Include current LDP site T3/9/h4 within the Revised LDP as a housing allocation.

Land South of Cwmgarw Road, Brynamman – ref. T3/9/h4 / ref. SR/015/004

Please find enclosed, on behalf of and under instruction from our clients, Mrs H Wight, Mrs C Dudlyke and G Searles, a detailed Site Representation, submitted to Carmarthenshire County Council for consideration for inclusion / allocation / retention within the 2nd Revised Local Development Plan (LDP).
As required, to enter the site for evaluation within the LDP process at this stage of plan preparation, the following documentation is enclosed with this submission:
• Completed Online Representations Form;
• Site Location Plan;
• Illustrative Masterplan;
• 01C – Proposed Access
• 02B - Proposed Improvements; and
• Detailed case provided in an addendum below.
In addition to the enclosed documentation, a detailed case for the retained inclusion of the Site within the emerging LDP as a housing allocation is provided - which is requested to be carefully and thoroughly taken into consideration in appraising the Site Representation and the site’s credentials for inclusion within the new Development Plan. As well as promoting the retention of the existing allocation within the LDP (Option 1), this representation also seeks to allocate the wider land beyond the existing allocation (Option 2) – in line with Candidate Site ref. SR/015/004, and the existing adopted LDP site allocation ref. T3/9/h4 (or part thereof). As such, this representation comprises an objection to the Deposit Plan on the basis that the site is to be delivered as a residential development during the Plan period.
In the absence of any methodology for the assessment of new allocations, we have reverted to the criteria and methodology outlined within the Site Assessment Methodology (September 2022).
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 2 of 20 We look forward to hearing from you in due course. In the meantime, we hope and trust that all is in order with this submission. Please do not hesitate to contact us in the event that further information is required or considered beneficial.
Yours sincerely
Geraint John
Director
Geraint John Planning Ltd

Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 3 of 20 Preface
Previous representations were made in support of this site, on behalf of the clients, to set out a detailed case for the retention of the site’s allocation within the current LDP, and inclusion of the wider site beyond the existing allocation, in response to the 1st Deposit Plan consultation in 2020.
Carmarthenshire County Council have advised that representations / comments submitted as part of the consultation on the 1st Deposit LDP will no longer be considered. Only those submitted as part of the 2nd Deposit will be considered and forwarded to the Inspector. Any previous representations / comments must be resubmitted and reflect the content of the second Deposit LDP. As such, this submission seeks to ‘build on’ and update the previously submissions made.
Carmarthenshire County Council’s ‘Site Assessment Table’ has set out that the candidate sites / options ref. T3/9/h4 / ref. SR/015/004 submitted through the candidate site process have failed Stage 2b of the Site Assessment Methodology of the candidate site process, and therefore, are not to be progressed as residential allocations.
Separate to the LDP process, the site itself has been previously subject to two previous outline applications for residential development, both of which have been refused. These are as follows:
• PL/01036 – refused 30th July 2021; and
• PL/04459 – refused 17th February 2023.
These applications have sought permission for proposed residential use on the basis that the site benefits from an existing residential allocation with the Adopted Local Development Plan. The proposal has been supported by a comprehensive level of assessment work, to evidence the site’s credentials in that it is not physically constrained by any means. It is therefore considered that the site is deliverable, and would represent an acceptable form of sustainable development in this location – not least that it is allocated for residential use. Moreover, the principle of development is considered acceptable, by way of its existing allocation, and all other planning considerations relating to the site / proposal are addressed by way of detailed supporting material that accompanied the planning submissions.
The second application (ref. PL/04459) is of particular importance, in terms of how it relates to this representation, in that it forms the basis of setting out the acceptability of the site as an allocation for residential development. It is considered that the reasons for refusal are not insurmountable in any event, and by association, would not pose a constraint to the deliverability of the site. Supporting assessment work has evidenced the acceptability of the proposal, in light of the concerns raised that underpin the reasons for refusal.
Accordingly, this submission responds to and addresses the reasons of refusal of the latest application ref. PL/04459, to evidence support the site’s credentials as a residential allocation within the RLDP.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 4 of 20 Detailed Site Representation
As set out on the previous page, these representations object to the Deposit LDP on the basis of the lack of inclusion of deliverable sites. Those being:
(1) The retention of the existing allocation (ref. T3/9/h4) in the LDP;
(2) The allocation of Candidate Site ref. SR/015/004 – which includes LDP allocation T3/9/h4.
