9. Strategaeth Newydd

Change to the Plan

1. Introduction
1.1. Pegasus Group is instructed by the Co-operative Group (the ‘Co-op’) to submit
representations to the Carmarthenshire Second Deposit Revised LDP consultation.
1.2. The Co-op own a Site referred to as ‘Land south of Penygroes Road, Gorslas’ (the ‘Site') and
are promoting the Site for residential development. A copy of the Site Location Plan is
enclosed with a copy of these representations (Appendix 1) and the extent of the land is
shown below:
1.3. The Site comprises an area of c. 6.5ha and is considered to be capable of accommodating
approximately 120 dwellings.1
1.4. A call for sites form was submitted to the Council in August 2019 by Pegasus Group on behalf
of the Co-op. A copy of this submission is also appended to these representations
(Appendix 2).
1.5. Representations were submitted to the Deposit LDP in March 2020 and these are
resubmitted here and amended as necessary. The Site has not been included as a candidate
site in the Second Deposit Revised LDP and we consider that it should be included as a
residential allocation for the reasons given in these representations.
1 Assuming 30dph on 60% of the site.
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Executive Summary
1.6. These representations respond directly to the following policies and paragraph references,
as set out in the Second Deposit Revised LDP:
 Preferred Spatial Option (Chapter 8);
 Paragraph 8.20;
 A New Strategy (Chapter 9);
 Policy SP1: Strategic Growth;
 Policy SP3: Sustainable Distribution – Settlement Framework;
 Policy SP4 – A sustainable Approach to Providing New Homes; and
 Policy SD1: Sustainable Distribution - Development Limits.
1.7. Our comments on the above policies would support a higher quantum of growth to the Tier
1 settlements in the interests of making the plan more effective in delivering its key aims and
more appropriate in terms of delivering sustainable development and mitigating its impact
on climate change.
1.8. This will, in turn, require the identification of additional sites for housing at these settlements
and we consider that the Site should be allocated for residential development as part of this
process, based on the updated sustainability appraisal we have undertaken using the
Integrated Sustainability Appraisal (ISA) template provided for developers. This
demonstrates that the Site is a sustainable, deliverable and logical location for housing.
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2. Preferred Spatial Option (Chapter 8)
2.1. Paragraph 8.20 sets out the preferred Spatial Option and is unchanged from the Deposit
Draft LDP. The Option is stated as being a hybrid of a Balanced Community and Sustainable
Growth Strategy. The Spatial Option acknowledges the need to recognise and reflect
investment/economic benefits and opportunities, seeks to be community led, and will aim to
allocate development in a sustainable way.
2.2. Whilst we are broadly supportive of the preferred Spatial Option, we feel that it needs to be
more explicit in stating that the strategy needs to align with the ambitious economic
aspirations of the plan.
2.3. At present, we do not feel that this is reflected in the proposed Spatial Option and, therefore,
it has not been fully justified in the context of the Council's economic growth ambitions.
2.4. We would stress that this does not require wholesale changes to the proposed Spatial Option
as this could still be community led and the delivery of sustainable development should be
at the heart of all Plan strategies. However, we would wish to see it reflect the Council's
ambitious economic growth aspirations and acknowledge that this will influence the spatial
distribution of development.
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3. A New Strategy (Chapter 9)
3.1. We are broadly supportive of the Plan's ambitions to deliver economic growth and an uplifted
housing requirement to support this. However, the perceived reduced importance of
delivering the Council's ambitious economic growth targets within the Preferred Spatial
Option has manifested in what we consider to be an ineffective Plan Strategy.
3.2. This is because the Second Deposit Revised LDP seeks to take a balanced approach to the
distribution of housing supply (paragraph 9.4), despite the fact that it will be reliant on only
a few key centres to deliver the vast majority of the economic growth it aspires to (namely,
Llanelli, Ammanford/Cross Hands and Carmarthen).
3.3. We accept that growth will need to come forward at all levels of the settlement hierarchy
(including rural areas) to support the vitality and viability of the diverse communities across
the county. However, the Plan's focus on delivering economic growth and a balanced
approach to the distribution of development are unlikely to be an effective combination in
meeting the plan's aspirations.
3.4. The plan acknowledges that the Tier 1 settlements are the strongest economic drivers from
a market demand and delivery perspective and states that they will receive an "appropriate
proportion" of the anticipated growth. However, this should be quantified within the plan
(which it is not at present) alongside the level of housing and other types of development
needed to be delivered in conjunction with it.
3.5. The Plan Strategy needs to be more realistic in acknowledging that it cannot rely on lower
order settlements and rural areas to deliver the economic growth it aspires to and that the
Tier 1 settlements will likely need to play a greater role than is currently identified.
3.6. It also needs to acknowledge that employment sites will only come forward where they have
access to good services, facilities and infrastructure. Furthermore, they will also need to be
accessible for the local/regional labour market.
3.7. It is, therefore, essential that the Plan identifies the supporting development and
