Amend Plan to include the site

Please see Supporting Statement. The vast majority of the site is allocated for residential development (Ref: SC16/h1) in the current LDP, with a non committal allocation for 10 dwellings. Efforts have been made to deliver this allocation, with this portion of the site having gained outline planning permission for the erection of 13 dwellings and associated infrastructure work (Ref: PL/00629), and a planning application was submitted in March 2023 concerning full planning permission for the construction of an access road in order to serve those dwellings (Ref: PL/05573). This proves that an attempt has been made to deliver the only housing allocation in the current LDP for Llanybri, therefore there is no logical reason for it`s removal within the deposit plan. It is the applicant’s intention to bring the site forward via the submission of reserved matters for the housing itself in the near future. The candidate site to the immediate south of the housing allocation is a natural extension of this. At present, this portion of the land contains old agricultural structures that are now in a state of disrepair.

Supporting statement (not including appendices):

1 Introduction
1.1 This supporting statement document for the Second Deposit Revised Local Development Plan for Carmarthenshire has been prepared in relation to an existing LDP allocation (SC16/h1 land adjacent to Parc Y Delyn) and adjacent candidate site (SR/108/001 land at Maes Y Meillion) in Llanybri, Carmarthenshire (E: 233989, N: 212783). It is submitted on behalf of Mr David Rhodri Davies.
1.2 The existing LDP allocation (SC16/h1) reproduced in Appendix 1 is proposed to be de-allocated. The reason specified in the Site Assessment Table is “the site has been allocated since the UDP without any indication of delivery”. It will be shown in this statement that an Outline Planning application for 13 dwellings was registered on the 20th October, 2020 and subsequently approved by the LPA on the 5th August, 2022 under planning reference PL/00629. The applicant has also subsequently submitted a full planning application for the access in order to bring forward such facilitating works and this has been registered by the LPA and pending determination under planning reference PL/05573. The above show a clear intent by the landowner to bring forward this existing housing allocation, and thus it should not be de-allocated.
1.3 The southern part of the site was previously submitted as a candidate site in 2018 in Appendix 2 (Ref: SR/108/001), but this has not been included within the Deposit Plan. The reason specified in the Site Assessment table is “site access taken through existing housing allocation which is to be taken out. Therefore this is not taken forward”. The reason is specific to the access aspect through the existing housing allocation, which should be retained as a housing allocation for the reasons mentioned above. The housing layout and access design is such that it facilitates the delivery of candidate site SR/108/001. The candidate site at present contains old agricultural buildings that are now in a state of disrepair.
1.4 In summary, this submission concerns the entire Maes y Meillion site including both the existing LDP allocation (SC16/h1) and adjacent candidate site (SR/108/001), and the applicant wishes for them to be brought within the settlement limits of Llanybri in order to comply with LDP Policy SD1 (Development Limits), along with being included as a housing allocation in order to accord with Policy HOM1 (Housing Allocation).
1.5 The site is situated in the village of Llanybri, lying to the north west of Llansteffan and situated south of Llangynnog. The site lies roughly 8.5 miles away from Carmarthen town centre where there are a host of amenities and services including supermarkets, a university and leisure centre.
1.6 This submission will demonstrate that the overall site in question, both the existing housing allocation (SC16/h1) and candidate site (SR/108/001) ought to be included within the settlement boundary of Llanybri in the Deposit LDP. Efforts have been made to deliver the existing allocation, with this portion of the site having gained outline planning permission for the erection of 13 dwellings and associated infrastructure work (Ref: PL/00629), and a planning application was submitted in March 2023 concerning full planning permission for the construction of an access road in order to serve those dwellings (Ref: PL/05573). This proves that an attempt has been made to deliver the only housing allocation in the current LDP for Llanybri, therefore there is no logical reason for its removal within the deposit plan. It is the applicant’s intention to bring the site forward via the submission of reserved matters for the housing itself in the near future. The candidate site SR/108/001 is a logical extension of this existing housing allocation and will be accessed through it. Appendix 3 and 4 provide copies of the outline layout plan
and approval respectively, whilst Appendix 5 and 6 provide copies of the proposed access plan and registration document.
1.7 In terms of the content of the submission Section 2 of this report provides a brief description of the site; Section 3 discusses the overall planning policy context; Section 4 assesses the site in the context of criteria identified in Planning Policy Wales. Section 5 provides a summary and conclusions.