The above sites are illustrated on the maps below:
Existing Allocation T3/9/h4 – Option 1
SR/015/004– Option 2
The two options presented above were submitted in response to the previous Deposit Plan consultation in 2020 as potential candidate site options (submission can be found in Appendix B).
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 5 of 20 Carmarthenshire County Council’s ‘Site Assessment Table’ sets out the assessments and conclusions of each candidate site submitted through the LDP Review process. In respect of the candidate site submissions previously made (ref. T3/9/h4 and SR/015/004), the site passed Stage 1 and 2a of the assessment, but was considered to fail Stage 2b for the following reason:
“There are concerns at the deliverability of the site. The site represents a longstanding residential allocation (T3/9/h4) and no firm progress has been made on delivery. Sufficient residential opportunities exist within the settlement.”
The representations below, therefore, set out the objection as a whole against the non-inclusion of the 2 options presented, specifically in response to the reasoning above.
Site Description /Characteristics
This representation relates to the Land South of Cwmgarw Road in Brynamman. As noted above, the representation proposes two options:
1) The retention of the existing allocation (ref. T3/9/h4) in the LDP;
2) The retention of the existing allocation in the LDP, as well as the allocation of the wider land within the site promoters ownership surrounding this site for residential development (as per Candidate Site ref. SR/015/004).
A summary of the characteristics of the site and options is set out below:
• The site is a irregularly shaped greenfield space, consisting of fields and bounded by trees;
• The site promoted in Option 1 is approximately 2ha in area and represents a portion of a wider allocation (approx. 3.5ha total) for residential development in the current LDP;
• The site promoted in Option 2 is approximately 4ha in area and comprises of the land allocated for residential development in Option 1, as well as additional land to the south within the site promoters ownership;
• The site is accessed via two access points in its north-eastern and north-western corners, which are both within the ownership of the site owner;
• The southern and western boundaries of the site comprise of further greenfield land;
• The northern and eastern boundaries of the site consist of the rear gardens of the properties along Cwmgarw Road.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 6 of 20 Site Location Plan with Option 1 Filled in Blue and Option 2 Outlined in Red
Current Planning Status – Designation in the Adopted Local Development Plan
LDP Proposal Map Extracts
Option 1 Outlined in Red and Option 2 in Blue
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 7 of 20 Symbol Designation Symbol Designation
Development Limits (GP2)
Residential Allocation (H1)
Cycle / Proposed Cycle Route (TR4)
Recreation / Open Space (REC1)
Higher Proportion of Welsh Speakers (SP18)
Category 2 Sand and Gravel (MPP3)
Coal Primary Resource Zone (MPP3)
To summarise, the site is:
• Located within settlement limits of Brynamman;
• Allocated for residential development (ref. T3/9/h4);
• Situated within an area with a Higher Proportion of Welsh Speakers;
• In close proximity to an existing / proposed Cycle Route; and
• In proximity to Recreation / Open Space – situated to the north of the site.
The LDP contains a significant number of policies of potential relevance to any development of the site. The key policies of relevance to the site and any proposal are appended to this overview (Appendix A).
Candidate Sites: Assessment Criteria & Methodology
We are aware that, in appraising the credentials of sites for inclusion as an allocation in the Plan, a series of criteria and a methodology have been defined and adopted.
We are also aware that the appraisal process consists of multiple stages, summarised as the following:
• Stage 1: An assessment of the site and its compatibility with the Preferred Strategy;
• Stage 2a: Identification of fundamental site constraints that cannot be overcome or mitigated for;
• Stage 2b: Detailed, site specific assessment including an analysis of its sustainability, viability and deliverability, as well as the assessment of the site against a SA/SEA;
• Stage 3: The sites will be further assessed with a HRA to be carried out to ensure that the Deposit plan has no significant detrimental impact on European Designated Sites.
