11. Polisïau

Amend Policy

To whom it may concern

Horse riders from the county and beyond deserve better provision we are vulnerable road users and have shared existing rights of way for decades without issue why is it that now funding s available for cycling and walking a huge population of people are being left out.
Please ensure we get a fair portion of funding and rights of way available to us 1. We should ask that the LDP takes account of this need for land to include horses and carriage drivers on routes for non motorised users. This is so we dont have to transport our horses in vehicles but can access our communities on hoof.
2. Where this isnt possible, we need land for parking horse transport as if we cant ride to safe sites for riding then we need to be able to park. It is just as unsafe for children on ponies to be on the road as it is for children on cycles and the incident statitics for Carmarthenshire from BHS indicate these have doubled. Input your own local issues and say where you want to ride. Examples may be forestry, beaches and parks.
3. We are reminded that we are not "transport" but are considered a leisure activity but there is no mention in the LDP specifically about equestrian sports or sites where we can go to to ride safely. We appear in the Planning Policy technical advice for leisure activities with walking and cycling but there is provision for them embedded in other policy but not for us. The LDP needs to more robustly provide for us as a leisure activity wanting countryside access, access to parks and green space, (not a menage). This requires land allocation in order to ensure we are not discriminated against as is currently happening under the planning policies. For health and well being and future generations of equestrians, we need to recover access we have lost and gain consideration alongside other vulnerable road users. By excluding us under Active Travel as transport, we need provision as leisure users so at the very least, any leisure routes need to include equestrians. Not all routes for walking are public footpaths, so not all routes for horses need to be bridleways. If we cant share a route then an alternative should be provided for us.

No specific changes specified.

I would like to make the following comments in the LDP.

Since the creation of the Active Travel Act and the funding provided by Welsh Government for walking and (mainly) cycling, horse riders have lost informal access to our communities and the countryside because for some reason horse riders are not eligible for the funding.

I would therefore like to raise the point that the LDP should take account of this need for land to include horses and carriage drivers on routes for non motorised users.

This would ensure horse riders don’t have to transport their horses in vehicles but instead can access our communities on hoof.

Where this isn't possible, horse riders need land for parking horse transport as if they can’t ride to safe sites for riding then they need to be able to park.

It is just as unsafe for children on ponies to be on the road as it is for children on cycles and the incident statistics for Carmarthenshire from the BHS indicate these have doubled.

We are reminded that horse riders are not "transport" but are considered a leisure activity but there is no mention in the LDP specifically about equestrian sports or sites where we can go to to ride safely.

Horse riders appear in the Planning Policy technical advice for leisure activities with walking and cycling but there is provision for them embedded in other policy but not for horse riders.

The LDP needs to more robustly provide for horse riders as a leisure activity wanting countryside access, access to parks and green space, (not a menage or riding schools).

This requires land allocation in order to ensure horse riders are not discriminated against as is currently happening under the planning policies.

For health and well being and future generations of equestrians, we need to recover access we have lost and gain consideration alongside other vulnerable road users. By excluding horse riders under Active Travel as transport, they need provision as leisure users so at the very least, any leisure routes need to include equestrians.

Not all routes for walking are public footpaths, so not all routes for horses need to be bridleways. If horse riders can’t share a route then an alternative should be provided for them.

Nothing stated

> Carmarthenshire County Council are generally not supportive or sympathetic to the needs of equestrians in Carmarthenshire. The untackled problems with PROWS, the non inclusion of equestrians in new paths being created and the lack of provision for parking in the very few green spaces that allow us to ride. Two weeks ago we had two serious equestrian accidents in Trimsaran, with one horse fatality. This is on top of the already doubling in traffic incidents in Carmarthenshire last year from the previous year. Please can the Council start to take our needs seriously before we lose a rider to a car accident. Please take our concerns seriously, I know many riders who won’t buy a permit for the safe forest because of the parking issues. We need safe places to ride and safe places to park.
> Your Sincerely
> Catherine Hoyt

Reference equestrian users as referred to in the submission.

Dear All
1. Equestrians are officially classed as vulnerable road users and need provision to keep them safe which is not being adequately assessed currently. Carmarthenshire is predominantly rural and has a high horse population.


2. Equestrians are not being included as active travellers on AT routes in Carmarthenshire so they require suitable parking space so they can transport horses to safe places to ride. Currently we are restricted by height and length in many council carparks. The LDP is not addressing current or future needs of equestrians. Where safe sites exist, riders feel unsafe riding to the site and often cannot park there.



3. Risk assessments for equestrians are not adequate when planning Active Travel improvements and alternative options are not provided for them where traffic/population growth is planned. This is evident in Cross Hands where there is significant development and a high horse population. Developments could require access suitable for horses but instead offer only shared use paths.



4. Equestrians are not positively included in any policy other than the Rights of Way Improvement Plan. They have been marginalised because they do not fit into any single portfolio. Their needs span, rural affairs, tourism, transport and leisure business areas and touch on others and risk assessments are not realistic if they are included at all.



5. The highway hierarchy to prioritise resources is discriminatory because although it places bridleways as a priority, there are very few of them; these do not connect and vehicular routes like unsurfaced highways, and byways provide essential parts of an equestrian network which are “no priority” under the hierarchy. This essentially makes it impossible to get to the bridleways on horseback because they are not kept open or maintained.



6. The LDP makes considerable reference to walking and cycling with projects and funding and policies referring to Active Travel and The Well Being and Future Generations Act. The LDP needs to allocate space and facilities for the same movement of equestrians, for local riders and tourists, where there is a significant interest in travelling a trail by tourists and access to local beaches, forests and parks. Removing all legal issues and opening all of the 165km kms of bridleway in the county will not provide sufficient access for the 22,000 horses residing here or the visitors that come on horseback because the routes are fragmented. This is a tourism opportunity that is not being realised and that could improve the local economy.



7. Many horse riders and carriage drivers are older people who have disabilities due to age. They are predominantly female and using a horse is a sustainable method of transport to access the country side for health and well being. Many would not be able to access the countryside otherwise, due to heath limitations but the lack of facilities for them in a rural county needs addressing.



8. Pembrey- There are specific issues relating to inadequate parking for horse transport to access the beach, other rights of way, and the forestry for permit holders. Equestrians are also refused access to the Pembrey Park and Millennium Coast Park despite significant land available and development for others that could incorporate horse use. There should be provision for all residents on the peninsular and this is very popular place for horses given the all weather sandy surfaces and numerous byways and other access opportunities.



9. Gwendraeth Railway- proposals to develop this line for walking and cycling do not include horse use despite historic use of the old railway corridor and other railway corridors that have already been made active travel routes and equestrians excluded. The excuses for lack of inclusion name the cost and inability to obtain the land required to make these routes wide enough. This needs addressing by policy as bridleways are the original Active Travel routes open to all non motorised users and are 3m wide. Cyclists were granted access to bridleways in 1968 so there should be no objection to horses sharing cycle paths.



10.Tywi Valley Path- This is being developed as a leisure route and has attracted leisure funding but horse riders re not being included on it. If the Authority is insisting that horse riders are predominantly leisure users and do not fall under Active Travel funding then any leisure funding should incorporate equestrian access in order to satisfy the improvement of equestrian access. The ROWIP contains reference to the lack of equestrian access in the county . but the Authority is not making reference to postitive steps in the LDP to do anything to retain past/present access had by horses and is more importantly not creating safe access for the future either on or off road. This means current and future needs of horse riders are not being met under the Well Being and Future Generations Act. Parents are not willing to risk the lives of their children by teaching them to ride on the road and this is affecting the numbers of children being able to ride at a young age.



11.Equestrians should be included in all road schemes under Government road safety legislation but the new link road built at Cross Hands has done nothing to improve the safety of equestrians accessing Llyn Lech Owain- where parking for horses has been denied- or Mynydd Mawr Woodland Park. Access is denied to a roadside cycle path and the grass path apparently provided is substantially inadequate and unusable.


12.As horse riders are not “Transport” in TAN18 there is insufficient assessment of their needs within local communities under planning of any sort. There may not be bridleways in the locality but there are horses so the road needs to be safe for them as well as walkers and cyclists. Making a quiet lane much busier will affect the route used by horses as does crossing of busier roads. This can be achieved by allocating sufficient land to accommodate them where horses are living, where there are equestrian facilities like riding clubs and livery yards or resident horses or equestrian businesses. Safe access both on and off road to where they want to go, like beaches, forests, parks and bridleways/byways is also a necessity and making sure that provision for others is not compromising safety of horse riders.