2 Site Description
2.1 This section discusses the site’s general location and provides a brief description of the application site and its immediate surroundings.
2.2 Llanybri is categorised as a Tier 3 sustainable village situated in the unitary authority of Carmarthenshire. It is located approximately 8.5 miles to the south west of the county town of Carmarthen and approximately 6.5 miles to the south east of St Clears. The highway that runs to the northwest of the site has a 30mph speed limit on entry to the village.
2.3 The majority of the entire site comprises agricultural grazing land, along with the farm holding of Maes Y Meillion. Access to the farm itself can be gained from the county road to the north via the concreted farm road on the eastern side, leading onto a hard-standing area in the south-eastern corner. There is a small agricultural building, which is now redundant and partially collapsed, in this corner of the field. Agricultural grassland and hedgerow forms the north eastern and north western boundaries. The north east of the site is bound by an access track associated with Maes Y Meillion and to the south east by Maes Y Meillion grounds within the ownership of the applicant. The south western boundary is formed by the curtilage of properties within Parc Y Delyn whereas the north western boundary is formed by the main highway running through Llanybri. Lying to the south of the site is an off-road track and children`s play area.
2.4 The village of Llanybri contains few services and facilities. Those located within the village includes places of worship and a public house. Llansteffan located nearby the site contains a few more facilities including Llansteffan primary school, a convenience shop and amenities associated with the coastal location, place of worship and community hall. The nearest service centre to the site is St. Clears which features a wider range of services and facilities including:
• Surgery;
• Ysgol Griffith Jones (Primary);
• St. Clears Leisure Centre;
• Supermarket;
• Convenience Shops; and
• Takeaways
2.5 The site can be reached via the B4312 from Carmarthen, that passes through Llangain, whereas those travelling from a westerly/northerly direction will cross the busy A40 dual carriageway near Bancyfelin and head along a country lane that leads to the centre of Llanybri. The road situated to the northwest of the site currently has a 30mph speed limit as users enter the village of Llanybri. The nearest national cycle route is route no.4 which is a long distance course between London and Fishguard. The nearest point of access for potential users is by Gul Wales: Littlemoor, approximately three miles from the site. Ger y Marbell bus stop is a short walk from the site and is serviced by the 227 bus. This service commences at Ger y Marbell and terminates at Carmarthen, with 6 services heading in that direction, and another six terminating at Ger y Marbell from Carmarthen on the return journey. In terms of trains, the nearest station is in Carmarthen town centre, nine miles away. The station is situated on the West Wales Line and is predominantly served by Transport for Wales who run services to destinations further west, along with journeys to Swansea, Cardiff Central and Manchester Piccadilly. In addition to this, Great Western Railway operate one service daily to London in both directions, and additional services are provided by the operator on Sundays.
2.6 In terms of ecology, a Preliminary Ecological Appraisal was conducted in July 2020 at the site to accompany outline application PL/00629. As it was conducted over two years ago, an updated appraisal of the site was required to accompany the full application for the access. Consequently, Habitat Matters conducted an Ecological Appraisal of the site during December 2022. The Preliminary Ecological summarised that “The site conditions remain unchanged from the July 2020 proposal apart from the derelict building which has now lost all sections of the roof. The recommendations for ecological mitigation and enhancement remain as before”. A section of hedge requires removal to facilitate the proposed access and will be translocated as shown in Appendix 7. In terms of ecological enhancements, the report suggests that these will be delivered as part of the wider residential development, comprising of suitable landscape planting and bird/bat boxes.
2.7 Intrado were instructed to produce a drainage strategy for the access proposal that is provided in Appendix 8. The engineering layout highlights how drainage aspects have been incorporated into the construction of the access road. These include:
1. 2.75m minimum width (half of highway) to be constructed from permeable asphalt to be lined with permeable geotextile membrane to facilitate infiltration to groundwater network below;
2. Kerb drainage to be installed at low point in highway to drain surface water runoff to infiltration basin during storm events in excess of 1:100yr to avoid highway flooding; and
3. ACO swale inlet (or similar approved product) to be installed in infiltration basin.
In addition to this, the Kerbing Layout notes that the kerb drainage will be implemented at a low point of the highway in order to convey runoff to bioretention section during an extreme storm occurrence greater than 1:100 years. The access and subsequent housing will be subject of separate SAB approval also.