The stage 1 assessment, as set out within the Site Assessment Methodology (September 2019) included criteria to filter sites out where they may be contrary to National Policy, or unsuitable due to overarching constraints (unless sufficient information is provided to prove otherwise).. As set out above, the site is NOT any of the following designations:
• Sites of Special Scientific Interest;
• Special Area of Conservation;
• Special Protection Areas;
• Local Nature Reserves;
• National Nature Reserves;
• Historic Parks and Gardens;
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 8 of 20 • Scheduled Ancient Monuments;
• C1 and C2 Flood Zones;
• Coal Safeguarding Areas;
• Land Stability and Coal Mining Issues (That are not remediable for economic or other reasons);
• Hazardous Installation Facilities;
• Landfill Sites; and
• Areas of Contamination (That are not remediable for economic or other reasons).
According to the LDP Site Assessment table, the site was found to be compatible with the location of future growth presented within the Preferred Strategy and as a result passed Stage 1. The Candidate Site also went on to pass Stage 2a of the Site Assessment, having been found to have no fundamental constraints which cannot be overcome or mitigated for.
The candidate sites’ performance in these respects have been previously dealt with at both the Candidate Site Stage for the current LDP, prior to its allocation within the Plan, and at the same stage for the Deposit Plan and as a result will not be rehearsed within these representations.
The Site Assessment table outlines that the site failed the Stage 2b Assessment, with the comments noting that this was due to concerns regarding the deliverability of the site. The comments go on to state that ‘There are concerns at the deliverability of the site. The site represents a longstanding residential allocation (T3/9/h4) and no firm progress has been made on delivery. Sufficient residential opportunities exist within the settlement.”
As such, the representations below will relate to the assessment of the site at Stage 2b, highlighting its deliverability during the Plan period.
Key Issues
It is considered that the key arguments in support of the inclusion of the Candidate Site within the LDP for residential development relate to areas identified within the Site Assessment Methodology ‘Stage 2b’, relating largely to site deliverability – this being the sole concern raised within the Sites Assessment at this stage.
However, as previously stated, two separate applications have been made for this site, which demonstrates the clients’ willingness to deliver the site for residential development within the site. Whilst both applications have been refused, it is considered that the concerns associated with the proposal are not insurmountable, and with the support of further assessment work, these issues can be overcome, by way of a further planning application.
Accordingly, in respect of the ‘deliverability’ of the site, it is pertinent to consider the key Reasons for Refusal relating to the previous application (ref. PL/04459), and how this relates to the overall acceptability of the site. The following section sets this out in detail, explaining the reasons for refusal, as well as the clients’ response to how the issues can be overcome – warranting an acceptable candidate site submission for its inclusion / allocation / retention in the RLDP.
Planning Application (PL/04459)
As set out above, the key issues relating to the site’s credentials as a residential allocation within the RLDP relate to its ‘deliverability’. Two separate applications have been made to-date for the proposed development of the site under its current allocation.
The concerns and objections to the proposed residential use, which formed the reasons of refusal for the most recent application (ref. PL/04459), are set out in the table overleaf:
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 9 of 20 ‘Reason for Refusal’
Issue
Basis for concern
1
Fails to demonstrate suitable visibility, which would impact upon highway safety
• Double Yellow Lines are subject to a Traffic Regulation Order – which cannot be conditioned.
• Lack of information to confirm that adequate access and visibility is proposed.
2
Would result in a net loss of biodiversity
• Would have an impact on priority species and habitats, resulting in a loss of Section 7 habitats.
• Mitigation proposed is unsuitable.
3
Fails to provide any community benefits
a) No legal agreement has been committed to.
In light of the above reasons for refusal, it is considered expedient to set out a detailed response to each. Before doing so, it is necessary to make the point that the clients contend the view and position taken that the scheme is unacceptable in both highways and ecology terms (Reason for Refusal 1 – highway safety, and Reason for Refusal 2 – Ecology).
Lengthy discussions took place with the Highways Authority, before and during the application process, particularly with the Applicant’s highway consultant, to discuss all matters pertaining to highway safety. Highways design proposals were submitted to obtain feedback, and necessary amendments were made to reflect the changes request by the HA, to ensure that the scheme would be acceptable. Throughout this process, it was acknowledged that the proposed Double Yellow Lines (DYL) to secure the appropriate visibility splays, would be subject to a Traffic Regular Order – a separate consultation process. However, it was not considered expedient, nor appropriate to in any event, to commence this process until planning permission had been secured for the proposal. As such, it was considered that the requirement for a TRO could be conditioned upon any granting of the planning permission.