infrastructure that needs to be delivered alongside employment sites in order to stimulate
investment and economic growth. The plan currently fails to do this, and this has resulted in
deficient policies which are discussed further below.
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4. Policy SP1: Strategic Growth and Policy SP4: A
Sustainable Approach to Providing New Homes
4.1. As stated above, we support the Council's decision to deliver a higher quantum of dwellings
over the plan period to align with the Council's economic growth ambitions. We support the
proposed 10% flexibility applied to the housing requirement as this will provide a reasonable
(albeit not optimal) level of flexibility to improve the prospects of meeting the minimum
housing requirement.
4.2. However, we question why this has been reduced from the 15% flexibility applied in the First
Deposit Revised LDP. This is particularly important in the context where one of the reserve
sites under Policy SG2 has been removed.
4.3. In addition, we are not convinced the distribution of housing has been properly justified in
the context of the ambition to deliver higher levels of economic growth. Our principal concern
is that the ambitions to deliver economic growth will be jeopardised by the balanced
approach to distributing growth across the county.
4.4. This has, in turn, resulted in a distribution pattern that does not appear to appreciate the
importance of the spatial relationship between employment growth and housing delivery as
they support the delivery of one another.
4.5. In simple terms, the distribution strategy does not take a realistic view of the capacity of
lower order settlements to deliver economic growth, relative to the Tier 1 settlements and
has, accordingly, failed to allocate a sufficient level of housing in close proximity to key
employment areas.
4.6. It is important for housing to be delivered in close proximity to key employment areas for a
number of reasons. Two particularly pertinent reasons are as follows:
1. It encourages commuting via alternative modes of transport to the private motor
vehicle in the interests of sustainability and mitigating impacts on climate change;
2. Housing delivery creates a critical mass and local workforce which stimulates
investment and job creation.
4.7. Policies SP1 and SP4 (including their supporting text) need to clearly justify the overall
quantum of development to be delivered at each settlement tier and then explain how it will
be distributed to support the economic aspirations of the plan, alongside its sustainability
and community aspirations. Its failure to do so at present is a significant deficiency with the
plan that needs to be addressed.
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5. Strategic Policy SP3: Sustainable Distribution –
Settlement Framework
5.1. Policy SP3 sets out the settlement hierarchy and settlement clusters. We largely agree with
the structure and support the Ammanford/Cross Hands area being included within the first
tier – Principal Settlements.
5.2. We also agree with the assertion that growth and development will be directed to sustainable
locations in accordance with the spatial framework; however, as mentioned above, we have
some reservations with how this has been implemented.
5.3. Whilst we note that the highest proportion of development is due to be delivered at the Tier
1 settlements (a principle we support), we consider that too great a proportion of growth has
been allocated to lower order settlements. As stated above, the Plan is unrealistic in the way
it proposes to distribute growth to deliver its economic aspirations and the allocation of
housing sites to support this is also unsuitable as a result.
5.4. If the Plan is serious about delivering economic growth, sustainable development and
mitigating its impacts on the environment to combat climate change, then it needs to rethink
its distribution framework and allocate higher levels of development to the Tier 1
settlements.
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6. Policy SD1: Development Limits
6.1. This policy states that development within the identified development of Tier 1-3 settlements
will be acceptable, provided that they accord with other relevant policies of the LDP.
6.2. Whilst there are exceptions to this rule (for example, Policy HOM6), the policy does not set
out a scenario whereby development for traditional housing can come forward beyond the
development limits. This will be problematic in circumstances where the Council's housing
delivery fails to keep pace with their proposed annual requirement.
6.3. Whilst we support the principle of identifying specific sites to meet the development needs
of the district within the LDP to guard against excessive unplanned development, Local Plans
still need to be sufficiently flexible to ensure that housing and other types of development
can come forward to meet the needs of the population. This is especially important in
situations when delivery does not match up with the plan's target levels of growth. This could
be due to any number of reasons, from deficiencies with the plan, unforeseen technical issues
affecting the delivery of certain sites or broader macro-economic factors.
6.4. We note the identification of Reserve Sites (Policy SG2) and acknowledge that this will go
some way to securing supply in the event allocated sites cannot come forward albeit one of
the reserve sites has been removed from the Second Deposit Revised LDP over the Revised
Deposit version. However, we would question whether this is a sufficiently flexible approach
that will help to guarantee the delivery of the plan's housing requirement. We note that the
delivery of a reserve site will need to be subject to a masterplanning exercise. This