3 Comments on Planning Policy
3.1 Paragraph 9.3 of the Revised Draft LDP correctly recognises the role that smaller settlements within Carmarthenshire have in delivering local and sustainable growth. This is further expanded upon in Paragraph 9.16 which again correctly recognises that by supporting growth of a proportionate scale in such areas, a positive contribution can be made towards the long term sustainability and cohesiveness of rural communities and the rural economy.
3.2 It is clear that there is a reliance on larger sites within rural areas which can be difficult to deliver. Due to issues around deliverability, this has impacted the resilience of housing land supply, with these larger sites not delivering the dwellings promised. A different approach is warranted in certain areas of Carmarthenshire, with a large proportion of the County being rural in nature. Within Tier 3 settlements (Sustainable Villages), sites that are small in scale but are easily deliverable ought to be favoured as they will be able to meet the housing need in an easy manner whilst not hampering the character of the area.
3.3 The Moving Rural Carmarthenshire Forward Report conducted in 2019 stated that in order to make rural areas attractive for younger people adequate housing needed to be provided to ensure that they could remain within their local communities. The report stated that a shift was required from depending on large housing developments to focusing more on smaller scale residential developments that would address housing requirements in rural settlements. A survey produced during the report revealed only 15% of respondents were happy with the housing provided within their rural area.
3.4 It is imperative that a sustainable and proportionate amount of housing growth is allowed in rural areas of Carmarthenshire during the plan period. The lack of such housing at present has unfortunately resulted in younger individuals departing rural areas, looking for housing and work in urban areas which is having a detrimental impact upon the resilience of rural areas
3.5 In terms of policy within the deposit LDP, the two key policies are SD1 (Development Limits) and HOM1 (Housing Allocations). In terms of Policy SD1, the site discussed in this statement ought to be included within the settlement boundary of Llanybri as it would represent a natural extension of the settlement. There is no logical reason for moving the site outside settlement limits within the deposit plan, as the site currently lies within limits and efforts have been made to develop the site, with two planning applications having recently been submitted, with the outline approved confirming acceptance of housing on the site
in principle. The candidate site to the south of the existing housing allocation is a logical extension of this and can be delivered via the facilitating infrastructure being developed for the existing housing allocation. The candidate site element includes old agricultural buildings, many of which are now in a state of disrepair.
3.6 In respect of Policy HOM1, there is proof that the site will be delivered as the site has gained outline planning permission for 13 dwellings and associated works, and a full application has recently been submitted for the access works. Welsh Government advice is to remove sites which have proved to be undeliverable, however this is not the case in respect of this land. The land owner is keen to progress development of the site with the submission of reserved matters for the housing itself in the near future. Furthermore, as a result of pulling the site out as a housing allocation within the deposit plan, Llanybri does not have any sites allocated for residential development. Retaining the existing housing allocation and including the logical extension to it will address this deficiency.
3.7 Having considered the last two paragraphs, there is no logical reason for altering the settlement limit of Llanybri, as this reduces opportunity for residential development and sustainable growth within a sustainable village. Furthermore, there is no reason for it to be removed as a housing allocation as there is intent to develop the site as illustrated by the submission of recent applications. Within the current plan, the site accords with LDP policy, and nothing suggests that the site could not do this when it comes to the deposit plan, were it to lie within settlement limits and be allocated for residential development. The candidate site to the south of the existing housing allocation is a logical extension to it and can be facilitated via the access being proposed.
4 Appraisal
4.1 This section examines the characteristics and features of the site in question.
Availability of Previously Developed Land
4.2 The site is not brownfield land but is well-connected to the current settlement pattern of Llanybri and its development for residential purposes represents a logical area for development and inclusion within the settlement boundary, at this location. Lying west is the Parc Y Delyn residential development which has a similar number of residential dwellings to what has gained outline planning permission at the Maes Y Meillion site, along with a comparable layout. Several services and facilities are available in the nearby towns of St Clears and Carmarthen that are a short drive away from the site.
4.3 In order to achieve a sufficient range and choice of housing land opportunities, there will be a need to consider sites which help achieve resilience in rural settings, with this site capable of being delivered in the short to medium term. The existing housing allocation element of the site can offer up to 13 residential units as illustrated in Appendix 3, whilst a few more can be delivered on the candidate site to the south. This will make a positive contribution to housing land supply,
Accessibility
4.4 Although the land consists of undeveloped agricultural grazing land which does not benefit from formal access, the site can be entered via the wider Maes Y Meillion grounds. The proposed access application submitted in March 2023 to the LPA will lie thirty yards south west of the current access. This development will offer access to a highway that runs centrally to the site with the 13 properties situated on either side as shown in Appendix 5. It will provide access to the parking areas, along with a turning head to enable vehicles to enter and leave the site in a forward gear. A section of hedge requires removal to facilitate the proposed access and will be translocated, whereas ecological enhancements as part of the proposed access will comprise suitable landscape planting and bird/bat boxes.
