Testun llawn:
1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Mrs N Andreu and Mr A Davies to
prepare and submit an Alternative Allocation Report for the allocation of land at
adjoining Cillefwr Industrial Estate, Carmarthen for the purposes of employment
related development in the forthcoming replacement Carmarthenshire Local
Development Plan (LDP).
1.2 This statement has been prepared in line with the Authority’s published site
assessment and selection documents. The contents of this Statement 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 Statement 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.
2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Candidate Site relates to a parcel of land measuring approximately 4.7 acres in
area, edged red on the plan and image below.
Plan A
Photograph 1
2.1.2 The Site currently consists of two parcels of level land, currently laid to grass, as can
be seen from the photograph below.
Photograph 2
2.1.3 Within the Site are a line of mature trees, which form part of the boundary treatment
between the two parcels of the Site. Further trees are then found along the Site’s
edges, contributing towards its boundary treatment together with stock proof fencing.
Just beyond its boundaries then lies the A40 trunk road to the north, St Clears Road
along its western boundary and the Carmarthen to Tenby rail line along its southern
boundary. Its remaining western boundary is then shared a small strip of woodland
owned by our Clients, with a further parcel of grazing land located beyond it.
2.1.4 Access to the Site is gained directly off St Clears Road via an existing gateway and
access ramp into the Site. As illustrated by the photographs below, visibility in both
directions at this point is good.
Photograph 3 Photograph 4
2.1.5 Under the provisions of the current Carmarthenshire LDP, the Site presently forms
part of the larger ‘West Carmarthen’ strategic site allocation, as illustrated below.
Plan B
2.1.6 The LDP Written Statement sets out that the allocation was expected to deliver a mix
of uses, including residential and employment related development. The Written
Statement is then supported by a comprehensive Supplementary Planning Guidance
document, within which two areas are indicated as being earmarked for employment
development – land shaded purple and hatched red (our Clients land) – as illustrated
in the plan below.
Plan C
2.1.7 As can be seen, the Alternative Allocation is well related to the existing and proposed
development form of the adjoining urban area and therefore continues to represent a
natural and logical location for the settlement’s expansion.
2.2 THE ADJOINING SETTLEMENT
2.2.1 As detailed above, the Alternative Allocation adjoins the existing built form of the
settlement of Carmarthen. Adjoining both its northern and southern boundaries are
two of the Town’s key transport arteries, with existing residential and employment
development beyond them.
2.2.2 Due to this position and close association with the existing built form, the Alternative
Allocation has excellent access to the range of community facilities and local services
the settlement of Carmarthen has to offer, with a number being within walking
distance of the Site. In addition, the Site is positioned directly off a key transport node
of the A40 Trunk Road, providing access to and from it in both an immediate and
regional sense.
2.2.3 This excellent level of accessibility is further heightened by the fact that there is a
Parc and Ride facility a short distance to the west of the Site, as well as a number of
bus stops served regularly by services providing access to the Town Centre and
beyond. The strong sustainable position of the Alternative Allocation should therefore
be given full consideration when considering potential future growth options.
2.2.4 In terms of planned growth, the proposed Alternative Allocation forms part of one of
the 3 identified Principal Centres within the 2nd Deposit LDP, in fact its largest -
Carmarthen. Within these areas, the majority of the County’s growth (particularly with
regards to employment) is expected to be accommodated within the Plan period.
2.2.5 Having undertaken a comprehensive review of the proposed allocations put forward
by the 2nd Deposit LDP for the Principal Centre in question, as well as those sites
currently allocated for employment development in the current LDP, we have
identified a number of significant concerns. The table below therefore provides details
of the current and proposed allocations for new employment development.
Current LDP 2nd Deposit LDP
Site
Reference Site Name
Site
Area
(Ha)
Site
Reference Site Name
Site
Area
(Ha)
GA1/E1 Cillefwr Industrial Estate 4.38 PrC1/E1 (i) LandWest of Cillefwr Road 2
GA1/MU1 West Carmarthen 5.45 PrC1/E1 (ii) Land North of Alltycnap Road 1.215
GA1/MU2 Pibwrlwyd 15.5 PrC1/E1 (iii) Land South of Alltycnap Road 0.952
PrC1/MU1 West Carmarthen 4.53
PrC1/MU2 Pibrlwyd 8.95
PrC1/SS1 Yr Egin 1.04
Total: 25.33 Total: 18.687
Table 1
2.2.6 The first and most concerning issue highlighted from the above figures is that the
Replacement LDP proposes that the land available for employment development
purposes and so economic growth in Carmarthen Town during the Plan period be
reduced by almost 7ha – over 25% compared to current provision. This is a
significant reduction from the role the County Town was considered to have in the
County’s economy since the adoption of the current LDP, despite the Town’s current
population and the Replacement LDPs aspirations for its growth. This imbalance is
clearly unsustainable.