requirement is something that would potentially delay its delivery and prevent it from
addressing a specific need (e.g. housing shortfall) in a timely manner.
6.5. As such, we consider that this policy should incorporate wording to allow for development in
sustainable locations that would otherwise comply with the relevant policies of the LDP in
the event that the supply and delivery of housing failed to keep pace with the Local Plan
Housing Requirement (i.e. the absence of a five-year supply of housing land).
6.6. We would suggest additional wording to the policy to make it clear to prospective applicants
when it would be acceptable to propose development on unallocated sites. This would
provide certainty and allow for windfall sites to come forward in accordance with the LDP to
meet shortfalls when they arise.
6.7. We acknowledge that the plan has attempted to plan positively for housing growth in
particular and sought to incorporate measures to secure this (10% buffer to the housing
requirement (albeit reduced from 15%) and the identification of reserve sites) over the plan
period. However, we consider that policy SD1 should incorporate additional flexibility to allow
development to come forward under certain circumstances (as specified above) in order the
ensure the plan can remain as effective as possible for its duration.
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7. Land to the south of Penygroes Road, Gorslas,
Llanelli
7.1. As stated in the Introduction, the Co-op controls an area of land to the south of Penygroes
Road, Gorslas comprising a number of fields which cover an area of around 6.5ha and would
be capable of delivering c. 120 dwellings.
7.2. Vehicular access could be taken from the B4556 to the east with an emergency/pedestrian
access being taken from the north via an existing driveway/access.
7.3. The Site is well related to development around the 6-way junction along the A476 which is
home to a number of services and facilities that would meet the day to day needs of future
residents.
7.4. The Site is also well related to existing and future large-scale employment and commercial
development areas at Cross Hands.
7.5. The Site's proximity to these services, facilities and employment opportunities would reduce
the reliance on the private motor vehicle to meet the day to day needs of future residents
and would encourage the use of active modes of travel such as walking and cycling.
7.6. The Site is free from any land use allocation or other designations that would otherwise
constrain development; it could be made available for development in the short-term and
be built out comfortably within a five-year time frame once detailed planning permission is
granted.
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8. Integrated Sustainability Appraisal
8.1. Our representations to the Deposit LDP in March 2020 included an assessment of the
sustainability of the Site with regard to the guidance available at that time. Since then, the
Council has published an Integrated Sustainability Appraisal (ISA) document for consultation
alongside the Second Deposit LDP.
8.2. Paragraph 1.7 of the ISA states that:
“The Council strongly advises that in responding to the Deposit rLDP, any relevant new,
site(s) proposed should be accompanied by an integrated Sustainability Appraisal
(incorporating Strategic Environmental Assessment). A site not subject to ISA is unlikely
to be considered suitable for allocation in the plan.”
8.3. As a result, we have provided an assessment of the sustainability of the Site against this
updated criteria in the below table.
8.4. As shown by our responses, the Site performs extremely well against the various elements of
the SA with only the fact that the Site is a greenfield site and may contain high carbon soils
being the only constraints affecting the Site's development.
9. Summary Representations
9.1. These representations have been submitted on behalf of the Co-op in respect of its land to
the south of Penygroes Road, Gorslas. The Co-op is promoting the Site for residential
development and consider it to be a sustainably located, deliverable and logical site for the
proposed use. The Co-op has a good track record of promoting sites for development and
working with developers and house builders to ensure that sites are sold on and deliverable.
It does not sit on sites or ‘land bank.’
9.2. Whilst we are broadly supportive of the economic aspirations of the LDP and agree with the
uplift to the housing requirement accordingly, we have reservations with the proposed
strategy to deliver this ambitions targets.
9.3. This is namely down to the following reasons:
 The Preferred Spatial Option and Plan Strategy appear to have diminished the
importance of delivering these said economic aspirations;
 They are unrealistic in their view that lower order settlements will be able to deliver the
currently proposed economic growth and role Tier 1 settlements will need to play has
been underestimated;
 There is a disconnect with the spatial distribution of employment development and
residential development and it is not clear how they will support the delivery of one
another; and
 The proposed flexibility measures notwithstanding, we consider that the plan should
include a policy to facilitate development beyond the defined settlement limits in the
case of severe plan failure.
9.4. We suspect that when the plan is reviewed in light of these issues, a higher proportion of
growth will be identified at the Tier 1 settlements and this will require additional housing
allocations to be included.
9.5. Our client's Site is available, deliverable and sustainably located. We have assessed it against
the Council's ISA template and it has performed very well with few minor issues. We would,
therefore, support a new policy allocating the Site for residential development in the final
version of the LDP.

