No change in respect of this representation, however attention is drawn to the respondent's other representations: 5703, 5704 & 5705.

1. We (the Tirycoed Campaign Group) support the removal of the ground to the west of the old Maternity Hospital from "housing development" (See red circle on map) on conservation and access restriction grounds.
In terms of conservation the area qualifies for SINC status given that the rhos pasture and hedges which are protected habitats1. The habitats are currently supporting or capable of supporting the following species; bats2, dormice3, hedgehogs4, badgers5, otters6, newts7, lizards8, herons9, eels10 (in Nant Llwyd), water voles11, Marsh Fritillary Butterflies12, Scabious spp (Succisa pratensis in particular)13, Purple Moor Grass (Molinia caerulea)14, Brambles (Rubrus fruticosus) and Bracken (Pteridium aquilinum).
1 https://naturalresources.wales/guidance-and-advice/environmental-topics/wildlife-and-biodiversity/protected-areas-of-land-and-seas/types-of-protected-areas-of-land-and-sea/?lang=en
2 All bat species (and their breeding sites) are protected under schedule 5 of the Wildlife & Countryside Act 1981 and since 2007 the
effective protection for bats now comes from Schedule 2 of the Conservation (Natural Habitats &c) Regulations 1994, and in the EU under
Article 12 of the Habitats Directive, which means that capture, killing, deliberate disturbance and destruction of their breeding sites and
resting places is prohibited.
3 Dormice (Muscardinus avellanarius) are protected under the aegis of the Wildlife and Countryside Act 1981 – schedule 5, a conservation
priority species in the UK (Environment Wales 2016 Act) and a European Protected Species (Habitats Directive 92/43/EEC – schedule 2).
Schedule 2 states it is an offence to destroy their habitat (breeding site or resting place).
4 Hedgehogs (Erinaceinae europaeus) are listed on Schedule 6 of the Wildlife and Countryside Act 1981 and the Wild Mammal Protection
Act 1996.
5 Badgers and their setts are legally protected from intentional cruelty and from the results of lawful human activities (The Protection of
Badgers Act 1992)
6 Otters (Lutra lutra) are strictly protected by the Wildlife and Countryside Act 1981 and the EU Habitats Directive (92/43/EEC – Annex 4)
and a priority species for maintaining biodiversity (Environment (Wales) Act 2016).
7 All newt species are protected under the aegis of the Wildlife and Conservation Act 1981 and the Great Crested Newt (Triturus cristatus)
is a priority species (Environment (Wales) Act 2016) and a EU protected species (Habitats Directive 92/43/EEC- Annex 4)
8 The common Lizard (Zootoca vivipara) is protected under the aegis of the Wildlife and Conservation Act 1981 and a priority species
(Environment (Wales) Act 2016) and the UK post 2010 Biodiversity Framework.
9 The heron is a protected species under the Wildlife and Countryside Act 1981, with fines or prison sentences available for anyone killing
or attempting to kill one
10 Eels are protected as an endangered species by the Convention on International Trade in Endangered Species of Wild Fauna and Flora
(CITES)
11The water vole is fully protected under Schedule 5 of the Wildlife and Countryside Act 1981 and is a priority conservation species.
12Marsh Fritillary Butterflies are protected under schedule 5 of the Wildlife and Countryside Act 1981 and Wildlife (NI) order 1985, a
priority species (Environment (Wales) Act 2016), and an EU protected species (Habitats Directive 92/43/EED – Annex 2).
13 Important food for Marsh Fritillary Butterfly caterpillars

Marsh Fritillary Butterfly - Charles J. Sharp, CC BY-SA 4.0 <https://creativecommons.org/licenses/by-sa/4.0>, via Wikimedia Commons
More on the importance of conservation in this area can be found at https://thunderbolt.me.uk/Docs/DrStudley-Objection-Rev3.pdf which were submitted under the aegis of PA E/38266, but applies equally to the RLDP