13. Horses are mentioned as leisure users briefly in TAN 16 in association with walking and cycling in relation to access to facilities. This needs to be more robust in the LDP as walking and cycling is being addressed under active travel but horse riders are not. Much of the reason given for not sharing routes, is lack of space to accommodate. Segregation is not always the best arrangement as it encourages fast moving cycles and lack of respect. This should be thought about on a case by case basis depending on expected numbers of users.


14.TAN 16 Sport Recreation and Open Space 2009 mentions horses in the following context but the mention of horse riders and carriage drivers has little mention in the current LDP to support provision of facilities for equestrians as leisure users, raised in the ROWIP.



2.6 In order to encourage walking, cycling and horse riding and other low carbon modes of travel which can help tackle climate change, particular attention should be given to

opportunities to use disused railway corridors and canal towpaths to provide local and long distance routes and to enhance and extend linear open space corridors, including circular routes which can help reduce equestrian use of roads. This reference to horses is not robust enough to get adequate assessment or inclusion of horse riders needs for the future under Well Being and Future Generations Act.


3.42 The LDP should also consider the potential for extending and enhancing local and long distance recreational routes for walking, cycling and horse riding. This reference to horses is not robust enough to get adequate assessment or inclusion of horse riders needs for the future under Well Being and Future Generations Act.


4.12 Local planning authorities should seek to promote and provide better facilities for walkers, cyclists and horse-riders, including people from ethnic minorities, disadvantaged and disabled people. This reference to horses is not robust enough to get adequate assessment or inclusion of horse riders needs for the future under Well Being and Future Generations Act.

Mention is made under RD5 Equestrian facilities but refers to menage provision and not access to communities or greenspace, social inclusion or health and well being and leisure facilities.


15. Since the submission of the Deposit LDP, horse riders have been officially classified as vulnerable road users under the Wales Road Safety Strategy. There has also been changes made to the Highway Code and a hierarchy of users with equestrians shown as vulnerable as cyclists. There should therefore be a significant reflection of this in the LDP to assist in safegarding horseriders through planning and development to give them as much protection from danger on the roads as other vulnerable road users. ie walkers and cyclists.


16. Equestrians rely heavily in Carmarthenshire, on road links to get to bridleways, byways and unsurfaced roads. Unfortunately unsurfaced roads used for leisure are at the bottom of the “highway hierarchy” for resources meaning they have no priority for maintenance but form important links in Equestrian circular routes that link bridleways. Byways and other vehicular routes subject of a Traffic Regulation Order to prevent vehicular use, receive no maintenance for decades and become obstructed, falling between the Highways Dept and Countryside Dept for responsibility. This has a significant effect on equestrian access.



17. Active Travel routes that include cycles, using public rights of way need to be made truly multi user by being awarded bridleway or restricted byway status to preserve access for all. Any development should include access opportunities for all users, not just walkers and cyclists so links within the community are accessible to all to obtain best value for public money. If this is not feasible then alternative routes are required for horses.

18. Horse riders are not considered under TAN18 as transport for consideration in planning applications and although the planning system requires equestrians to be considered and included in risk assessments as road users, in reality, this is not effective consideration. There is insufficient inclusion of equestrians in the LDP and it doesnt go far enough to provide safe on and off road opportunities for the equestrian community or protect them when planning road schemes and active travel improvements. There are more than 22,000 registered/passported horses in the county. Nationally equestrian routes form 22% of the rights of way network but in Carmarthenshire its less than 7%. There needs to be a much more positive and active statement to provide land and development for multi user routes that include horse riders and carriage drivers.




Comments on Policy in blue below

The previous LDP referred to


5.5.13 The need to develop a plan which optimises the opportunity for the delivery of an efficient, effective, safe and integrated transport system is recognised. In this respect, the strategy aims to co-ordinate land use to:

•

Reduce the need to travel, particularly by private motor car, through promoting accessibility to public transport facilities;

•

Promote, support and enhance alternatives to the motor car, such as public transport (including park and ride facilities and encourage the adoption of travel plans), cycling, walking and opportunities for horse riding where
appropriate;



“Where appropriate” is not robust enough to provide for equestrian needs. There are no stats regarding horse numbers being used to assess where horses are or where they want to go and there is no criteria for when something is appropriate. This needs clarifying. There is data available under horse passports/microchip database held by DEFRA and BHS equestrian statistics and police statistics.




There is a need for links to bridleways and byways for horses, walkers and cyclists and to allow horses to travel safely to off road facilities so they do not need to transport horses in vehicles. Where horse parking is not provided, there should be inclusion on AT routes both off road and road side paths. The LDP does not acknowledge the needs of equestrians particularly in developing towns like the Cross Hands area where there is a high horse population even though comments are made on planning consultations.





Policy TR3 Highways in Developments - Design Considerations

The design and layout of all development proposals will, where appropriate, be required to include:

a) An integrated network of convenient and safe pedestrian and cycle routes (within and from the site) which promotes the interests of pedestrians, cyclists and public transport; Horses not included
b) Suitable provision for access by public transport;

c) Appropriate parking and where applicable, servicing space in accordance with required standards; Equestrian parking

d) Infrastructure and spaces allowing safe and easy access for those with mobility difficulties;

e) Required access standards reflective of the relevant class of road and speed restrictions including visibility splays and

design features and calming measures necessary to ensure highway safety and the ease of movement is maintained and where required enhanced;

f) Provision for Sustainable Urban Drainage Systems to allow for the disposal of surface water run off from the highway.
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 Where quiet lanes provide a circular route or a link to a bridleway or byway, alternative provision needs considering for local equestrians. This is currently not happening. There is no thought to horses accessing safer routes or horses using the roads in semi rural areas like Cross Hands.

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. Developers may be required to facilitate appropriate works as part of the granting of any permission.





Policy TR4 Cycling and Walking

Land required to facilitate the following improvements to the cycle network will be safeguarded. Proposed routes where known are shown on the proposals map. The potential opportunity for horse riding should where appropriate be

considered.

a) Towy Valley (between Llandeilo and Carmarthen); This is being built as a leisure route yet horse riders are still barred from using this off road path. We are being told that we are leisure users but are not getting any access improvements on new leisure routes either.

b) Whitland to Llanglydwen;

c) Ammanford to the Amman Valley. This is a high ly populated horse area with riding clubs and equestrian facilities. Inclusion in land allocation needs to be more robust to provide for local equestrians.
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.



This walking and cycling policy puts bridleways in the frame for an increase in walking and cycling traffic but because they are so few and there are no alternative routes for horse riders, we are being pushed off the only routes we have away from traffic without us being offered additional alternative routes.



Policy TR6 Redundant Rail Corridors
Development proposals which do not prejudice the re-use of redundant rail corridors for potential future recreational and rail development purposes will be permitted.

Strategic Objective Supported:

SO7, SO8, SO10, SO11 and SO12

This policy should be read in conjunction with other relevant policies and proposals of this LDP.

6.5.24 The Plan area has a number of former railway lines which offer considerable benefit for recreational activities including cycle routes, footpaths and bridleways. Consideration also needs to be given to the potential future re-use of rail routes when considering proposals which may impact upon the continuity and availability of the route.



Because of the lack of official bridleways, horses have used redundant rail corridors to make links in the local network. Access to horse riders is not currently happening on routes that have used informally and are now being turned into Active Travel routes. They are being referred to as recreational routes but CCC are not providing access to horses on these routes.





6.9 Recreation and Leisure
6.9.1 Open space has the potential to provide benefits to health and wellbeing and can assist in mitigating the causes and effects of climate change. Open spaces can also provide arenas for social interaction and community activities, and have a key role to play in underpinning other key strategic documents, such as the Health, Social Care and Well Being strategy. In this regard, the protection and enhancement of provision represents a key consideration for the LDP.