Dylai’r cyngor gyd-gynhyrchu Asesiad Cymunedol rheolaidd ym mhob ardal o'r sir gyda chymunedau fel partneriaid cyfartal.
___
The council should co-produce a regular Community Assessment in all areas of the county with communities as equal partners.

Ymateb Rhanbarth Caerfyrddin Cymdeithas yr Iaith i ymgynghoriad ar Gynllun Datblygu Lleol Diwygiedig Adneuo Sir Gaerfyrddin 2018-2033
Sylwadau cychwynnol

Cydnabyddwn fod amcanion y Cynllun Datblygu Lleol Diwygiedig yn uchelgeisiol a bod dyhead y Cyngor Sir i hwyluso creu swyddi o ansawdd uchel yn un clodwiw.
Wedi dweud hynny a wedi dadansoddi’r dogfennau perthnasol, rhaid i ni fynegi pryderon difrifol am effaith y cynllun ar y Gymraeg a rhai o gymunedau ac ardaloedd
Cymreiciaf Sir Gâr.

Credwn nad yw elfennau allweddol o’r cynllun diwygiedig yn seiliedig ar dystiolaeth gadarn, a bod tipyn o waith i’w wneud i sicrhau dyfodol hyfyw i’r Gymraeg cyn i’r
Cyngor gyflwyno’r Cynllun Adneuo i’r Llywodraeth. Nid oes unrhyw ddadansoddiad o sut y gall creu nifer sylweddol o swyddi mewn un gornel o’r sir gyflawni’r nod o atal yr
allfudiad difrifol o bobl ifainc o’n cymunedau ledled y sir. Camgymeriad sylfaenol yw fod y Cynllun yn trin adfywiad economaidd ac adfywiad iaith a chymunedol fel dau
beth ar wahân yn lle ystyriaeth fanwl o ba fath ar ddatblygu economaidd a fydd o fudd pennaf i’r iaith ac i’n cymunedau.