In respect of ecology, it is acknowledged and accepted that an alternative means of mitigation is required, given that the previous proposal would have not been acceptable – in that it would not have achieved a ‘net benefit’. The mitigation proposed comprised the translocation of existing Section 7 habitat species to a supplementary area (within the Applicant’s ownership) where the species were already present. Accordingly, it was deemed that no translocation could take place, and therefore, no net gain could be achieved. As such, alternative areas of mitigation within the Applicant’s control were required to offset any ecological impacts.
Finally, in respect of Reason for Refusal 3, it is considered that this will “fall away”, in that the necessary legal agreements can be agreed and implemented, to secure community benefits. Given the aforementioned issues were ongoing, it was not considered expedient to commence the drafting of legal terms until the position had been resolved, and was progressing to a favourable conclusion.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 10 of 20 Having set out these matters, the following responses are made in respect to each of the reasons for refusal.
Highways
The Decision Notice for this application set out that there were two elements of which the proposal was not acceptable under highway grounds, relating to:
a) Double yellow lines (DYL) as proposed are subject to a Traffic Regulation Order and would displace parking for existing dwellings; and
b) There is a lack of information to confirm that adequate access and visibility is being proposed.
The above matters are discussed further below.
a) Double Yellow Lines & displacement of parking
Double Yellow Lines
In relation the need to carry out a TRO, it was conceived that measures subject to a TRO could not be conditioned upon any permission, as it is a separate process. Specifically, the following is outlined on the Decision Notice:
‘Measures subject to a Traffic Regulation Order cannot be conditioned as they are subject to consideration under other legislation and there is no reasonable certainty that they will be found acceptable. This process should be undertaken at the developer’s expense prior to resubmission of any application.’
However, it is considered that a ‘Grampian’ condition could have been imposed upon any permission, which would seek to control the development, subject to a TRO being carried out, prior to works commencing on site / occupation. Specifically, the following condition working could have been utilised:
“The development hereby approved shall not be occupied until a scheme to provide Traffic Regulation Orders along Cwmgarw Road has been submitted to and agreed in writing by the Local Planning Authority. The works shall be completed in accordance with the approved details prior to any works commencing on site.”
In addition, WG Circular 016/2014, (Oct 2014) : ‘The Use of Planning Conditions for Development Management’ sets out the following when advising on Access conditions:
5.34
“A ‘Grampian’ condition can be used to prevent the commencement of development until certain highway improvements are made, if they relate directly to the development. TAN 18 (Transport) provides further advice with regards to such conditions.”
Moreover, Annex F of Tan 18 : Transport, set outs in para. F1 that
“Planning authorities may grant planning permission subject to a condition that development should not be commenced or occupied until some obstacle to the development has been surmounted (a ‘Grampian Condition). This may include the carrying out of highway works. A ‘Grampian’ condition may be necessary where works must be caried out in an existing highway in order to safely and efficiently accommodate traffic created by a development.” (GJP Emphasis).
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 11 of 20 Clearly, the imposition of a Grampian condition is supported by legislation and national policy, to ensure that highway issues relating to a development are not insurmountable, and are addressed in an appropriate manner. The highlighted text clearly demonstrates that Grampian conditions relating to highway works are acceptable, which is of course pertinent to the refused application i.e. carrying out of a TRO to implement DYL.
It should be recalled that it is considered that the TRO is to be needed to make the development acceptable in planning terms. The TRO will be confined to highway land / extent – which is always pre-supposed to be available to development to make an otherwise unacceptable position acceptable. CCC Highways are in control of the TRO, and having required its entering into in the first place cannot then determine that it is not possible or appropriate to enter into. This means that any condition meets the test of being necessary, reasonable, related, precise and enforceable etc.
The other point to make is that without a scheme there’s no need for a/the TRO. The latter therefore follows the former. This is the same principle and approach to all other regulatory regimes – building control following planning / licensing following planning. Without an approval to the development in the first place, these other regulatory processes have no meaning or purpose.