4.5 In terms of facilities, these are limited to a public house, chapel and playground within Llanybri. A range of services and facilities are provided in nearby Carmarthen, that can be reached via a bus service that calls at the nearby Ger Y Marbell bus stop. In terms of trains, the nearest station lies in Carmarthen, where services run to several destinations across south Wales, along with Manchester Piccadilly and London Paddington. The nearest cycle route is no 4 which is a long-distance route between London and Fishguard running via Reading, Bristol, Swansea, Tenby and St. Davids.
4.6 It is evident that drivers travel along the main road running through the village in a sensible manner as residents have to walk along the side of the road due to no footway being constructed. Such an arrangement is not uncommon in rural settlements of Carmarthenshire and underlines that the development is occurring within a pedestrian safe environment.
Land Ownership
4.7 The land to which this submission refers is within the joint-ownership of the Site Promoter – Mr David Rhodri Davies. The landowner is fully committed to bringing forward the development of the site.
Capacity of Infrastructure
Utilities
4.8 All utilities are readily available within the proximity of the site. In addition, as the detailed design of the proposed development progresses, the provision of electric-charging on a plot-by-plot basis will be considered further.
Drainage
4.9 The site is not affected by a flood risk area (which would prevent vulnerable forms of development such as housing), and it is considered that foul water will connect with the existing mains sewer. Drainage aspects have been clearly incorporated into the proposed access, with further detail provided in Appendix 8.
Access
4.10 Achieving sufficient widths and visibility at the site’s proposed access point will be achieved, with some of the hedge at the northern end of the site translocated. The development will provide the necessary pedestrian and cyclist infrastructure within the site to encourage residents to walk and cycle, with 2m wide footways included on both sides of the carriageway, and a potential path may be built in future in order to connect the site with the playground that lies south of the site. A S.106 completed in relation to the outline permission also secured a £25,000 contribution towards improving pedestrian facilities in the village of Llanybri.
Impact on the Community/Welsh Language
4.11 It is not considered that the development of the site for housing will have any significant adverse impact upon the Welsh language or any local communities. The nearest primary school is situated in Llansteffan, which is a Welsh medium school therefore enabling development of the site could increase the number of Welsh speakers in the village. A S.106 was completed in relation to the outline which secured 30% affordable housing and a financial contribution towards local education facilities.
Physical and Environmental Constraints
Ecology
4.12 The Preliminary Ecological Appraisal in Appendix 7 summarised that appropriate ecological enhancements will be provided a part of the access application, and the hedge removed to facilitate the access will be translocated.
Visual Impact
4.13 Overall it is considered that the proposal would not have any significant adverse impact upon the visual amenities of the area. Separation distances, to prevent any adverse or overbearing impacts, between proposed dwellings and existing dwellings can easily be provided.
Coalescence of settlements
4.14 Development on the site would not result in the coalescence of settlements. Development of the site would result in the retention of the existing housing allocation in Llanybri and a marginal extension of Llanybri`s development limits within the deposit plan, which makes sense considering a similar scale residential development lies west of the site. Furthermore, part of the site currently lies within settlement limits, and is allocated for residential development within the adopted plan. It has been proven in this submission that the existing allocation is deliverable with progress already made at significant expense to
the applicant by successfully obtaining outline planning permission and submitting a full application to bring forward access facilitating works.
Flood Risk
4.15 The site is not identified in the TAN 15 Development Advice Maps as being at risk from flooding.
Site Contamination
4.16 In terms of ground conditions there are no known constraints that prevent the development of the site for residential uses.
Compatibility with Neighbouring Uses
4.17 It is anticipated that all of the proposed dwellings would respond well to the established character of the surrounding area. It is anticipated that a range of dwelling types and sizes, including 30% affordable dwellings would be incorporated ranging from 2 beds up to 4 beds which forms the basis for interesting street scenes and helps establish a balanced community. Overall it is considered that the proposal would not have any significant adverse impact upon the residential amenities of existing or future occupiers.