Er bod "gwarchod, gwella a hyrwyddo'r Gymraeg a hunaniaeth ddiwylliannol" yn un o Amcanion Strategol y Cynllun dydy cynnwys y Cynllun ei hun ddim yn adlewyrchu
hynny.

Ymhellach, mae Strategaeth Hybu’r Gymraeg y Cyngor yn cynnwys y nod o wneud y Gymraeg yn brif iaith y sir. Dydy’r Cynllun Datblygu Lleol ddim yn cyfeirio at hynny o
gwbl, ac yn gweithio yn erbyn hynny.

Anghenion tai ac amcanestyniadau poblogaeth

Fel gyda’r yr ail Gynllun gwrieddiol, mae’n anodd peidio â dod i’r casgliad i’r Cyngor Sir ofyn faint o dai fyddai eu hangen er mwyn cyflawni amcanion ei strategaeth
adfywio gan fod nifer y tai wedi ei seilio ar Adroddiad Tai a Thwf Economaidd (Twf Poblogaeth) Turley.

Mae’r cynllun yn cydnabod y bu dirywiad sylweddol yn nifer y siaradwyr Cymraeg dros y degawdau diwethaf, felly rhaid gofyn pam bod yr ail Gynllun Datblygu Lleol wedi ei seilio ar amcanestyniad deng mlynedd yn Adroddiad Tai a Thwf Economaidd (Twf Poblogaeth) Turley.
Roedd y Cynllun Datblygu Lleol cyntaf wedi ei seilio ar amcanestyniad poblogaeth hefyd, ac yn cynllunio ar gyfer twf.

Mae’r Cynllun Adneuo’n disgwyl twf o 14,468 ym mhoblogaeth y Sir a bod angen 8,822 o dai er mwyn cyflawni amcan o greu 4,140 o swyddi.

Anghytunwn gyda'r Opsiwn a Ffefrir, sef Strategaeth Twf Cynaliadwy a Chymuned Gytbwys felly.

Bydd canolbwyntio'r twf mewn dwy ardal yn nwyrain y sir, Llain Arfordirol Llanelli ac ardal Rhydaman / Cross Hands, yn annog mewnlifiad trwy greu pentrefi cymudwyr.

Mae'r Adroddiad ar yr Ymgynghoriad Cychwynnol yn nodi, mewn ymateb i sylwadau Cymdeithas yr Iaith i bryderon am seilio Cynllun Datblygu Lleol ar gynllun economaidd:

"Further evidence will be produced to inform the economic needs of the County and its impacts upon the County's housing needs."

Mae sylwadau Llywodraeth Cymru i’r ymgynghoriad gwreiddiol hefyd yn nodi:
“Further evidence and explanation is required to explain how and where the level of job growth will be delivered, including both strategic and non strategic allocations. It
is unclear what the level of employment provision is and for what sector and how this translates into a land requirement for employment uses. The current employment evidence base is inconsistent and unclear.

“The authority must fully justify/evidence that the growth levels are directed to the most sustainable places, related to the scale and location of housing need, not impacting negatively on the Welsh language and is realistic and deliverable.”

Does dim cyfeiriad yn y dogfennau diweddaraf at dystiolaeth bellach o effaith nac anghenion yn sgil datblygiadau economaidd.

Dylai’r cyngor gyd-gynhyrchu Asesiad Cymunedol rheolaidd ym mhob ardal o'r sir gyda chymunedau fel partneriaid cyfartal.

Y Gymraeg
Er bod “Asesiad Effaith ar yr Iaith Gymraeg, Rhagfyr 2019” bellach wedi ei gyhoeddi ymddengys nad yw Asesiad o Effaith CDLl diwygiedig Adneuo Drafft Sir Gaerfyrddin
ar y Gymraeg, 2023, ar gael.
Dyma fyddai’r dystiolaeth fwyaf perthnasol o ran y Gymraeg.