In summary, it has not been / is not considered expedient to commence the TRO process simultaneously to the application, given in any case it can be undertaken thereafter following approval, which, as evidenced above, can be controlled by condition.
Accordingly, in terms of how this relates to the promotion of the site as an allocation within the new Plan, the above evidences that the site is deliverable, in that the requirement to undertake a TRO can be actioned in any event, and is not an insurmountable issue that would deem the site undeliverable.
Displacement of Parking
It was raised by the HA that the proposed implementation of DYL, to the east of the proposed access, to ensure that appropriate visibility splays are achieved, would result in the displacement of existing residents’ parking.
It is noted that the existing arrangement comprises residents parking off Cwmgarw Road, along the pavements, which do not constitute formal off-road parking. The result of this existing arrangement poses a risk to highway safety, in that the width of Cwmgarw Road is narrowed, thus increasing the likelihood of car collisions across this stretch of the road. In addition, the pavement is also narrowed, culminating in a tight space for wheelchair uses and child push chairs i.e. vulnerable users, to use the pedestrian path.
The proposed alterative arrangement, as illustrated below, would address the existing highway safety concerns set out above, whilst also providing a safe means of parking for the residents. The proposal takes the form of providing safe and accessible parking along the bow access road into the development, off Cwmgarw Road.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 12 of 20 Proposed Access Arrangements
In total, there is capacity for 3no. cars to park along the access road, without causing any detriment to highway safety, and this would serve the two existing dwellings east of The Tregib Arms (public house). It is proposed that this stretch of the internal high network of the development is to be adopted, and therefore, there is no constraint proposed that would prohibit car parking here. Moreover, tactile paving is proposed near the access to facilitate safe pedestrian crossing from this stretch of road to the forementioned dwellings – to ensure that there is a link between the car parking and dwellings.
As such, it is considered that the parking proposals represents a safer and more appropriate arrangement than that of the existing, therefore, resulting in a betterment for highway safety.
b) Adequate access and visibility
To support the planning application submission, an Access Design was submitted, setting out the proposed access arrangements. As shown in the extract below, visibility splays of 2.4m x 43m can be achieved in either direction, which is considered to be appropriate for a 30mph road. This is supported by Manual for Streets guidance which sets out that under the assumption that 85th percentile traffic speeds are no more than 10% above the posted 30mph speed limit, visibility splays of 2.4m x 43m in each direction are required. As such, the proposed visibility splays comply with the pertinent guidance.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 13 of 20 Proposed Access Design
Of course, the proposed access design is subject to the TRO process, as discussed above, to ensure that parked cars do not impinge upon visibility for cars egressing the site. Specifically, the yellow lines will extend into the development site to remove parked vehicles from within the junction bellmouth, and allow vehicles on exit from the site to approach Cwmgarw Road correctly i.e. perpendicular to it.
As previously set out, it is considered that the TRO can be undertaken in any event, for the proposed DYL, and therefore, the proposed arrangement does not give rise to any highway concerns, in that it represents a safety improvement to the existing position.
In summary, the proposed site access junction provides sufficient visibility to ensure highway safety is not adversely affected by the development. The increase in traffic generated by the proposal is negligible, and therefore, will not cause any detriment to Cwmgarw Road.
Ecology
The Decision Notice (PL/04459) outlined that the proposal would have a negative impact upon biodiversity within the site, in regard to existing priority species and habitats. Specifically, the following is set out:
“The proposed development will have an adverse impact on priority species and habitats and result in a loss of Section 7 habitat, marshy grassland and broad-leaved woodland as well as loss of otter habitat (bramble) and dormouse habitat (dense scrub). Marshy grassland and broadleaved-woodland are habitats that appear on the Environment (Wales) Act 2016 Section 7 list of habitats of key significance to sustain and improve biodiversity in relation to Wales.”
To offset the loss of Section 7 habitats, it was proposed through the application that these would be translocated to the south-western area of the site, which would act as a ‘mitigation area’. Essentially, this comprised the proposed translocation of Marshy Grassland and the planting of Semi-Natural broad-leaved woodland.
However, it was advised by the Council’s ecologist that the proposed mitigation area already contained the Section 7 habitats, and therefore, translocation / planting could not be achieved as these habitats were already in-situ.