6.9.2 Along with open space, policy REC 1 also recognises the key role of allotments, particularly in terms of developing community cohesion and also as an acknowledgment of the future issue of food security . Whilst seeking to promote

allotments, their future management is governed by specific legislation (see PPW: Edition 4)

6.9.3 Locally distinctive evidence underpins the Plan’s policies in respect of open space. The Carmarthenshire Greenspace Study provide s an audit of provision based upon national standards and guidance (including the

C.C.W green space toolkit and the N.P.F.A. Six Acre Standard) as well as local in formation on locally significant
provision sourced from the local community and/or Authority officers. It should be noted that there may be locally significant provisions that are not formally recognised in the Greenspace Study, or on the proposals/inset

maps, that make an important contribution towards open space and therefore ‘local knowledge’ should also be

considered when determining the significance of these spaces to the local community. The study provides a spatial context in terms of accessibility to provision and provides some useful definitions of open space.

For the purposes of the LDP, open space includes: natural green space, play space and public open space, in

accordance with the guidance issued within TAN 16.

The Greenspace study project standards are the ones to which the County is working towards, with the 2.4ha per
1000 N.P.F.A standard adopted. It should however be noted that the LDP is seeking to facilitate betterment in terms of accessibility to open space, and therefore an aspirational standard of 2.8 ha per 1000 is include d within the Plan’s monitoring framework. The study also provides a spatial appreciation of where there are potential deficiencies and surpluses in provision a cross the County.

6.9.4 Clear national guidance in respect of this topic is contained within PPW: Edition 4: Tourism, sport and recreation and TAN 16

: - Sport, Recreation and Open Space. Consequently, the following matters do not require LDP policies as they are

adequately covered by the aforementioned national guidance:



•Golf courses;

•Allotments, cemeteries and church yards;

•Major sporting and recreation facilities;

•Off road recreational vehicles.


6.9.5 Additional national development management policy statements may also be found in the above guidance, including such issues as impact of floodlighting and amenity concerns. In terms of leisure and recreation, reference should also be made to SP16 which confirms the Plan’s emphasis on protecting, and wherever possible enhancing, the sustainability and vitality of the County’s recreation and leisure facilities in accordance with the settlement framework. Whilst being covered by legislation by virtue of the C.R.O.W. Act 2000, rights of way also play an integral role in enhancing health and well being and their role (alongside that of footpaths and informal connectivity corridors) should be consider ed within the context of the LDP. Assisting in improving access to Carmarthenshire’s attractive coastal areas is an important consideration for the LDP, however any development proposals should not be in conflict with Policies EP4 and EP5.



The above reference to leisure and recreation opportunities does not specifically mention equestrian needs and its inference in the policy does not suggest that equestrians are being adequately considered as “predominantly leisure users”. (this phrase is routinely used in responses by the council when we are asking for inclusion on Active Travel routes so it would be expected that equestrians would be robustly included in any leisure and recreation policy and the LDP.) Forestry, beaches and parks are important sites for lawful safe off road riding and the limited rights of way network for horses means that these sites are attracting increased equestrian traffic as riders are looking for off road places to ride that they can also park at. Parking of horse transport is required if access to these sites is on a busy A road or requiring negotiation of roundabouts, fast moving traffic or other hazards.


I have included the following items of supporting evidence.
1. Horse numbers for Wales - from the National Equine Database 2012 produced from passports registered to horse owners registered to a Carmarthenshire address.
2. BHS stats Carmarthenshire 2009- breakdown of passported horses by post code area
3. Bridleways Carms- map of registered bridleways which are not all available for use.
4. Wales bridleways copy- Countryside Council for Wales map of registered bridleways in Wales/Carmarthenshire.
5. Wales footpaths copy- comparison CCW map of registered footpaths in Wales.
6. BHS Road Safety stats- 2021/2022 for Wales showing doubling of issues.

Reference made in the LDP to equestrian users.

To whom it may concern,
Please note my response to LDP.

1. Equestrians are officially classed as vulnerable road users and need provision to keep them safe which is not being adequately assessed currently. Carmarthenshire is predominantly rural and has a high horse population.
2. Equestrians are not being included as active travellers on AT routes in Carmarthenshire so they require suitable parking space so they can transport horses to safe places to ride. Currently we are restricted by height and length in many council carparks. The LDP is not addressing current or future needs of equestrians. Where safe sites exist, riders feel unsafe riding to the site and often cannot park there.
3. Risk assessments for equestrians are not adequate when planning Active Travel improvements and alternative options are not provided for them where traffic/population growth is planned. This is evident in Cross Hands where there is significant development and a high horse population. Developments could require access suitable for horses but instead offer only shared use paths.
4. Equestrians are not positively included in any policy other than the Rights of Way Improvement Plan. They have been marginalised because they do not fit into any single portfolio. Their needs span, rural affairs, tourism, transport and leisure business areas and touch on others and risk assessments are not realistic if they are included at all.
5. The highway hierarchy to prioritise resources is discriminatory because although it places bridleways as a priority, there are very few of them; these do not connect and vehicular routes like unsurfaced highways, and byways provide essential parts of an equestrian network which are “no priority” under the hierarchy. This essentially makes it impossible to get to the bridleways on horseback because they are not kept open or maintained.
6. The LDP makes considerable reference to walking and cycling with projects and funding and policies referring to Active Travel and The Well Being and Future Generations Act. The LDP needs to allocate space and facilities for the same movement of equestrians, for local riders and tourists, where there is a significant interest in travelling a trail by tourists and access to local beaches, forests and parks. Removing all legal issues and opening all of the 165km kms of bridleway in the county will not provide sufficient access for the 22,000 horses residing here or the visitors that come on horseback because the routes are fragmented. This is a tourism opportunity that is not being realised and that could improve the local economy.
7. Many horse riders and carriage drivers are older people who have disabilities due to age. They are predominantly female and using a horse is a sustainable method of transport to access the country side for health and well being. Many would not be able to access the countryside otherwise, due to heath limitations but the lack of facilities for them in a rural county needs addressing.
8. Pembrey- There are specific issues relating to inadequate parking for horse transport to access the beach, other rights of way, and the forestry for permit holders. Equestrians are also refused access to the Pembrey Park and Millennium Coast Park despite significant land available and development for others that could incorporate horse use. There should be provision for all residents on the peninsular and this is very popular place for horses given the all weather sandy surfaces and numerous byways and other access opportunities.
9. Gwendraeth Railway- proposals to develop this line for walking and cycling do not include horse use despite historic use of the old railway corridor and other railway corridors that have already been made active travel routes and equestrians excluded. The excuses for lack of inclusion name the cost and inability to obtain the land required to make these routes wide enough. This needs addressing by policy as bridleways are the original Active Travel routes open to all non motorised users and are 3m wide. Cyclists were granted access to bridleways in 1968 so there should be no objection to horses sharing cycle paths.
10.Tywi Valley Path- This is being developed as a leisure route and has attracted leisure funding but horse riders re not being included on it. If the Authority is insisting that horse riders are predominantly leisure users and do not fall under Active Travel funding then any leisure funding should incorporate equestrian access in order to satisfy the improvement of equestrian access. The ROWIP contains reference to the lack of equestrian access in the county . but the Authority but is not making reference to postitive steps in the LDP to do anything to retain past/present access had by horses and is more importantly not creating safe access for the future either on or off road. This means current and future needs of horse riders are not being met under the Well Being and Future Generations Act. Parents are not willing to risk the lives of their children by teaching them to ride on the road and this is affecting the numbers of children being able to ride at a young age.
11.Equestrians should be included in all road schemes under Government road safety legislation but the new link road built at Cross Hands has done nothing to improve the safety of equestrians accessing Llyn Lech Owain- where parking for horses has been denied- or Mynydd Mawr Woodland Park. Access is denied to a roadside cycle path and the grass path apparently provided is substantially inadequate and unusable.
12.As horse riders are not “Transport” in TAN18 there is insufficient assessment of their needs within local communities under planning of any sort. There may not be bridleways in the locality but there are horses so the road needs to be safe for them as well as walkers and cyclists. Making a quiet lane much busier will affect the route used by horses as does crossing of busier roads. This can be achieved by allocating sufficient land to accommodate them where horses are living, where there are equestrian facilities like riding clubs and livery yards or resident horses or equestrian businesses. Safe access both on and off road to where they want to go, like beaches, forests, parks and bridleways/byways is also a necessity and making sure that provision for others is not compromising safety of horse riders.
13. Horses are mentioned as leisure users briefly in TAN 16 in association with walking and cycling in relation to access to facilities. This needs to be more robust in the LDP as walking and cycling is being addressed under active travel but horse riders are not. Much of the reason given for not sharing routes, is lack of space to accommodate. Segregation is not always the best arrangement as it encourages fast moving cycles and lack of respect. This should be thought about on a case by case basis depending on expected numbers of users.
14.TAN 16 Sport Recreation and Open Space 2009 mentions horses in the following context but the mention of horse riders and carriage drivers has little mention in the current plan to support the need for facilities for equestrians as leisure users, raised in the ROWIP.
2.6 In order to encourage walking, cycling and horse riding and other low carbon modes of travel which can help tackle climate change, particular attention should be given to
opportunities to use disused railway corridors and canal towpaths to provide local and long distance routes and to enhance and extend linear open space corridors, including circular routes which can help reduce equestrian use of roads. This reference to horses is not robust enough to get adequate assessment or inclusion of horse riders needs for the future under Well Being and Future Generations Act.
3.42 The LDP should also consider the potential for extending and enhancing local and long distance recreational routes for walking, cycling and horse riding. This reference to horses is not robust enough to get adequate assessment or inclusion of horse riders needs for the future under Well Being and Future Generations Act.
.
4.12 Local planning authorities should seek to promote and provide better facilities for walkers, cyclists and horse-riders, including people from ethnic minorities, disadvantaged and disabled people. This reference to horses is not robust enough to get adequate assessment or inclusion of horse riders needs for the future under Well Being and Future Generations Act.
Mention is made under RD5 Equestrian facilities but refers to menage provision and not access to communities or greenspace, social inclusion or health and well being and leisure facilities.
15. Since the submission of the Deposit LDP, horse riders have been officially classified as vulnerable road users under the Wales Road Safety Strategy. There has also been changes made to the Highway Code and a hierarchy of users with equestrians shown as vulnerable as cyclists. There should therefore be a significant reflection of this in the LDP to assist in safegarding horseriders through planning and development to give them as much protection from danger on the roads as other vulnerable road users. ie walkers and cyclists.
16. Equestrians rely heavily in Carmarthenshire, on road links to get to bridleways, byways and unsurfaced roads. Unfortunately unsurfaced roads used for leisure are at the bottom of the “highway hierarchy” for resources meaning they have no priority for maintenance but form important links in Equestrian circular routes that link bridleways. Byways and other vehicular routes subject of a traffic regulation order to prevent vehicular use, receive no maintenance for decades and become obstructed, falling between the Highways Dept and Countryside Dept for responsibility. This has a significant effect on equestrian access.
17. Active Travel routes that include cycles, using public rights of way need to be made truly multi user by being awarded bridleway or restricted byway status to preserve access for all. Any development should include access opportunities for all users, not just walkers and cyclists so links within the community are accessible to all to obtain best value for public money. If this is not feasible then alternative routes are required for horses.
Horse riders are not considered under TAN18 as transport for consideration in planning applications and although the planning system requires equestrians to be considered and included in risk assessments as road users, in reality, this is not effective consideration. There is insufficient inclusion of equestrians in the LDP and it doesnt go far enough to provide safe on and off road opportunities for the equestrian community or protect them when planning road schemes and active travel improvements. There are more than 22,000 registered/passported horses in the county. Nationally equestrian routes form 22% of the rights of way network but in Carmarthenshire its less than 7%. There needs to be a much more positive and active statement to provide land and development for multi user routes that include horse riders and carriage drivers.