Polisi, Y Gymraeg a Diwylliant Cymru

Mae geiriad polisi SP8 yn achos pryder:

“Ni fydd cynigion datblygu sy'n cael effaith anfanteisiol ar fywiogrwydd a hyfywedd y Gymraeg a diwylliant Cymru'n cael eu caniatáu oni bai y gellir lliniaru'r effaith.”

Trwy fynnu mesurau lliniaru mae cydnabod bod effaith negyddol i’r Gymraeg, ac yn unol â’u diffiniad, nid atal effaith negyddol fydd unrhyw fesurau lliniaru ond lleihau’r effaith hynny.

Mae Cymdeithas yr Iaith yn croesawu penderfyniad y Cyngor Sir i ddynodi’r sir gyfan yn ardal yn ieithyddol sensitif eto ond mae angen i’r Cynllun adlewyrchu mor fregus yw’r cymunedau hynny, trwy seilio’r Cynllun ar angen am dai.

Tra yn cytuno ag amcan cymal 11.174 i greu swyddi a chyfleoedd er mwyn galluogi pobl i aros yn y sir anghytunwn bod y twf sy'n cael ei gynllunio yn "gynaliadwy" ac y bydd y Cynllun yn "cynyddu i'r eithaf y cyfleoedd i siaradwyr di-Gymraeg sy'n symud i mewn i'r Sir gael eu hintegreiddio i fywyd cymunedol ar raddfa a chyflymder na fydd yn tanseilio bywiogrwydd a hyfywedd y Gymraeg a diwylliant Cymru.”

Pryderwn bod cymal 11.176 yn nodi y bydd:

“ceisio sicrhau bod datblygu'n mynd rhagddo ar raddfa y gellir ei derbyn a'i chymhathu heb niweidio cymeriad y gymuned.”

Mae “ceisio sicrhau” yn groes i’r egwyddor yng nghymal 11.174 y bydd integreiddio ar raddfa gynaliadwy.

WL1: Y Gymraeg a Datblygiadau Newydd

Mae'n galonogol bod y polisi ei hun yn glir mai bwriad y Cynllun Gweithredu Iaith Gymraeg fyddai nodi mesurau "i ddiogelu, hyrwyddo a gwella'r Gymraeg", ond mae
cymal 11.179 yn cyfeirio at “fesurau lliniaru” Cynllun Gweithredu, sy’n awgrym mai mesurau lliniaru sydd mewn golwg mewn gwirionedd.

Yn ogystal, nodwn eto bod Strategaeth Hybu’r Gymraeg y cyngor yn gosod nod o wneud y Gymraeg yn brif iaith y sir, ac nad yw polisi WL1 yn cyd-fynd â hynny.

Mae’n galonogol hefyd bod y polisi yn rhoi disgwyliadau bod Cynllun Gweithredu Iaith Gymraeg yn dangos bod y datblygiad yn cyfrannu’n gadarnhaol i grwpiau iaith
Gymraeg yn yr ardal.

Dydy hi ddim yn glir beth fyddai'n cael ei ystyried yn ddatblygiad ar "raddfa fawr" ac a fyddai'n gymwys i baratoi Asesiad o'r Effaith ar y Gymraeg.

Credwn bod angen ffigyrau penodol yn yr achos yma, a nodi canran ychwanegol o dai yn achos datblygiad tai neu ganran o weithwyr a phoblogaeth yn achos datblygiadau cyflogaeth.

Nid oes unrhyw sôn o gwbl am y Gymraeg yn y Profion Cadernid. Os mai nod y Cynllun yw “'hyrwyddo'r Gymraeg a'i diwylliant” oni ddylai hynny fod yn rhan o
Brofion Cadernid?