The clients have been in discussions with the scheme’s Ecologist in regard to exploring alternative areas of land, which have potential and capacity to accommodate the necessary translocation of the Section 7 habitats. The clients own a number of parcels of land that are within their control, which are located within the vicinity of the promotion site. It is considered that these parcels are sufficient in size in that they can meet the requisite ratios of planting and translocation, to mitigate the loss of the protected species within the site.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 14 of 20 Ecology surveys are to be undertaken of these parcels, to unequivocally confirm their suitability to act as a mitigation area for the development, however, a desk-based review has confirmed that there are no existing Section 7 habitats present within these sites – contrary to that of the previously proposed mitigation area.
Accordingly, it is considered that there are possible solutions to overcome this ecology issue, with neighbouring land having the potential to accommodate the required translocation of the Section 7 habitats. As outlined above, these lands are within the clients’ control, and therefore, it is considered that there are no legal issues associated with this possible approach. As such, the possible ecological impacts of the development can be mitigated for, to ensure that a biodiversity ‘net gain’ is achieved with the development of the site.
In light of this, it is conceived that the ecological position does not present a constraint to the deliverability of the site, as a proposed residential allocation within the RLDP, and therefore, is wholly acceptable in respect of this Reason for Refusal.
Legal Agreement
Finally, in respect of Reason for Refusal 3, the Decision Notice sets out that the proposal “does not contribute to the creation of sustainable places and spaces since the proposal has not been accompanied by a commitment to enter into a legal agreement to secure any community benefits.”
Given that discussions were ongoing between the Applicant and the LPA, in relation to the outstanding issues discussed above (i.e. highways and ecology), it was not considered expedient to undertake the necessary arrangements to prepare a legal agreement i.e. S106 agreement. It was acknowledged throughout the application process that contributions would be required, as part of the approval, following consultation responses received from statutory consultees.
Both the principle and the detail relating to the requested contributions were not disputed by the Applicants, nor would be in any event for a future application, as it is expected that a proposal of this nature and scale would warrant a S106 application – given the effects on the wider community.
Given the aforementioned issues were ongoing, it was not considered expedient to commence the drafting of legal terms until the position had been resolved, and was progressing to a favourable conclusion.
It is therefore considered that the securement of a legal agreement is not an insurmountable issue that would deem the development undeliverable, and therefore, would not impede upon the site’s allocation within the RLDP.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 15 of 20 Other Planning Considerations
Land Ownership
The site could make a realistic (and sustainable) contribution towards the provision of housing land within Carmarthenshire over the LDP period.
The land – representing a large portion of the site as allocated within the existing LDP – is wholly within the ownership of the site promoters, Mrs H Wight, Mrs G Searles and Mrs C Dudlyke, and no restrictions / constraints to the development of the site coming forward over the plan period are identified. The land is readily available to come forward for development, as evidenced by the proceeding sections.
Sustainability
Sustainability and Linkages with Nearby Settlements
As referred to above, the site is located within the settlement limits for Brynamman, which is identified as a Local Service Centre within the current local development plan. As a result, the site has close association and linkages with the facilities and services available within the settlement. A key destination for local residents is The Black Mountain Centre, which comprises a community centre including a café, post office, library and doctors surgery. Other services located within the settlement and within close proximity to the site include a number of public houses, places of worship, food / retail outlets and amenity / recreational facilities.
Pedestrian footways are provided on both sides of Cwmgarw Road with a general width of at least 1.5m, albeit with some instances of localised narrowing due to physical constraints or footway parking. There are also opportunities for cycling in the area, mainly consisting of on-carriageway routes although National Cycle Route 437 is accessible within 500m of the site, linking the site to Ammanford in the west and Cwmllwynfell in the east.
Evidently, the site is located in a highly accessible location, within easy and convenient walking distance of the services provided within Brynamman, with a range of facilities on offer. The site therefore benefits from being positioned within a highly sustainable location – which in light of the availability existing services and facilities, is considered extremely well-suited to residential development. It is considered that the services and facilities in close proximity to the site would facilitate and encourage the growth of the settlement in both a natural and sustainable manner.
Public Transport
The proposed development site is well served by public transport with a number of regular scheduled bus services running along Cwmgarw Road. Bus stops are available well within the recommended maximum walking distance of 400m from the application site, with travel via bus available in both directions near the site frontage.