We also support the removal of this area from “housing development” because it would make it difficult for potential developers to build roads from Tirycoed Road to the old maternity hospital. It was removed because CCC considered the area was undeliverable and was aware of the extent of opposition against its inclusion (Neil Bateman pers. comm 27/2/23). Tirycoed Road is already a single track road for much of the day (See photo gallery) and is potentially very hazardous for pedestrians and equestrians. In both petitions (Daffyd Wyn and TCG) local residents cited traffic issues as a main reason for objecting to PAs PACs and LDPs. The prospect of up to 50 new cars in not tenable.
2. We object to possible housing development on the remaining development site (See purple box on map below) on conservation grounds and lack of access. The management of Amman Valley Hospital have stated to us that they would not support any housing development on the old maternity hospital site.
We would remind CCC that nearly 700 people objected to housing development on this site under the aegis of both the RLDP and the current PAC (S21.186). (See online petition https://www.change.org/p/no-to-the-housing-development-on-tirycoed and door to door petition https://thunderbolt.me.uk/Docs/Tirycoed%20Petition%20Redacted.rar )

We would also draw your attention to the fact, that the actual size of this site would support a great deal more homes than the 25 currently being proposed in PAC S21.186. However we also object on the understanding that the current LDP cannot be met on the following grounds:
SP2 Retail and Town Centres
Both the Brecon Beacons and Glanamman have an ageing demographic. Glanamman only has one small convenience store. There are no large retail outlets, unless you travel to Ammanford. There is no Dentist, the GP surgery is oversubscribed, there are no leisure facilities nearby and the local infrastructure is not able to cope with an influx of housing on this scale.
SP3 Sustainable Distribution – Settlement Framework
There are very few services available in this location and a housing development would put huge strain on existing ones. We constantly suffer from disrupted water supplies due to the ageing and inadequate water supply system, which would be overwhelmed by the additional capacity needed.
SP4 A Sustainable Approach to Providing New Homes
There has never been an “appropriate number” of houses suggested for this site. Although 25 dwelling houses are currently being requested, it is very clear that the site has capacity for at least 100. That would be a massive burden on the local infrastructure and facilities. The access road is not suitable for such volumes of traffic and there are already huge issues with water supply and drainage which have never been addressed.
SP9 Infrastructure
Given that some Tirycoed residents have had to pay for the upgrading of their electricity supply, due to its lack of capacity, we are only too aware how poor the local infrastructure is but especially water, electricity capacity and drainage.
SP12 Placemaking and Sustainable Places
Sustainable Placemaking should be holistic and inclusive and rightly be at the heart of any planning decision. It is important to recognise that sustainable placemaking is contingent upon local “sense of place” (comprised of place attachment, place identity, and place meaning), intrinsic value of place, and well-being (aka satisfaction, happiness). Most communities are resilient in the face of small changes that take place gradually. Sense of place, intrinsic value of place and well-being are distinctive in rural communities and may take several generations to develop. Rapid population growth or an influx of new people who are not wanted and who do not share the same sense of place or intrinsic value undermines social cohesion, place identity and place-making. There was some evidence that placemaking was undermined as a result of the introduction of flats on Tirycoed Road and this would be exacerbated should housing development go ahead.

Integrating wellbeing with sense of place helps make more explicit a range of social issues important for human welfare. Furthermore it draws out the importance of the phenomenological meanings that people attach to places through place attachment, place
dependence, place identity, and place satisfaction. There are other often less tangible matters that arise as a consequence of changes in population size and structure that can impact wellbeing. This is a reflection of people's capacity to adapt to change, especially if change occurs at a rapid pace. For example, rapid increases in the size of a community can engender a sense of pessimism about the future and so affect people's sense of wellbeing. Similarly, changes in the composition of the population, in terms of demographics can lead to anxiety or tension impacting on the cohesion of society.

