Include the site as an employment allocation within the LDP.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/031/002, seeking inclusion of their land for future residential and employment
development within the defined settlement limits of Cross Hands within the Replacement
Local Development Plan.
The Candidate Site comprises an undeveloped field enclosure set off the rear of a newly
formed operational yard at the rear of Continental Leisure Vehicles showrooms and service
garage at Heol Parc Mawr, upon the Cross Hands Business Park.
The Candidate Site aims to expand off the recently laid surfaced yard and expand the range
of employment opportunities in a north-east direction over undulated scrub land which
eventually reaches several hundred metres distant at the common rear boundary of
residential properties at Black Lion Road in Gorslas.
The 2018 Candidate Site proposed a mixed use of both employment and residential, with
both zones of use achieving vehicular access off the adjacent Cross Hands East Strategic
Employment Site (CHESES), via an extension of an estate road currently under formation as
part of the Phase 2 development of that neighbouring Council-owned site.
The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our clients’ submission, reasons why the site was not selected for inclusion within the draft
settlement limits of Cross Hands, as contained within the Deposit Draft.
We note that the submission successfully passed through the initial Assessment Stages,
being Stage 1 (site compatible against the location of future growth presented in the
Preferred Strategy), and Stage 2A (Initial Detailed Site Assessment). However, it did not
proceed past Stage 2b (Further Detailed Site Assessment) of the Council’s site assessment.
The Council have published reasons for non-inclusion, which are reported as follows:
Our clients have decided to review matters considering the above reasoning and concluded
to remove the element of residential development from the proposed scheme.
Consequently, they only now seek inclusion of land for employment purposes only within
the Deposit Draft of the LDP.
Our clients consider the LDP is “unsound” and should be changed, as it fails to meet the
tests for “soundness”, in that the Plan “is not appropriate”, and “will not deliver”, as defined
by the Planning Inspectorate’s LDP Examinations Procedural Guidance.
Specifically, our clients consider that the Second draft settlement limits for Cross Hands, as
defined under Policy SD1 “Settlement Limits”, should be amended to include the land as
edged in red upon the extract of the Proposals Map for Cross Hands as reproduced
below in Figure 1. The land should be allocated for Employment under Policy SP6
“Employment & The Economy” and EME3 “Employment Proposals on Allocated
Sites.”
Figure 1 – Extract from Proposals Map with Representation site edged in red
This formal representation letter supplements the following documents which comprise a
complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
- Location and Indicative Site Layout Plan
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits
1.0 Availability of Employment Land at Cross Hands
1.1 The Council consider that the only reason for the Candidate Site off Heol Parc Mawr
not being included within the draft Plan as an Employment Allocation is that they
believe that sufficient employment land is already available at Cross Hands to meet
future needs.
1.2 The proposals under this Representation seek the addition of circa 2.0 hectares (4.8
acres) of employment land to provide starter workshops and modest office space, for
which there is a dearth of available opportunities in the settlement. Cross Hands
forms a Principal Centre, being part of the Ammanford / Cross Hands Cluster as
defined within the draft LDP. Figure 2 below provides an extract of the indicative site
layout plan for this Representation site, which as clarified above now only includes for Employment Provision.

Figure 2 – Indicative Site Layout plan of Representation Site
The Cross Hands Cluster aims to provide Employment Land across a wide area, but
principally at Cross Hands East – Sites PrC3/E1 for 8 hectares and Cross Hands
West Food Park (PrC3/E2) for 7 hectares. A further 4.7 hectares is said to be
available at Cross Hands Business Park (Site PrC3/E3). Policy EME3 is reproduced
below in relation to Cross Hands sites:
Figure 3 – Sites Allocated for Employment under Policy EME3
The Council’s reasoning implies that Cross Hands is awash with employment land
opportunities. However, we submit that not all employment opportunities require large
serviced development plateaus as has been created at Cross Hands West Food
Park, and privately off Heol Stanllyd. Those sites are available for large scale new
industrial units, geared to a single user. This theme is also being promoted at Cross
Hands East, although the Council are being selective as to the type of employment
uses permissible upon that half-completed site. The Council seek Research &
Development, hi-technology and high specification engineering operations. Those
uses have been slow in coming forward at Cross Hands East.
1.4 What is immediately apparent at Cross Hands is the lack of opportunities for small to
medium sized businesses to secure business premises, be that workshops, office
units and modest warehousing units. This is notable at the Cross Hands Business
Workshops, which are owned by the Council, but have remained at capacity with no
vacancies for the last few years. Acer Court at Heol Parc Mawr is also full of tenants,
as is Llys-y-Barced, the modern offices at the south-eastern side of Heol Parc Mawr.
See attachments