Reference equestrian users as referred to in the submission.

Please consider my comments below to include equestrians in the LDP plan as currently they are vulnerable and excluded.

1. Equestrians are officially classed as vulnerable road users and need provision to keep them safe which is not being adequately assessed currently. Carmarthenshire is predominantly rural and has a high horse population.

2. Equestrians are not being included as active travellers on AT routes in Carmarthenshire so they require suitable parking space so they can transport horses to safe places to ride. Currently we are restricted by height and length in many council carparks. The LDP is not addressing current or future needs of equestrians. Where safe sites exist, riders feel unsafe riding to the site and often cannot park there.

3. Risk assessments for equestrians are not adequate when planning Active Travel improvements and alternative options are not provided for them where traffic/population growth is planned. This is evident in Cross Hands where there is significant development and a high horse population. Developments could require access suitable for horses but instead offer only shared use paths.

4. Equestrians are not positively included in any policy other than the Rights of Way Improvement Plan. They have been marginalised because they do not fit into any single portfolio. Their needs span, rural affairs, tourism, transport and leisure business areas and touch on others and risk assessments are not realistic if they are included at all.

5. The highway hierarchy to prioritise resources is discriminatory because although it places bridleways as a priority, there are very few of them; these do not connect and vehicular routes like unsurfaced highways, and byways provide essential parts of an equestrian network which are “no priority” under the hierarchy. This essentially makes it impossible to get to the bridleways on horseback because they are not kept open or maintained.

6. The LDP makes considerable reference to walking and cycling with projects and funding and policies referring to Active Travel and The Well Being and Future Generations Act. The LDP needs to allocate space and facilities for the same movement of equestrians, for local riders and tourists, where there is a significant interest in travelling a trail by tourists and access to local beaches, forests and parks. Removing all legal issues and opening all of the 165km kms of bridleway in the county will not provide sufficient access for the 22,000 horses residing here or the visitors that come on horseback because the routes are fragmented. This is a tourism opportunity that is not being realised and that could improve the local economy.

7. Many horse riders and carriage drivers are older people who have disabilities due to age. They are predominantly female and using a horse is a sustainable method of transport to access the country side for health and well being. Many would not be able to access the countryside otherwise, due to heath limitations but the lack of facilities for them in a rural county needs addressing.

8. Pembrey- There are specific issues relating to inadequate parking for horse transport to access the beach, other rights of way, and the forestry for permit holders. Equestrians are also refused access to the Pembrey Park and Millennium Coast Park despite significant land available and development for others that could incorporate horse use. There should be provision for all residents on the peninsular and this is very popular place for horses given the all weather sandy surfaces and numerous byways and other access opportunities.

9. Gwendraeth Railway- proposals to develop this line for walking and cycling do not include horse use despite historic use of the old railway corridor and other railway corridors that have already been made active travel routes and equestrians excluded. The excuses for lack of inclusion name the cost and inability to obtain the land required to make these routes wide enough. This needs addressing by policy as bridleways are the original Active Travel routes open to all non motorised users and are 3m wide. Cyclists were granted access to bridleways in 1968 so there should be no objection to horses sharing cycle paths.

10.Tywi Valley Path- This is being developed as a leisure route and has attracted leisure funding but horse riders re not being included on it. If the Authority is insisting that horse riders are predominantly leisure users and do not fall under Active Travel funding then any leisure funding should incorporate equestrian access in order to satisfy the improvement of equestrian access. The ROWIP contains reference to the lack of equestrian access in the county . but the Authority but is not making reference to postitive steps in the LDP to do anything to retain past/present access had by horses and is more importantly not creating safe access for the future either on or off road. This means current and future needs of horse riders are not being met under the Well Being and Future Generations Act. Parents are not willing to risk the lives of their children by teaching them to ride on the road and this is affecting the numbers of children being able to ride at a young age.

11.Equestrians should be included in all road schemes under Government road safety legislation but the new link road built at Cross Hands has done nothing to improve the safety of equestrians accessing Llyn Lech Owain- where parking for horses has been denied- or Mynydd Mawr Woodland Park. Access is denied to a roadside cycle path and the grass path apparently provided is substantially inadequate and unusable.

12.As horse riders are not “Transport” in TAN18 there is insufficient assessment of their needs within local communities under planning of any sort. There may not be bridleways in the locality but there are horses so the road needs to be safe for them as well as walkers and cyclists. Making a quiet lane much busier will affect the route used by horses as does crossing of busier roads. This can be achieved by allocating sufficient land to accommodate them where horses are living, where there are equestrian facilities like riding clubs and livery yards or resident horses or equestrian businesses. Safe access both on and off road to where they want to go, like beaches, forests, parks and bridleways/byways is also a necessity and making sure that provision for others is not compromising safety of horse riders.