Very little has been done in Tirycoed under the aegis of PAs PACs or LDPs to assess the impact of housing development in terms of local identity sense of place, social cohesion, wellbeing or the undermining of the Welsh language
Furthermore any development should; comply with Welsh Government policy on sustainable places https://research.senedd.wales/research-articles/making-sustainable-places-what-role-can-the-planning-system-play/, and take account of the Well-being of Future Generations (Wales) Act 2015 and be predicated on
• Making the best use of resources;
• Facilitating accessible and healthy environments;
• Creating and sustaining communities; and
• Maximising environmental protection and limiting environmental impact.
Seemingly housing development will fail to meet most of those expectations. There are dangers that development will destroy established habitat and endangered species, it will cause light pollution and it will adversely affect community cohesion in which it is being placed.
SP13 Rural Development
Instead of increasing the enjoyment of the countryside, housing development would destroy it! The site is located close an area of outstanding natural beauty and the Amman Valleys unique cloud forest where wildlife currently thrives. Allowing such a large development on such precious land appears to be contrary to current rural development policy https://research.senedd.wales/research-articles/the-rural-development-plan-for-wales/ which is predicated on “the sustainable management of natural resources and climate action”
SP14 Maintaining and Enhancing the Natural Environment
Housing development will destroy our unique and bio diverse landscape and our protected habitats and lead to loss of biodiversity. There are very real dangers that development will lead to the de-wilding of the site and the subsequent loss of bats, dormice, hedgehogs, badgers, otters, newts, lizards, herons, eels (in Nant Llwyd), water voles, Marsh Fritillary Butterflies, Scabious spp (Succisa pratensis in particular), Purple Moor Grass (Molinia caerulea) and winter visitors such as snipe and woodcock

Devils Bit Scabious- Christian Fischer, CC BY-SA 3.0 <https://creativecommons.org/licenses/by-sa/3.0>, via Wikimedia Commons
Previous planning applications have absolutely failed to address the issue of habitat destruction (Which the developers have been actively engaged in). Endangered species will be displaced and lost and riparian corridors will be blocked preventing otters (which are low in Wales) from travelling.