The bus stops along Cwmgarw Road are served by service numbers X26, 64, 124, 167 and 905, providing services to Swansea, Upper Brynamman, Tycroes, Neath Abbey, Ammanford, Ystradgynlais, Crynant and Cwmtwrch Isaf.
In terms of rail transport, Ammanford railway station is located approximately 9.4km to the west of the site. Whilst not convenient for all, it could be used as part of a multi-modal journey along with a car, taxi, bicycle or bus.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 16 of 20 Flood Risk
The relevant extract from Natural Resources Wales’ Development Advice Map (DAM) (NRW) Flood Map is provided overleaf. This confirms that the representation site is not at risk of flooding.
Extract from NRW Flood Map
Key:
Heritage and Conservation
The Historic Wales website indicates that there are no Listed buildings or Scheduled Ancient Monuments on or within close proximity of the site. Moriah Chapel, situated in the north-eastern corner of the site, is contained as a National Monument Record for Wales and within the Welsh Archaeological Trusts’ Historic Environment Records as a post-medieval church. Given the residential setting of the chapel, the impact of the residential development of the site is expected to be negligible.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 17 of 20 Extract from NMR (Historic Wales)
Tree Preservation Order (TPO)
Carmarthenshire County Council’s online map indicates that there are no protected trees on site as illustrated below:
TPO Map Extract
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 18 of 20 A tree survey of the site has been carried out by ArbTS which will guide the form of development proposed at the site. It is considered that appropriate access, infrastructure and built form can be incorporated within the site without detrimentally impacting the existing trees on the site.
Summary and Conclusions
As outlined above, it is considered that the site is a highly suitable location for housing, and for inclusion as such within the emerging LDP at the Candidate Site stage. To summarise:
• The land lies within the settlement boundary for Brynamman, and within a defined ‘Local Service Centre’.
• The site (Option 1) is currently afforded a residential allocated status within the currently adopted LDP, and this should be considered as the baseline for the site.
• The Reasons for Refusal of planning application ref. PL/04459 are not considered to be insurmountable, in that they would culminate in the proposal being either undeliverable or unacceptable, therefore, representing an appropriate form of development.
• The development of the site would not unduly damage the character of the surrounding area, due to the site’s location within an existing residential area and its strong association with the settlement of Brynamman.
• The site benefits from a close association and connection with the services and facilities provided within Brynamman, which are situated within convenient walking distance (which would facilitate sustainable growth of the settlement).
• The sustainability and accessibility credentials of the site lend themselves to supporting residential development at this location – several bus stops are located immediately north of the site on Cwmgarw Road.
• The land is not identified as being of any special landscape / nature conservation / ecology interest – it is not afforded any such protection status within the current LDP; and
• It is considered that the inclusion of this land for residential development will assist the Local Authority in meeting their housing needs provision.
• The site is wholly deliverable and can realistically come forward within the early years of the Plan period.
• Object to the Deposit LDP on the grounds that the site isn’t included and is set to be delivered, as set out above.
We consider that the site ‘performs’ well against the defined assessment criteria and methodology, with no evident constraints, obstacles, or failings.
Our clients would be happy to discuss any aspect of the submission made and credentials of the site when your Authority (and the appointed Inspector in turn) comes to evaluate matters.
We respectfully urge you, for the reasons given herein and in the associated submitted information, to include the site put forward within the emerging LDP for housing development.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 19 of 20 APPENDIX A – CARMARTHENSHIRE PLANNING POLICY
Ref. Title Summary
SP1
Sustainable Places and Spaces
Proposals for development will be supported where they reflect sustainable development and design principles subject to a number of criteria.
SP2
Climate Change
Development proposals which respond to, are resilient to, adapt to and minimise for the causes and impacts of climate change will be supported subject to a number of criteria.
SP3
Sustainable Distribution – Settlement Framework
Provision for growth and development will be at sustainable locations in accordance with the settlement framework. Llanelli is identified as a Growth Area.
SP9
Transportation
Proposals should contribute to the delivery of an efficient, effective, safe and sustainable integrated transport system.
