the client considers ought to be included in the
revised settlement development limits associated with the village of
Broadway, if the said limits are to be re-introduced.
The Site
6
5.3 The built up area consists predominantly of residential dwellings
and also consists of a public house which provides a communal
place for congregating.
Figure iii – Location Plan – Suggested revised limits for Broadway
5.4 The site plan below illustrates in greater detail the extent of the land
deemed appropriate for inclusion in the revised settlement limits
for the village.
7
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.
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.
8
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.
6.3.6 These key planning principles are set out with a view to achieve a
number of national sustainable placemaking outcomes, as
9
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.”
10
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
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.
11
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
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 proposed housing allocation to the defined
settlement development limits for Broadway 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 proposed housing allocation to the existing
village with its undefined boundaries in the 2
nd Deposit Revised
Carmarthenshire Local Development Plan (LDP) is illustrated in the
map extract below, Figure (vi).
12
Figure vi – Proposals Map (Revised LDP 2018-2033)
7 Detailed Consideration
7.1 It is asserted that the incorporation of defined settlement limits for
Broadway would be 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 the close proximity of Broadway to the to the town of
Laugharne which is classed as a Tier 2 Service Centre, it is asserted
that Broadway could potentially play an important role in facilitating
any future growth which would assist in sustaining Laugharne as a
recognised service centre.
7.3 Given the well documented physical constraints associated with
Laugharne, particularly its location with a C2 Flood Zone together
with the topography of the surrounding area, evidently there is no
scope whatsoever to accommodate any further housing. The DAM
map extract below (Figure vii) highlights the extent of the flooding
hazard.
13
Figure vii – DAM Map extract (Source:NRW)
7.4 In contrast, Broadway, in occupying an elevated position is well
placed to accommodate any future residential development which
would be of significant benefit given its close links to Laugharne. The
proximity of the housing site being promoted as part of this
representation, to both Broadway and Laugharne, means ISA
Objective 1 (Sustainable Development) is satisfied in this instance.
7.5 It is asserted that the consequence of not allowing any future
housing expansion to be accommodated within Broadway would
have a negative impact on the township of Laugharne itself.
7.6 It is considered the highlighted land for potential residential
development represents a sustainable location given its close
proximity to existing housing in Broadway as well as its proximity to
Laugharne which is classed as a Service Centre in Strategic Policy SP3
of the LDP.
7.7 Natural Resources Wales Development Advice Maps indicate that
the land 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 ix).
7.8 TAN15 states that new development should be directed away from
Zone C and towards zone A, otherwise to zone B, where river or
14
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.
7.9 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.
Figure ix – DAM Map
7.10 The Flood Map for Planning Wales also indicates that the rear of the
land subject of this representation is at risk from localised or surface
water flooding; this is illustrated on the FMfP extract below (Figure
x).
7.11 However, the intention would be to develop along the front part of
the site as this part of 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 land 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.
The Site
15
Figure x – FMfP
7.12 The land does not fall within a C1 or C2 flood risk zone as delineated
by TAN15 DAM flood maps. Neither does the part of the site to be
developed fall within a Flood Zone 2 or Flood Zone 3 as delineated
by FMfP (Flood Map for Planning Wales). As such, ISA Objective 4
(Climatic Factors) and ISA Objective 5 (Water) are both satisfied in
this instance.
7.13 The land 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.
7.14 The land 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.
7.15 The proposed inclusion of additional land within the redefined
settlement development limits is deemed appropriate at this
location in that it would not impact on any core planning principles.
The land would be located immediately adjacent to existing
residential dwellings, and would represent a natural rounding off
the existing built form.
Land under consideration
16
7.16 It is asserted that the addition of further residential plots would not
lead to unacceptable ribbon development as it is sited within a
defined and mature hedgerow boundary. It would not be deemed
tandem development, it would not lead to unacceptable
coalescence of settlements and it cannot be described as
unacceptable sporadic development or an unacceptable extension
to the settlement. If anything the inclusion of these house along
with the vacant plot represents a logical extension do the
settlement.
7.17 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.
7.18 Additional residential plots 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 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.
7.19 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.
7.20 The site has a road frontage boundary that fronts onto the A4066.
As such, the site is readily accessible from the existing public
highway. The site has existing and established entrances with
adequate visibility splays, which allows direct access into the site
from the adjacent highway.
7.21 The map below (Figure xi) illustrates the number of crashes in the
immediate vicinity of the site.
17
Figure xi (Source:Crashmap.co.uk)
7.22 Data obtained from Crashmap.co.uk confirms that in the last 10
years, there have been no slight, serious or fatal crash incidents
along this part of the A4066 County Road. This would suggest that
there are no highway issues relating to the site or the public road(s)
which serve the site.
7.23 The site lies in very close proximity to National Cycle Network Route
4, which is approximately 1km away. This proximity of the site to
this cycle route is illustrated on the Sustrans National Cycle Network
Map extract below (Figure xii).
Figure xii (Source:Sustrans)
7.24 The site is readily accessible to a local bus services (First Cymru
South & West Wales) Route. There’s a regular bus service which
links the village to Laugharne and commercial centres beyond.
18
7.25 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).
7.26 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 settlement of Laugharne. As such, it is
considered the site satisfies ISA Objective 12 (Health & Well-being)
and ISA Objective 15 (Social Fabric) .
7.27 The site along with the existing houses are within a reasonable
walking distance of a number of retail and employment provisions;
and services and facilities that can be found in Laugharne service
centre. Whilst the site occupies a rural location, it represents a very
sustainable location given its close proximity to the service centre.
As such, the site satisfies the following ISA Objectives; ISA 6
(Material Assets), ISA 10 (Population), ISA 14 (Economy), ISA 15
(Social Fabric).
7.28 The site represents a sustainable location in terms of its proximity
to nearby nursery schools and Primary School. As such, ISA
Objective 13 (Education & Skills) is satisfied in this instance.
7.29 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.
7.30 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.
7.31 The site is not located within or immediately adjacent to any
Regionally Important Geological or Geomorphological Sites. As
19
such, ISA Objective 9 (Landscape) is satisfied in this instance.
7.32 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.
7.33 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).
7.34 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.
7.35 The traffic movements associated with additional residential plots
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.
7.36 It is asserted that owing to the nature of the development proposal
being advanced, 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.
7.37 It is not disputed that the siting of an additional dwellings at this
location would introduce built form at an otherwise undeveloped
site. However, the dwellinsg 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.
7.39 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.
7.40 The development would not have a significant impact on the
amenity of adjacent land uses, properties, residents or the
20
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.
7.41 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 Gwyn
Lewis and provides planning support for the inclusion of additional
land in the revised Local Development Plan to accommodate
potential residential development in Broadway.
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 change 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 the
existing group of dwellings along with the inclusion of one additional
site for residential development in the upcoming revised local plan.