2.2.7 The above is of further concern when the overall allocation of employment land within
the County is considered. Under the provisions of Policy SP 7, the 2nd Deposit LDP
advises that 71.21 ha of land is to be allocated within the County during the Plan
period for employment development purposes. As a result and despite its strategic
and sustainable position, approximately only 25% of the total land allocated in the
Replacement LDP is to positioned within the County Town. This imbalance again is
clearly unsustainable, particularly when its sustainable transport attributes are taken
into consideration.
2.2.8 As a result of the above, it is considered that further land such as the Site owned by
our Clients should be allocated for employment development purposes to address the
above highlighted imbalance, to ensure the Plan can be regarded as being ‘sound’.
3.0 THE PROPOSAL
3.0.1 As part of the requirements for the promotion of sites for employment development,
this Statement is accompanied by an indicative layout for a potential employment
development 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 a mix of 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 employment development, together with areas to be retained
and managed for biodiversity enhancement purposes. As a result, the accompanying
illustrative layout (reproduced below) demonstrates that the Site is capable of
accommodating a range of new employment units to serve a variety of B1, B2 and B8
end-users, as well as its biodiversity assets.
Plan D
3.1.2 As illustrated above, the Site is capable of accommodating a mix of unit sizes and
types, ensuring that it is responsive to all existing and future needs of the businesses
in the local and wider area.
3.1.3 With regards then to access, the existing point off St Clears Road will be utilised and
altered if required. From this then, a new access road will be constructed to serve the
Site as a whole.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Any development of the Candidate Site for employment 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.
4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 Any potential biodiversity assets the Site may include have been given full
consideration with regards to exploring its potential for employment 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” 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
Carmarthen locality. The red star denotes the position of the Alternative Site.
Plan E
4.1.3 As can be seen from the above, the Alternative Allocation does not form part of and
neither is it near any national or local designations. The nearest designation is the
River Tywi SSSI/SAC, but due to the intervening distance and topography, the
development of the Alternative Alocation will not have any detrimental impact on this
feature.
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 Allocation 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 area of the Alternative Allocation would not include any elements 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 Allocation indicated
by the red star).
Plan G
(Development Advice Maps)
Plan H
(Flood Maps for Planning)
4.3.2 Due to its greenfield nature, the Alternative Allocation has no ground contamination
related constraints.
5.0 NATIONAL PLANNING POLICY CONSIDERATIONS
5.0.1 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.
5.1 EMPLOYMENT LAND SUPPLY
5.1.1 With regards to the provision of land for employment use, Paragraph 5.4.1 of PPW
sets out that “The planning system should ensure that the growth of output and
employment in Wales as a whole is not constrained by a shortage of land for
economic use.”. Paragraph 5.4.3 goes on then to require that:
“Planning authorities should support the provision of sufficient land to meet the needs
of the employment market at both a strategic and local level. Development plans
should identify employment land requirements, allocate an appropriate mix of sites to
meet need and provide a framework for the protection of existing employment sites.”.
5.1.2 As detailed in previous sections of this Statement, the Replacement LDP proposes a
significant reduction in the level of land available to accommodate employment
development in the Town of Carmarthen during the Plan period. On a local level, the
Replacement LDP proposes a significant growth in the Town’s population through the
proposed housing allocations. However, and despite this, the same document
proposes a reduction of over 25% of the land available for new job opportunities to
this new element of its population.
5.1.3 From a wider and more strategic perspective, Carmarthen represents the County’s
principal settlement that has a range of transport links to all areas of the County, the
M4 corridor and the key transport arteries to the commercial ports of Pembrokeshire.
Again, despite these sustainable attributes, only 25% of the total land allocated for
employment development in the County is proposed to be located at Carmarthen.
5.1.4 The above imbalances are clearly at odds with the guidance and objectives of
national planning policy in terms of both local and national growth. In contrast and
quite clearly, the allocation of the Alternative Allocation for employment development
would help address these imbalances, through the provision of a deliverable and
sustainable new source of economic land.
6.0 CONCLUSION
6.1 Although currently undeveloped, the Alternative Allocation 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.
6.2 In addition to the above, the Site lies on part of the County Borough’s key
transportation network and is accessible not only by private vehicle, but also by the
regularly served public transport network. This provides it with a good level of access
for potential customers and employees from the settlement of Carmarthen, as well as
those further afield, ensuring therefore that the Alternative Allocation will make a
positive contribution to both national and local sustainable development objectives.
6.3 In tandem to the above, the development of the Site will also address the imbalances
in employment land provision identified in this report, not only in terms of the local
area, but also in terms of a County wide perspective. Carmarthen represents the
County’s key settlement, but the current employment land provisions are not
capitalising or strengthening this role, in direct conflict therefore with the objectives of
the Replacement LDP.
6.4 With the Alternative Allocation having no access, ground condition, flood risk,
hydrological, ecological, archaeological or land ownership related constraints, its
delivery if allocated is assured. Combined therefore with its locational characteristics,
the Site in question represents a sustainable candidate for future employment
development.
6.5 In view of the above and information provided in this Statement, it is respectfully
requested that the Alternative Allocation in question be designated for employment
development.