13. Horses are mentioned as leisure users briefly in TAN 16 in association with walking and cycling in relation to access to facilities. This needs to be more robust in the LDP as walking and cycling is being addressed under active travel but horse riders are not. Much of the reason given for not sharing routes, is lack of space to accommodate. Segregation is not always the best arrangement as it encourages fast moving cycles and lack of respect. This should be thought about on a case by case basis depending on expected numbers of users.

14.TAN 16 Sport Recreation and Open Space 2009 mentions horses in the following context but the mention of horse riders and carriage drivers has little mention in the current plan to support the need for facilities for equestrians as leisure users, raised in the ROWIP.

2.6 In order to encourage walking, cycling and horse riding and other low carbon modes of travel which can help tackle climate change, particular attention should be given to

opportunities to use disused railway corridors and canal towpaths to provide local and long distance routes and to enhance and extend linear open space corridors, including circular routes which can help reduce equestrian use of roads. This reference to horses is not robust enough to get adequate assessment or inclusion of horse riders needs for the future under Well Being and Future Generations Act.

3.42 The LDP should also consider the potential for extending and enhancing local and long distance recreational routes for walking, cycling and horse riding. This reference to horses is not robust enough to get adequate assessment or inclusion of horse riders needs for the future under Well Being and Future Generations Act.

.

4.12 Local planning authorities should seek to promote and provide better facilities for walkers, cyclists and horse-riders, including people from ethnic minorities, disadvantaged and disabled people. This reference to horses is not robust enough to get adequate assessment or inclusion of horse riders needs for the future under Well Being and Future Generations Act.

Mention is made under RD5 Equestrian facilities but refers to menage provision and not access to communities or greenspace, social inclusion or health and well being and leisure facilities.

15. Since the submission of the Deposit LDP, horse riders have been officially classified as vulnerable road users under the Wales Road Safety Strategy. There has also been changes made to the Highway Code and a hierarchy of users with equestrians shown as vulnerable as cyclists. There should therefore be a significant reflection of this in the LDP to assist in safegarding horseriders through planning and development to give them as much protection from danger on the roads as other vulnerable road users. ie walkers and cyclists.

16. Equestrians rely heavily in Carmarthenshire, on road links to get to bridleways, byways and unsurfaced roads. Unfortunately unsurfaced roads used for leisure are at the bottom of the “highway hierarchy” for resources meaning they have no priority for maintenance but form important links in Equestrian circular routes that link bridleways. Byways and other vehicular routes subject of a traffic regulation order to prevent vehicular use, receive no maintenance for decades and become obstructed, falling between the Highways Dept and Countryside Dept for responsibility. This has a significant effect on equestrian access.

17. Active Travel routes that include cycles, using public rights of way need to be made truly multi user by being awarded bridleway or restricted byway status to preserve access for all. Any development should include access opportunities for all users, not just walkers and cyclists so links within the community are accessible to all to obtain best value for public money. If this is not feasible then alternative routes are required for horses.

Horse riders are not considered under TAN18 as transport for consideration in planning applications and although the planning system requires equestrians to be considered and included in risk assessments as road users, in reality, this is not effective consideration. There is insufficient inclusion of equestrians in the LDP and it doesnt go far enough to provide safe on and off road opportunities for the equestrian community or protect them when planning road schemes and active travel improvements. There are more than 22,000 registered/passported horses in the county. Nationally equestrian routes form 22% of the rights of way network but in Carmarthenshire its less than 7%. There needs to be a much more positive and active statement to provide land and development for multi user routes that include horse riders and carriage drivers.

No specific change noted.

To whom it may concern,

Please accept my comments regarding consideration of equestrians needs within the Carmarthenshire revised LDP.

The Future of Generations Act 2015 underpins the importance of access to our outdoor spaces. Equestrians’ activities provide great opportunity for people of all ages and disabilities to access the countryside and participate in sport.
Equestrians also can and do contribute significantly to local economies. The LDP, Councils and design engineers etc can, by consulting with local equestrians and associated businesses and with The British Horse Society help to engage and so plan for inclusion and safer off-road access.
Many people find it difficult to respond to online consultations and miss alerts to respond by other means and can be put off by difficult language and complicated terminology. Also, many equestrians find the process daunting.

Active Travel Act so far has designed the policy without full inclusions of equestrians.
Active Travel Act Guidance July 2021 (WG).( Active travel Wales Act 2013).

1.3.6 Equestrianism is overwhelmingly for leisure purposes rather than as a mode of transport as it rarely displaces a car journey. Forms of equestrian travel (horse riding, carriage driving, pony and trap etc.) are not considered forms of active travel. However, in delivering the provisions of the Act, local authorities should be aware that equestrians are vulnerable road users and should not restrict equestrian access to routes that they currently enjoy. Bridleways can be used by equestrians, walkers and cyclists and so may form part of an active travel route. Enhancements to bridleways should not impede equestrian use or require them to use a less safe route instead. In some cases, it may be more appropriate for all users if separate provision is made for walkers, cyclists and equestrian users. Where active travel routes are planned on an alignment for which there is also high demand from horse riders, the feasibility of accommodating them should also be assessed.

11.32.5 Equestrians should not be denied access to routes that they currently have the right to use by changing the classification of the rights of way. There needs to be clear signing pf which routes are intended for use by equestrians. If widths permit , separate unsealed surface may be preferable for equestrians.

There has been a presumption by Welsh Government that equestrians do not use the horse as a mode of transport in Wales. Horse riders and Carriage drivers do use this form of transport to visit family and friends, collect feed, deliver goods and there are equestrians who operate in business for example in sites of environmental importance and commercial enterprises.

Due to vulnerability on the road network, equestrians must risk assess, when best to travel, therefore our presence is not noticed and presumed sometimes by local councils as not existing.

Due to funding cuts on our public rights of Way and reduced maintenance we have sort to encourage local equestrian groups to liaise and partnership with other organisations, Prow, highways, community councils to assist.

https://www.bhs.org.uk/ More info from our site and I am happy to provide more data.

Thank you for consulting the Welsh Government on the Carmarthenshire County Council Local Development Plan (LDP) 2nd Deposit plan and documents. It is essential the authority is covered by an up-to-date LDP to give certainty to local communities and business.
Without prejudice to the Minster’s powers, the Welsh Government is committed to helping Local Planning Authorities (LPAs) minimise the risk of submitting unsound plans by making comments at the earliest stages of plan preparation. The Welsh Government looks for clear evidence that the plan is in general conformity with Future Wales: The National Development Framework and aligns with Planning Policy Wales (PPW), and that the tests of soundness (as set out in the ‘LDP Manual’) are addressed.
National planning policies are set out in Planning Policy Wales (PPW) Edition 11, which seeks to deliver high quality, sustainable places through a place-making approach. The implementation of the core policy areas in PPW, such as adopting a sustainable spatial strategy, appropriate housing and economic growth levels, infrastructure delivery and place-making, are articulated in more detail in the LDP Manual (Edition 3). We expect the core elements of the Manual, in particular Chapter 5 and the ‘De-risking Checklist(s) to be followed. The development planning system in Wales is evidence led and demonstrating how a plan is shaped by the evidence is a key requirement of the LDP examination.
After considering the key issues and policies in Future Wales, the Welsh Government is of the view that the level and spatial distribution of growth is in general conformity with Future Wales: The National Development Framework. However, the Statement of General Conformity (Annex 1 to this letter) is a ‘caveated response’. Annex 2 of this letter raises fundamental inconsistencies regarding the total housing provision and until these matters have been addressed and their implications understood, it is not possible to give a firm view on matters of general conformity at this time. Annex 2 of this letter also highlights a range of issues that need to be addressed for the plan to align with PPW and DPM. Collectively, our comments highlight a range of issues that need to be addressed for the plan to be considered ‘sound’ as follows:
Annex 1 – General Conformity with Future Wales (Caveated Response)
· Regional Collaboration/Level of growth Further clarity required. Annex 2 – Core matters that need to be addressed (PPW and the DPM)
Our representations are separated into three categories set out by topic area, with further detail in the attached annex.
Category A: Fundamental issues that are considered to present a significant degree of risk for the LPA if not addressed prior to submission stage and may have implications for the plan’s strategy.
None.
Category B: Matters where it appears that the deposit plan has not satisfactorily translated national policy down to the local level and there may be tensions within the plan, namely (not exhaustive):
· Level of Housing Provision
· Delivery and Viability
· Restriction of new homes to Class C3 only
· Gypsy and Traveller Provision
· Best and Most Versatile Land (BMV)
Category C: Whilst not considered to be fundamental to the soundness of the LDP, we consider there to be a lack of certainty or clarity on the following matters:
· Flooding
· Renewable Energy
· Minerals
· Phosphates
I would urge you to seek your own legal advice to ensure you have met all the procedural requirements, including the Sustainability Appraisal (SA), Strategic Environmental Assessment (SEA) and Habitats Regulation Assessment (HRA), as responsibility for these matters rests with your authority. A requirement to undertake a Health Impact Assessment (HIA) arising from the Public Health (Wales) Act 2017, if appropriate, should be carried out to assess the likely effect of the proposed development plan on health, mental well-being and inequality.
It is for your Authority to ensure that the LDP is ‘sound’, and it will be for the Inspector to determine how the examination proceeds if you submit the plan without addressing the concerns we raise. My colleagues and I look forward to meeting you and the team to discuss matters arising from this response.