Example of habitat destruction on the site
SP15 Protection and Enhancement of the Built and Historic Environment
The old maternity hospital is unique and is considered the “heart” of the community. It still has an iconic status on the basis that the first NHS baby was born there on 5/7/1948. Given that many local people were born there and they retain a very strong sense of emotional attachment it would be sacrilege to demolish it. Furthermore the carbon cost of demolishing it (13 T C) and replacing it (242 T C) would be 255 TC which is more than double the carbon cost of refurbishing or retrofitting it which would be 120 T C (Hurst 2021: O’Hegerty 2021)
255 T C is the equivalent of the sequestration of 4,216 tree seedlings over 10 years (Greenhouse Gas Equivalencies Calculator | US EPA)
If it were replaced by 20 houses the carbon cost would be about 2,410 T C or the equivalent of the sequestration of 40,000 trees over 10 year (Berners-Lee 2010)
It would be better to refurbish and retrofit the existing building in terms of its carbon saving and its historic and psychological (place attachment) value.
Absolutely no consideration has been given to the wishes of the local community nor the protection of this historic site.
SP16 Climate Change
The destruction of Rhos pasture, trees and grassy marshland on this site would be an absolute disaster for the local environment and for the loss of carbon stocks. Paving over huge areas for roads and paths will create hard standing that will cause rain water to surge onto surrounding roads and properties, causing flooding. Previous planning applications have had few mitigating measures for renewable energy, carbon negative building materials or energy conservation schemes.
There has been no carbon audit of potential housing development on this site. It has been estimated (Drexler et al 2021, NERR094) that the current carbon stocks (rhos pasture, shrubs and hedges) on the whole site (ca 2ha) are 220 T C which will be cut by 84.75 T C to 135.25 T C after housing development. The carbon emissions (Berners-Lee 2010) as a result of development (25 houses plus roads, paths, drives, parking bays) will be approximately 3000 T CO2 and there will be a sequestration reduction of 0.125 T C yr (NERR094)
SP19 Waste Management
Safeguarding resources would not be achievable if planning permission were granted for this site. The loss of trees and pasture would contribute to Climate Change while the amount of carbon that would be released (3000 T CO2) during the construction phase alone would be damaging to the environment.
3.We suggest to CCC that the development site it taken into public ownership or classified as community or public space1 and refer CCC to your obligations under the aegis of the placemaking guide 2020. (https://dcfw.org/wp-content/themes/dcfw-child/assets/PlacemakingGuideDigitalENG.pdf)
The importance of community space was highlighted In a recent supreme court ruling - Hilary Term (2023) UKSC 8 on appeal from (2020) EWCA civ 1751- (R (on the application of Day) (Appellant) v Shropshire Council (Respondent) (landmarkchambers.co.uk)) where the court ruled in favour of the local community.
Furthermore the importance of having access to community space was a frequent theme highlighted in a consultation report on connected communities, and is especially important for Tirycoed’s aging population https://www.gov.wales/sites/default/files/consultations/2019-03/summary-of-responses_2.pdf
4.We propose that the site be used for well-being, conservation and recreation (with a well-being centre, a conservation area with pond, and board-walks for recreation and for interpretative trails (perhaps inter-connecting with Glyndrainog and Ty Llwyd farms). I would also remind CCC that the site is adjacent to the most important breeding ground (on Glyndrainog Farm) for the Marsh Fritillary Butterfly in the Amman Valley and to your obligations under the placemaking charter (http://dcfw.org/placemaking/placemaking-charter/) to provide spaces to promote prosperity, health, happiness, and well-being in the widest sense.
This would meet the current requirements on the following grounds:
SP1 Strategic Growth
The installation of Health and conservation facilities would be far more beneficial for Tirycoed’s aging demographic than housing for outsiders. Furthermore the site and its interpretive trails would be within easy reach of local Schools, so could be used as an outdoor education centre for children and adults alike.
SP2 Retail and Town Centres
Having a Community lead health and conservation facility on this site benefits everyone.
SP3 Sustainable Distribution – Settlement Framework
Our suggested project (The Tirycoed Well-being Centre) not only uses the existing building foundation as its base but it will be refurbished, retrofitted and managed sustainably, the exact opposite of the current proposals.
Retrofitting is the act of fitting new systems designed for high energy efficiency and low energy consumption to buildings previously built without them. This can range from small activities such as fitting energy-efficient light bulbs to installing state of the art heating systems. The reasons for doing this are simple. A more efficient building will be cheaper to run, have a lower impact on the environment and the higher energy rating that comes with this can increase the value of the property. There is a broad spectrum of commonly used methods of sustainably retrofitting properties. These include solar panels, smart meters and sustainable water and heating systems. It should be noted that the maintenance of these systems is just as important a consideration as their energy efficiency. https://www.elmhurstenergy.co.uk/blog/2022/06/29/what-is-retrofit-in-construction/#:~:text=Retrofitting%20is%20the%20act%20of,of%20the%20art%20heating%20systems.