SP13
Protection and Enhancement of the Built and Historic Environment
Development proposals should preserve or enhance the built and historic environment of the County, its cultural, townscape and landscape assets and where appropriate, their setting.
SP14
Protection and Enhancement of the Natural Environment
Development should reflect the need to protect, and wherever possible enhance the County’s natural environment. All development proposals should be considered in accordance with national guidance/legislation and the policies and proposals of this Plan, with due consideration given to areas of nature conservation value, the countryside, landscapes and coastal areas.
GP1
Sustainability and High Quality Design
Development proposals will be permitted where they accord with a range of criteria.
GP2
Development Limits
Proposals within defined Development Limits will be permitted, subject to policies and proposals of this Plan, national policies and other material planning considerations.
GP3
Planning Obligations
The Council will, where necessary seek developers to enter into Planning Obligations (Section 106 Agreements), or to contribute via the Community Infrastructure Levy to secure contributions to fund improvements to infrastructure, community facilities and other services to meet requirements arising from new developments.
GP4
Infrastructure and New Development
Proposals for development will be permitted where the infrastructure is adequate to meet the needs of the development.
H1
Housing Allocations
Land has been allocated for residential development for the plan period 2006 – 2021 at those locations as set out in the LDP, and as depicted on the Proposals Map.
H2
Housing within Development Limits
Proposals for housing developments on unallocated sites within the development limits of a defined settlement will be permitted, provided they are in accordance with the principles of the Plan’s strategy and its policies and proposals.
AH1
Affordable Housing
A contribution to affordable housing will be required on all housing allocations and windfall sites. The Council will seek a level of affordable housing contribution of 30% in the higher viable areas, 20% in the middle viable areas, and 10% within the Ammanford / Cross Hands sub-market areas.
Where viability at the target levels cannot be achieved, variation may be agreed on a case-by-case basis.
TR2
Location of Development – Transport Considerations
States that proposals which have a potential for significant trip generation will be permitted where:
a) it is located in a manner consistent with the plans strategic objectives, its settlement framework and its policies and proposals;
b) it is accessible to non-car modes of transport including public transport, cycling and walking;
c) provision is made for the non-car modes of transport and for those with mobility difficulties in the design of the proposal and the provision of onsite facilities;
d) travel plans have been considered and where appropriate incorporated.
TR3
Highways in Developments – Design Considerations
The design and layout of all development proposals will, where appropriate, be required to include a range of criteria. Proposals which do not generate unacceptable levels of traffic on the surrounding road network and would not be detrimental to highway safety or cause significant harm to the amenity of residents will be permitted. Proposals which will not result in offsite congestion in terms of parking or service provision or where the capacity of the network is sufficient to serve the development will be permitted.
TR4
Cycling and Walking
Developments should, where appropriate seek to incorporate, or where acceptable, facilitate links to the cycle, rights of way and bridleway network to ensure an integrated sustainable approach in respect of any site.
REC2
Open Space Provision and New Developments
All new residential developments of five or more units will be required to provide on site open space in accordance with the Council’s adopted standards of 2.4ha per 1000 population.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 20 of 20 Ref. Title Summary
EQ4
Biodiversity
Proposals for development which have an adverse impact on priority species, habitats and features of recognised principal importance to the conservation of biodiversity and nature conservation, will not be permitted, except where it can be demonstrated that unless specific criteria can be met.
EP1
Water Quality and Resources
Proposals for development will be permitted where they do not lead to a deterioration of either the water environment and/or the quality of controlled waters. Proposals will, where appropriate, be expected to contribute towards improvements to water quality.
EP2
Pollution
Proposals for development should wherever possible seek to minimise the impacts of pollution. New developments will be required to demonstrate that they:
• Do not conflict with National Air Quality Strategy objectives, or adversely affect to a significant extent, designated Air Quality Management Areas;
• Do not cause a deterioration in water quality;
• Ensure that light and noise pollution are where appropriate minimised;
• Ensure that risks arising from contaminated land are addressed through an appropriate land investigation and assessment of risk and land remediation to ensure its suitability for the proposed use.
EP3
Sustainable Drainage
Proposals for development will be required to demonstrate that the impact of surface water drainage, including the effectiveness of incorporating Sustainable Drainage Systems (SUDS), has been fully investigated