No change specified.

Dear All
1. Equestrians are officially classed as vulnerable road users and need provision to keep them safe which is not being adequately assessed currently. Carmarthenshire is predominantly rural and has a high horse population.


2. Equestrians are not being included as active travellers on AT routes in Carmarthenshire so they require suitable parking space so they can transport horses to safe places to ride. Currently we are restricted by height and length in many council carparks. The LDP is not addressing current or future needs of equestrians. Where safe sites exist, riders feel unsafe riding to the site and often cannot park there.



3. Risk assessments for equestrians are not adequate when planning Active Travel improvements and alternative options are not provided for them where traffic/population growth is planned. This is evident in Cross Hands where there is significant development and a high horse population. Developments could require access suitable for horses but instead offer only shared use paths.



4. Equestrians are not positively included in any policy other than the Rights of Way Improvement Plan. They have been marginalised because they do not fit into any single portfolio. Their needs span, rural affairs, tourism, transport and leisure business areas and touch on others and risk assessments are not realistic if they are included at all.



5. The highway hierarchy to prioritise resources is discriminatory because although it places bridleways as a priority, there are very few of them; these do not connect and vehicular routes like unsurfaced highways, and byways provide essential parts of an equestrian network which are “no priority” under the hierarchy. This essentially makes it impossible to get to the bridleways on horseback because they are not kept open or maintained.



6. The LDP makes considerable reference to walking and cycling with projects and funding and policies referring to Active Travel and The Well Being and Future Generations Act. The LDP needs to allocate space and facilities for the same movement of equestrians, for local riders and tourists, where there is a significant interest in travelling a trail by tourists and access to local beaches, forests and parks. Removing all legal issues and opening all of the 165km kms of bridleway in the county will not provide sufficient access for the 22,000 horses residing here or the visitors that come on horseback because the routes are fragmented. This is a tourism opportunity that is not being realised and that could improve the local economy.



7. Many horse riders and carriage drivers are older people who have disabilities due to age. They are predominantly female and using a horse is a sustainable method of transport to access the country side for health and well being. Many would not be able to access the countryside otherwise, due to heath limitations but the lack of facilities for them in a rural county needs addressing.



8. Pembrey- There are specific issues relating to inadequate parking for horse transport to access the beach, other rights of way, and the forestry for permit holders. Equestrians are also refused access to the Pembrey Park and Millennium Coast Park despite significant land available and development for others that could incorporate horse use. There should be provision for all residents on the peninsular and this is very popular place for horses given the all weather sandy surfaces and numerous byways and other access opportunities.



9. Gwendraeth Railway- proposals to develop this line for walking and cycling do not include horse use despite historic use of the old railway corridor and other railway corridors that have already been made active travel routes and equestrians excluded. The excuses for lack of inclusion name the cost and inability to obtain the land required to make these routes wide enough. This needs addressing by policy as bridleways are the original Active Travel routes open to all non motorised users and are 3m wide. Cyclists were granted access to bridleways in 1968 so there should be no objection to horses sharing cycle paths.



10.Tywi Valley Path- This is being developed as a leisure route and has attracted leisure funding but horse riders re not being included on it. If the Authority is insisting that horse riders are predominantly leisure users and do not fall under Active Travel funding then any leisure funding should incorporate equestrian access in order to satisfy the improvement of equestrian access. The ROWIP contains reference to the lack of equestrian access in the county . but the Authority is not making reference to postitive steps in the LDP to do anything to retain past/present access had by horses and is more importantly not creating safe access for the future either on or off road. This means current and future needs of horse riders are not being met under the Well Being and Future Generations Act. Parents are not willing to risk the lives of their children by teaching them to ride on the road and this is affecting the numbers of children being able to ride at a young age.



11.Equestrians should be included in all road schemes under Government road safety legislation but the new link road built at Cross Hands has done nothing to improve the safety of equestrians accessing Llyn Lech Owain- where parking for horses has been denied- or Mynydd Mawr Woodland Park. Access is denied to a roadside cycle path and the grass path apparently provided is substantially inadequate and unusable.


12.As horse riders are not “Transport” in TAN18 there is insufficient assessment of their needs within local communities under planning of any sort. There may not be bridleways in the locality but there are horses so the road needs to be safe for them as well as walkers and cyclists. Making a quiet lane much busier will affect the route used by horses as does crossing of busier roads. This can be achieved by allocating sufficient land to accommodate them where horses are living, where there are equestrian facilities like riding clubs and livery yards or resident horses or equestrian businesses. Safe access both on and off road to where they want to go, like beaches, forests, parks and bridleways/byways is also a necessity and making sure that provision for others is not compromising safety of horse riders.



13. Horses are mentioned as leisure users briefly in TAN 16 in association with walking and cycling in relation to access to facilities. This needs to be more robust in the LDP as walking and cycling is being addressed under active travel but horse riders are not. Much of the reason given for not sharing routes, is lack of space to accommodate. Segregation is not always the best arrangement as it encourages fast moving cycles and lack of respect. This should be thought about on a case by case basis depending on expected numbers of users.


14.TAN 16 Sport Recreation and Open Space 2009 mentions horses in the following context but the mention of horse riders and carriage drivers has little mention in the current LDP to support provision of facilities for equestrians as leisure users, raised in the ROWIP.



2.6 In order to encourage walking, cycling and horse riding and other low carbon modes of travel which can help tackle climate change, particular attention should be given to

opportunities to use disused railway corridors and canal towpaths to provide local and long distance routes and to enhance and extend linear open space corridors, including circular routes which can help reduce equestrian use of roads. This reference to horses is not robust enough to get adequate assessment or inclusion of horse riders needs for the future under Well Being and Future Generations Act.


3.42 The LDP should also consider the potential for extending and enhancing local and long distance recreational routes for walking, cycling and horse riding. This reference to horses is not robust enough to get adequate assessment or inclusion of horse riders needs for the future under Well Being and Future Generations Act.


4.12 Local planning authorities should seek to promote and provide better facilities for walkers, cyclists and horse-riders, including people from ethnic minorities, disadvantaged and disabled people. This reference to horses is not robust enough to get adequate assessment or inclusion of horse riders needs for the future under Well Being and Future Generations Act.

Mention is made under RD5 Equestrian facilities but refers to menage provision and not access to communities or greenspace, social inclusion or health and well being and leisure facilities.


15. Since the submission of the Deposit LDP, horse riders have been officially classified as vulnerable road users under the Wales Road Safety Strategy. There has also been changes made to the Highway Code and a hierarchy of users with equestrians shown as vulnerable as cyclists. There should therefore be a significant reflection of this in the LDP to assist in safegarding horseriders through planning and development to give them as much protection from danger on the roads as other vulnerable road users. ie walkers and cyclists.


16. Equestrians rely heavily in Carmarthenshire, on road links to get to bridleways, byways and unsurfaced roads. Unfortunately unsurfaced roads used for leisure are at the bottom of the “highway hierarchy” for resources meaning they have no priority for maintenance but form important links in Equestrian circular routes that link bridleways. Byways and other vehicular routes subject of a Traffic Regulation Order to prevent vehicular use, receive no maintenance for decades and become obstructed, falling between the Highways Dept and Countryside Dept for responsibility. This has a significant effect on equestrian access.