Crynodeb

Mae Cymdeithas yr Iaith yn rhannu’r farn gyffredin i’r Cynllun Datblygu Lleol presennol fod yn fethiant, ac roeddem yn gobeithio y byddai’r Cyngor achub ar y
cyfle pellach hwn i lunio cynllun diwygiedig a fyddai’n newid cyfeiriad trwy flaenoriaethu lles cymunedau ledled y Sir a rhoi lle canolog i’r Gymraeg.

Siomedig felly yw gweld strategaeth gorfforaethol sydd yn canolbwyntio ar gyflawni ychydig o ddatblygiadau yn ne a dwyrain y Sir yn hytrach na rhaglen arloesol o hyrwyddo datblygiadau a chyfleoedd cyflogaeth ar raddfa llai ledled Sir Gaerfyrddin.

Teimlwn yn gryf fod diffyg tystiolaeth o ran y dyraniadau tai a safleoedd cyflogaeth. Nid yw gobaith ac uchelgais yr un peth â thystiolaeth.
Croesawn rai o’r camau y mae’r Cyngor am eu gwneud i liniaru ac asesu effaith datblygiadau ar yr iaith ond mae cryn dipyn o waith i’w wneud o hyd, a’r pryder yw y
caiff buddiannau cymunedau Cymraeg eu gosod yn ail i amcanion strategaeth adfywio’r Cyngor Sir, strategaeth sydd yn ei hanfod yn edrych yn hen ffasiwn erbyn
hyn.

Rhanbarth Caerfyrddin, Cymdeithas yr Iaith Ebrill 2023

Cymdeithas yr Iaith - Carmarthen Region's response to consultation on Carmarthenshire’s Deposit Revised Local Development Plan 2018 - 2033

Initial comments

We recognise that the objectives of the Revised Local Development Plan (LDP) are ambitious and that the County Council's aspiration to facilitate high quality job creation is commendable.
Having said that and having analysed the relevant documents, we must raise serious concerns about the impact of the scheme on the Welsh language and some of Carmarthenshire’s communities and areas where the Welsh language is at its strongest.

We believe that key elements of the revised plan are not based on hard evidence, and that there is a long way to go to ensure a viable future for the Welsh language before the Council submits the Deposit Scheme to the Government. There is no analysis of how creating a significant number of jobs in one corner of the county can achieve the goal of preventing the severe exodus of young people from our communities across the county. A fundamental mistake is that the Plan treats economic regeneration and language and community regeneration as two separate things instead of giving detailed consideration into what kind of economic development will best benefit the language and our communities.

Although "protecting, enhancing and promoting the Welsh language and cultural identity" is one of the Strategic Objectives of the Plan, the content of the Plan itself does not reflect that.

Furthermore, the Council's Welsh Language Promotion Strategy includes the aim of making Welsh the main language of the county. The LDP does not refer to that at all and works against it.

Housing needs and population projections

As with the second original Plan, it is difficult not to conclude that the County Council asked how much housing would be needed to achieve the objectives of its regeneration strategy, as the number of houses is based on Turley's Housing and Economic Growth (Population Growth) Report.

The plan recognises that there has been a significant decline in the number of Welsh speakers in recent decades, therefore one must ask why the second LDP is based on a ten-year projection in Turley's Housing and Economic Growth (Population Growth) Report.
The first LDP was also based on a population projection, and it planned for growth.

The Deposit Plan expects a growth of 14,468 in the County's population and that 8,822 houses are needed to achieve an objective of creating 4,140 jobs.

We disagree with the Preferred Option, which is a Balanced Community and Sustainable Growth Strategy.

Focusing growth in two areas in the east of the county, the Llanelli Coastal Belt and the Ammanford / Cross Hands area, will encourage an influx through the creation of commuter villages.

The Report on the Initial Consultation states, in response to Cymdeithas yr Iaith's comments regarding concerns about basing a Local Development Plan on an economic plan:

"Further evidence will be produced to inform the economic needs of the County and its impacts upon the County's housing needs."