The Potential to reduce carbon emissions through co-location with other uses
4.18 The site is proposed for residential uses. However, increasing Llanybri`s population will allow help sustain local facilities and potentially increase demand for additional services to benefit the village.
Relationship with Historic Environment
4.19 The site is not located within or adjacent to the boundary of a Conservation Area. The closest feature of historic importance is Scheduled Ancient Monument Yr Hen Gapel which sits together with Grade II
listed Tower of Yr Hen Gapel. These are situated within the village of Llanybri, roughly 0.4 kilometres to the south west of the development site.
Delivery of Key Placemaking Objectives
4.20 Placemaking is at the heart of both ‘Future Wales’ and Planning Policy Wales (Edition 11, February 2021). As set out at Section 3 of ‘Future Wales’: “Future Wales’ Outcomes are overarching ambitions based on the national planning principles and national sustainable placemaking outcomes set out in Planning Policy Wales”. Preliminary investigations have identified that the site can provide homes in the right place and create a sustainable, well-designed, and high-quality housing scheme, where people will want to live, in accordance with national placemaking objectives.
Conclusion
5.1 This site representation is made by Asbri Planning Limited on behalf of Mr David Rhodri Davies. It in respect of the land at Maes Y Meillion, Llanybri which should be reinstated within the development limits of the village, as well as being included as a housing allocation as part of the Carmarthenshire County Council Second Deposit Revised Local Development Plan 2018 - 2033.
5.2 The extension of the settlement limit of Llanybri, and reintroduction of Maes y Meillion as a housing allocation for the Tier 3 settlement can ensure that a proportional amount of housing growth will be delivered across the plan period. Across the plan period it is highly unlikely that any other sites will come forward in the settlement, therefore it is essential that this site is reconsidered as part of the deposit plan, and as previously mentioned, the site is within limits and allocated for residential development in the current plan. The candidate site to the south is a logical extension of the existing housing allocation, with it currently including agricultural structures that are in a dilapidated state.
5.3 Whilst the soundness of the Plan is not challenged objections are made to the following policies within the deposit plan:
a) Object to SD1 (Development Limits) – the site shown in Appendix A ought to be reinstated within the settlement limits of Llanybri. Within the adopted plan, the site is within limits however it has been placed outside limits in the deposit plan. There is no justification for it`s removal, and allowing development at the land in Maes y Meillion enables a natural extension of the settlement. Lying west of the site is the Parc Y Delyn residential development which has a similar amount of residential dwellings to what has gained outline planning permission at the Maes Y Meillion site, along with a similar layout. The previous candidate site shown in Appendix B should also be included within the settlement limit as it is a natural extension of the existing housing allocation and can be facilitated by infrastructure developed as part of the current site that benefits from outline planning permission.
b) Object to HOM1 (Housing Allocation) – the Maes y Meillion housing allocation is not included within the deposit plan, although the site has been allocated for 10 dwellings within the adopted plan. The site layout in Appendix 3 shows 13 dwellings will be delivered in total. There is no reason for removing the site as an allocation, and it has gained outline planning permission for the erection of 13 dwellings and associated infrastructure work (Ref: PL/00629), and a subsequent planning application was submitted in March 2023 concerning full planning permission for the construction of an access road in order to serve those dwellings. The applicant is keen to progress with the reserved matters for the site shortly, therefore this would be considered a deliverable allocation were it to be included in the deposit plan. It is critical that this housing allocation is reinstated into the deposit plan as at present, no housing allocations are proposed for Llanybri, and there are limited opportunities for residential development in other parts of the settlement. The candidate site aspect as shown in Appendix B is a natural extension of this and should also be included.
5.4 Extending the development limit to incorporate this site would promote sustainable growth in a way that takes into consideration the nature of the current settlement. There needs to be an opportunity for some proportional housing growth within this tier 3 settlement that can be facilitated over the plan period until 2033. The site could potentially deliver 13-20 dwellings which would complement the existing form of the
settlement. It will not give rise to any significant adverse impacts upon the character of the area, local amenities, residential amenity and highway safety whilst providing a suitable contribution to the area’s housing land supply. In addition to this, it is located in a sustainable area where some amenities can be accessed on foot, and nearby Carmarthen can be accessed via a bus service that runs nearby. It is also considered acceptable in terms of drainage and ecological aspects.
5.5 In summary, it is considered that Carmarthenshire County Council should, in its review of the Local Development Plan, include the site within the settlement boundary of Llanybri, and include the Maes y Meillion site as a housing allocation within the deposit plan.