17. Active Travel routes that include cycles, using public rights of way need to be made truly multi user by being awarded bridleway or restricted byway status to preserve access for all. Any development should include access opportunities for all users, not just walkers and cyclists so links within the community are accessible to all to obtain best value for public money. If this is not feasible then alternative routes are required for horses.

18. Horse riders are not considered under TAN18 as transport for consideration in planning applications and although the planning system requires equestrians to be considered and included in risk assessments as road users, in reality, this is not effective consideration. There is insufficient inclusion of equestrians in the LDP and it doesnt go far enough to provide safe on and off road opportunities for the equestrian community or protect them when planning road schemes and active travel improvements. There are more than 22,000 registered/passported horses in the county. Nationally equestrian routes form 22% of the rights of way network but in Carmarthenshire its less than 7%. There needs to be a much more positive and active statement to provide land and development for multi user routes that include horse riders and carriage drivers.




Comments on Policy in blue below

The previous LDP referred to


5.5.13 The need to develop a plan which optimises the opportunity for the delivery of an efficient, effective, safe and integrated transport system is recognised. In this respect, the strategy aims to co-ordinate land use to:

•

Reduce the need to travel, particularly by private motor car, through promoting accessibility to public transport facilities;

•

Promote, support and enhance alternatives to the motor car, such as public transport (including park and ride facilities and encourage the adoption of travel plans), cycling, walking and opportunities for horse riding where
appropriate;



“Where appropriate” is not robust enough to provide for equestrian needs. There are no stats regarding horse numbers being used to assess where horses are or where they want to go and there is no criteria for when something is appropriate. This needs clarifying. There is data available under horse passports/microchip database held by DEFRA and BHS equestrian statistics and police statistics.




There is a need for links to bridleways and byways for horses, walkers and cyclists and to allow horses to travel safely to off road facilities so they do not need to transport horses in vehicles. Where horse parking is not provided, there should be inclusion on AT routes both off road and road side paths. The LDP does not acknowledge the needs of equestrians particularly in developing towns like the Cross Hands area where there is a high horse population even though comments are made on planning consultations.





Policy TR3 Highways in Developments - Design Considerations

The design and layout of all development proposals will, where appropriate, be required to include:

a) An integrated network of convenient and safe pedestrian and cycle routes (within and from the site) which promotes the interests of pedestrians, cyclists and public transport; Horses not included
b) Suitable provision for access by public transport;

c) Appropriate parking and where applicable, servicing space in accordance with required standards; Equestrian parking

d) Infrastructure and spaces allowing safe and easy access for those with mobility difficulties;

e) Required access standards reflective of the relevant class of road and speed restrictions including visibility splays and

design features and calming measures necessary to ensure highway safety and the ease of movement is maintained and where required enhanced;

f) Provision for Sustainable Urban Drainage Systems to allow for the disposal of surface water run off from the highway.
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 Where quiet lanes provide a circular route or a link to a bridleway or byway, alternative provision needs considering for local equestrians. This is currently not happening. There is no thought to horses accessing safer routes or horses using the roads in semi rural areas like Cross Hands.

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. Developers may be required to facilitate appropriate works as part of the granting of any permission.





Policy TR4 Cycling and Walking

Land required to facilitate the following improvements to the cycle network will be safeguarded. Proposed routes where known are shown on the proposals map. The potential opportunity for horse riding should where appropriate be

considered.

a) Towy Valley (between Llandeilo and Carmarthen); This is being built as a leisure route yet horse riders are still barred from using this off road path. We are being told that we are leisure users but are not getting any access improvements on new leisure routes either.

b) Whitland to Llanglydwen;

c) Ammanford to the Amman Valley. This is a high ly populated horse area with riding clubs and equestrian facilities. Inclusion in land allocation needs to be more robust to provide for local equestrians.
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.



This walking and cycling policy puts bridleways in the frame for an increase in walking and cycling traffic but because they are so few and there are no alternative routes for horse riders, we are being pushed off the only routes we have away from traffic without us being offered additional alternative routes.



Policy TR6 Redundant Rail Corridors
Development proposals which do not prejudice the re-use of redundant rail corridors for potential future recreational and rail development purposes will be permitted.

Strategic Objective Supported:

SO7, SO8, SO10, SO11 and SO12

This policy should be read in conjunction with other relevant policies and proposals of this LDP.

6.5.24 The Plan area has a number of former railway lines which offer considerable benefit for recreational activities including cycle routes, footpaths and bridleways. Consideration also needs to be given to the potential future re-use of rail routes when considering proposals which may impact upon the continuity and availability of the route.



Because of the lack of official bridleways, horses have used redundant rail corridors to make links in the local network. Access to horse riders is not currently happening on routes that have used informally and are now being turned into Active Travel routes. They are being referred to as recreational routes but CCC are not providing access to horses on these routes.





6.9 Recreation and Leisure
6.9.1 Open space has the potential to provide benefits to health and wellbeing and can assist in mitigating the causes and effects of climate change. Open spaces can also provide arenas for social interaction and community activities, and have a key role to play in underpinning other key strategic documents, such as the Health, Social Care and Well Being strategy. In this regard, the protection and enhancement of provision represents a key consideration for the LDP.

6.9.2 Along with open space, policy REC 1 also recognises the key role of allotments, particularly in terms of developing community cohesion and also as an acknowledgment of the future issue of food security . Whilst seeking to promote

allotments, their future management is governed by specific legislation (see PPW: Edition 4)

6.9.3 Locally distinctive evidence underpins the Plan’s policies in respect of open space. The Carmarthenshire Greenspace Study provide s an audit of provision based upon national standards and guidance (including the

C.C.W green space toolkit and the N.P.F.A. Six Acre Standard) as well as local in formation on locally significant
provision sourced from the local community and/or Authority officers. It should be noted that there may be locally significant provisions that are not formally recognised in the Greenspace Study, or on the proposals/inset

maps, that make an important contribution towards open space and therefore ‘local knowledge’ should also be

considered when determining the significance of these spaces to the local community. The study provides a spatial context in terms of accessibility to provision and provides some useful definitions of open space.

For the purposes of the LDP, open space includes: natural green space, play space and public open space, in

accordance with the guidance issued within TAN 16.

The Greenspace study project standards are the ones to which the County is working towards, with the 2.4ha per
1000 N.P.F.A standard adopted. It should however be noted that the LDP is seeking to facilitate betterment in terms of accessibility to open space, and therefore an aspirational standard of 2.8 ha per 1000 is include d within the Plan’s monitoring framework. The study also provides a spatial appreciation of where there are potential deficiencies and surpluses in provision a cross the County.

6.9.4 Clear national guidance in respect of this topic is contained within PPW: Edition 4: Tourism, sport and recreation and TAN 16

: - Sport, Recreation and Open Space. Consequently, the following matters do not require LDP policies as they are

adequately covered by the aforementioned national guidance:



•Golf courses;

•Allotments, cemeteries and church yards;

•Major sporting and recreation facilities;

•Off road recreational vehicles.


6.9.5 Additional national development management policy statements may also be found in the above guidance, including such issues as impact of floodlighting and amenity concerns. In terms of leisure and recreation, reference should also be made to SP16 which confirms the Plan’s emphasis on protecting, and wherever possible enhancing, the sustainability and vitality of the County’s recreation and leisure facilities in accordance with the settlement framework. Whilst being covered by legislation by virtue of the C.R.O.W. Act 2000, rights of way also play an integral role in enhancing health and well being and their role (alongside that of footpaths and informal connectivity corridors) should be consider ed within the context of the LDP. Assisting in improving access to Carmarthenshire’s attractive coastal areas is an important consideration for the LDP, however any development proposals should not be in conflict with Policies EP4 and EP5.