The Welsh Government's comments regarding the original consultation also state:

"Further evidence and explanation is required to explain how and where the level of job growth will be delivered, including both strategic and non strategic allocations. It is unclear what the level of employment provision is and for what sector and how this
translates into a land requirement for employment uses. The current employment evidence base is inconsistent and unclear.

"The authority must fully justify/evidence that the growth levels are directed to the most sustainable places, related to the scale and location of housing need, not impacting negatively on the Welsh language and is realistic and deliverable."

There is no reference in the latest documents to further evidence of impact nor to needs arising from economic developments.

The council should co-produce a regular Community Assessment in all areas of the county with communities as equal partners.

The Welsh Language

Although a "Welsh Language Impact Assessment, December 2019" has now been published it appears that Carmarthenshire's Draft Deposit Revised LDP - Welsh Language Impact Assessment, 2023, is not available.
This would be the most relevant evidence regarding the Welsh language.

Policy, Welsh Language and Culture

The wording of policy SP8 is a cause for concern:

"Development proposals which have a detrimental impact on the vitality and viability of the Welsh language and culture will not be permitted unless the impact can be mitigated."

By requiring mitigation measures it is recognised that there is a negative impact on the Welsh language, and according to their definition, any mitigation measures will not prevent a negative impact but rather minimise that impact.

Cymdeithas yr Iaith welcomes the County Council's decision to designate the whole county as a linguistically sensitive area again but the Plan needs to reflect the vulnerability of those communities, by basing the Plan on housing need.

Whilst agreeing with the objective of clause 11.174 to create jobs and opportunities to enable people to stay in the county, we disagree that the growth being planned is "sustainable" and that the Plan will "maximise opportunities for non-Welsh speakers who move to the County to be integrated into community life at a scale and pace that will not undermine the vitality and viability of the Welsh language and culture."
We are concerned that clause 11.176 states that:
"…will seek to ensure that development occurs at a rate which can be absorbed and assimilated without damaging the character of the community."

"Seeking to ensure" is contrary to the principle in clause 11.174 that integration will be on a sustainable scale.

WL1: Welsh Language and New Developments

It is encouraging that the policy itself is clear that the intention of the Welsh Language Action Plan would be to set out measures "to safeguard, promote and enhance the Welsh language", but clause 11.179 refers to the Action Plan’s "mitigation measures", which suggests that it is mitigation measures that are actually in mind.

In addition, we again note that the council's Welsh Language Promotion Strategy sets a goal of making Welsh the primary language of the county, which does not accord with policy WL1.

It is also encouraging that the policy sets expectations for the Welsh Language Action Plan to show that the development contributes positively to Welsh language groups in the area.

It is unclear what would be considered a "large-scale" development and whether it would qualify to prepare a Welsh Language Impact Assessment.

We believe that specific figures are needed in this case, and that an additional percentage of housing is identified in the case of a housing development or a percentage of employees and population in the case of employment developments.

There is absolutely no mention of Welsh in the Tests of Soundness. If the aim of the Plan is to "promote the Welsh language and its culture" shouldn't that be part of Tests of Soundness?

Summary

Cymdeithas yr Iaith shares the common view that the current LDP has been a failure, and we hoped that the Council would take this further opportunity to produce a revised plan that would change direction by prioritising the wellbeing of communities across the County and placing the Welsh language at its heart.

It is therefore disappointing to see a corporate strategy that focuses on delivering a few developments in the south and east of the County rather than an innovative programme of promoting smaller-scale employment developments and opportunities across Carmarthenshire.

We strongly feel that there is a lack of evidence on housing allocations and employment sites.

Hope and ambition are not the same thing as evidence.
We welcome some of the steps the Council wants to take to mitigate and assess the impact of developments on the language but there is still a long way to go, and we are concerned that the interests of Welsh-speaking communities will be placed second to the objectives of the County Council's regeneration strategy, a strategy that essentially looks outdated now.

Cymdeithas yr Iaith, Carmarthen Region April 2023