SP6 Strategic sites
This project will invest in the local Community and provide much needed facilities for all, but especially our ageing population1. This inward development will also create local sustainable jobs, benefit local business and bring a much needed boost to the local economy.
1 In Carmarthenshire between 2011 and 2021 there was an increase of 18.9% in people aged 65 years and over, a decrease of 2.5% in people aged 15 to 64 years, and a decrease of 0.8% in children aged under 15 years https://www.ons.gov.uk/visualisations/censuspopulationchange/W06000010/
SP7 Employment and the Economy
This project will invest in the local Community and provide much needed facilities for all, but especially Tirycoeds aging population. Currently there are no leisure facilities. This inward development will also create local sustainable jobs, benefit local business and bring a much needed boost to the local economy. It will also serve as a Community hub, allowing people to meet and interact, something a housing estate appears to discourage.
SP8 Welsh Language and Culture
The plan to build houses on this site will simply allow wealthier people from outside the local area to have better homes. Our plan will bring the local community together and enhance its integration, keeping the Welsh language alive, rather than causing its demise due to the influx of non-Welsh speaking people.
SP9 Infrastructure
This centre could be both refurbished, retrofitted and managed to meet the felt needs of our local demographic and include features such as water harvesting, solar panels and ev points.
SP11 The Visitor Economy
With careful planning, the site could also be made to meet the requirements of local tourism and education. It is very close to an area of outstanding natural beauty and cloud oak forests which are full of rare and exotic wildlife.
SP12 Placemaking and Sustainable Places
Our proposal would fully comply with the placemaking charter (http://dcfw.org/placemaking/placemaking-charter/) and we would endeavour to provide spaces to promote prosperity, health, happiness, and well-being in the widest sense. Furthermore we would endeavour to ensure the site was both sustainably managed (possibly with help from INCC) and built to enhance and improve the local biodiversity, with all the benefits this would bring.
More on the importance of placemaking in this area can be found at https://thunderbolt.me.uk/Docs/DrStudley-Objection-Rev3.pdf (part b) which were submitted under the aegis of PA E/38266, but applies equally to the RLDP
SP13 Rural Development
Again, this site absolutely fulfils the requirements of this section of the RLDP. It actively improves and enhances the available facilities accessible to the local Community, while adding and improving local facilities for all.
SP14 Maintaining and Enhancing the Natural Environment
Habitat conservation is at the heart of what our proposal will include, unlike the questionable development currently proposed, which has habitat destruction at its heart. Efforts will be made to improving the landscape and biodiversity naturally, by using cattle to lightly graze the Rhos pasture, establishing ponds and encouraging natural regeneration. These are just some of the many ways our proposal would fully meet this requirement of the RLDP.
SP15 Protection and Enhancement of the Built and Historic Environment
The current proposal to simply destroy the existing iconic building on this site is not tenable on the basis of history, heritage, place attachment and carbon cost.
Any required works (such as refurbishment and retrofitting) would be carried out sympathetically and in an environmentally sensitive way.
SP16 Climate Change
Again, our proposal fully meets these requirements by using sustainable methods and by protecting valuable natural assets. There would be no need to destroy vast areas of natural land, as would be the case if a housing development was allowed. The refurbishment and retrofitting of the old hospital building as a well-being centre will have a carbon cost of ca 120 T C and will have minimal impact on carbon stocks, carbon emissions and carbon sequestration rates. Carbon stocks on the remaining area (ca 0.7663 ha) will be approximately 85 T C with an annual sequestration rate of 0.38 T C (NERR094)
SP17 Transport and Accessibility
This site already has transport links that can be used to reach it from all over Carmarthenshire. The site is close to the Amman valley cycleway and if the Swansea 9 Lines project comes to fruition train visitors would be a possibility. Our plans would include access to Electric vehicle charging points, to encourage sustainable travel to the site.
SP18 Mineral Resources
Our proposal would actively promote improvements to the environment encouraging carbon sequestration and improving the local landscape to the benefit of the environment.
SP19 Waste Management
We will be investing in solar and wind power installations to make the site self sufficient for its energy and thus reducing reliance in carbon generation.

References
Berners-Lee, M. ‘What’s the Carbon Footprint of .....Building a House’. The Guardian, 2010, Environment - Green Living Blog.
Drexler, S, A Gensior, and A Don. ‘Carbon Sequestration in Hedgerow Biomass and Soil in the Temperate Climate Zone’. Regional Environmental Change 21, no. article number 74 (2021): 157-.
Hurst, W. (2021) Derby Assembly Rooms’ carbon cost of demolishing laid bare, Architects Journal, 22 June 2021
NERR094. ‘Carbon Storage and Sequestration by Habitat: A Review of the Evidence (Second Edition)’. Natural England, 2021.
O’Hegarty, R. (2021) The embodied carbon of buildings, Share Your Green Design