The above reference to leisure and recreation opportunities does not specifically mention equestrian needs and its inference in the policy does not suggest that equestrians are being adequately considered as “predominantly leisure users”. (this phrase is routinely used in responses by the council when we are asking for inclusion on Active Travel routes so it would be expected that equestrians would be robustly included in any leisure and recreation policy and the LDP.) Forestry, beaches and parks are important sites for lawful safe off road riding and the limited rights of way network for horses means that these sites are attracting increased equestrian traffic as riders are looking for off road places to ride that they can also park at. Parking of horse transport is required if access to these sites is on a busy A road or requiring negotiation of roundabouts, fast moving traffic or other hazards.


I have included the following items of supporting evidence.
1. Horse numbers for Wales - from the National Equine Database 2012 produced from passports registered to horse owners registered to a Carmarthenshire address.
2. BHS stats Carmarthenshire 2009- breakdown of passported horses by post code area
3. Bridleways Carms- map of registered bridleways which are not all available for use.
4. Wales bridleways copy- Countryside Council for Wales map of registered bridleways in Wales/Carmarthenshire.
5. Wales footpaths copy- comparison CCW map of registered footpaths in Wales.
6. BHS Road Safety stats- 2021/2022 for Wales showing doubling of issues.

No change specified.

SECOND REVISED LOCAL DEVELOPMENT PLAN 2018 – 2033: CYNGOR SIR GÂR
Response to Public Consultation April 2023

1. We wish to support the points raised in the response submitted by Plaid Cymru Councillors and fully support the content of the document
2. We wish to add these points for consideration, in addition to responses made online:
• Rural Enterprise Dwellings: The interpretation of this policy needs to be expanded beyond traditional rural enterprise to include supporting individuals who make a positive social and or ecological impact in our rural landscape.
• When interpreting development proposals against policy, all proposals should be required to meet a higher level of minimum standards regarding environmental design and sustainable developments, essentially setting SP12 and PSD5 as substantive pre-requisites before other policy is then considered.
• Consideration should be given against the local context, where evidenced, when considering affordable and intermediate housing.
• Planning policy should aim to limit the impact of second homes/holiday homes on rural settlements.
• The development limits in Llansteffan do not yet include a long established group of houses along Mill Pond Lane, SA33 5LG. This lane is part of the settlement, and should reside within the limits. See below image of proposed change to boundary.

No change specified.

To whom it may concern,
Please note my response to LDP.

1. Equestrians are officially classed as vulnerable road users and need provision to keep them safe which is not being adequately assessed currently. Carmarthenshire is predominantly rural and has a high horse population.
2. Equestrians are not being included as active travellers on AT routes in Carmarthenshire so they require suitable parking space so they can transport horses to safe places to ride. Currently we are restricted by height and length in many council carparks. The LDP is not addressing current or future needs of equestrians. Where safe sites exist, riders feel unsafe riding to the site and often cannot park there.
3. Risk assessments for equestrians are not adequate when planning Active Travel improvements and alternative options are not provided for them where traffic/population growth is planned. This is evident in Cross Hands where there is significant development and a high horse population. Developments could require access suitable for horses but instead offer only shared use paths.
4. Equestrians are not positively included in any policy other than the Rights of Way Improvement Plan. They have been marginalised because they do not fit into any single portfolio. Their needs span, rural affairs, tourism, transport and leisure business areas and touch on others and risk assessments are not realistic if they are included at all.
5. The highway hierarchy to prioritise resources is discriminatory because although it places bridleways as a priority, there are very few of them; these do not connect and vehicular routes like unsurfaced highways, and byways provide essential parts of an equestrian network which are “no priority” under the hierarchy. This essentially makes it impossible to get to the bridleways on horseback because they are not kept open or maintained.
6. The LDP makes considerable reference to walking and cycling with projects and funding and policies referring to Active Travel and The Well Being and Future Generations Act. The LDP needs to allocate space and facilities for the same movement of equestrians, for local riders and tourists, where there is a significant interest in travelling a trail by tourists and access to local beaches, forests and parks. Removing all legal issues and opening all of the 165km kms of bridleway in the county will not provide sufficient access for the 22,000 horses residing here or the visitors that come on horseback because the routes are fragmented. This is a tourism opportunity that is not being realised and that could improve the local economy.
7. Many horse riders and carriage drivers are older people who have disabilities due to age. They are predominantly female and using a horse is a sustainable method of transport to access the country side for health and well being. Many would not be able to access the countryside otherwise, due to heath limitations but the lack of facilities for them in a rural county needs addressing.
8. Pembrey- There are specific issues relating to inadequate parking for horse transport to access the beach, other rights of way, and the forestry for permit holders. Equestrians are also refused access to the Pembrey Park and Millennium Coast Park despite significant land available and development for others that could incorporate horse use. There should be provision for all residents on the peninsular and this is very popular place for horses given the all weather sandy surfaces and numerous byways and other access opportunities.
9. Gwendraeth Railway- proposals to develop this line for walking and cycling do not include horse use despite historic use of the old railway corridor and other railway corridors that have already been made active travel routes and equestrians excluded. The excuses for lack of inclusion name the cost and inability to obtain the land required to make these routes wide enough. This needs addressing by policy as bridleways are the original Active Travel routes open to all non motorised users and are 3m wide. Cyclists were granted access to bridleways in 1968 so there should be no objection to horses sharing cycle paths.
10.Tywi Valley Path- This is being developed as a leisure route and has attracted leisure funding but horse riders re not being included on it. If the Authority is insisting that horse riders are predominantly leisure users and do not fall under Active Travel funding then any leisure funding should incorporate equestrian access in order to satisfy the improvement of equestrian access. The ROWIP contains reference to the lack of equestrian access in the county . but the Authority but is not making reference to postitive steps in the LDP to do anything to retain past/present access had by horses and is more importantly not creating safe access for the future either on or off road. This means current and future needs of horse riders are not being met under the Well Being and Future Generations Act. Parents are not willing to risk the lives of their children by teaching them to ride on the road and this is affecting the numbers of children being able to ride at a young age.
11.Equestrians should be included in all road schemes under Government road safety legislation but the new link road built at Cross Hands has done nothing to improve the safety of equestrians accessing Llyn Lech Owain- where parking for horses has been denied- or Mynydd Mawr Woodland Park. Access is denied to a roadside cycle path and the grass path apparently provided is substantially inadequate and unusable.
12.As horse riders are not “Transport” in TAN18 there is insufficient assessment of their needs within local communities under planning of any sort. There may not be bridleways in the locality but there are horses so the road needs to be safe for them as well as walkers and cyclists. Making a quiet lane much busier will affect the route used by horses as does crossing of busier roads. This can be achieved by allocating sufficient land to accommodate them where horses are living, where there are equestrian facilities like riding clubs and livery yards or resident horses or equestrian businesses. Safe access both on and off road to where they want to go, like beaches, forests, parks and bridleways/byways is also a necessity and making sure that provision for others is not compromising safety of horse riders.
13. Horses are mentioned as leisure users briefly in TAN 16 in association with walking and cycling in relation to access to facilities. This needs to be more robust in the LDP as walking and cycling is being addressed under active travel but horse riders are not. Much of the reason given for not sharing routes, is lack of space to accommodate. Segregation is not always the best arrangement as it encourages fast moving cycles and lack of respect. This should be thought about on a case by case basis depending on expected numbers of users.
14.TAN 16 Sport Recreation and Open Space 2009 mentions horses in the following context but the mention of horse riders and carriage drivers has little mention in the current plan to support the need for facilities for equestrians as leisure users, raised in the ROWIP.
2.6 In order to encourage walking, cycling and horse riding and other low carbon modes of travel which can help tackle climate change, particular attention should be given to
opportunities to use disused railway corridors and canal towpaths to provide local and long distance routes and to enhance and extend linear open space corridors, including circular routes which can help reduce equestrian use of roads. This reference to horses is not robust enough to get adequate assessment or inclusion of horse riders needs for the future under Well Being and Future Generations Act.
3.42 The LDP should also consider the potential for extending and enhancing local and long distance recreational routes for walking, cycling and horse riding. This reference to horses is not robust enough to get adequate assessment or inclusion of horse riders needs for the future under Well Being and Future Generations Act.
.
4.12 Local planning authorities should seek to promote and provide better facilities for walkers, cyclists and horse-riders, including people from ethnic minorities, disadvantaged and disabled people. This reference to horses is not robust enough to get adequate assessment or inclusion of horse riders needs for the future under Well Being and Future Generations Act.
Mention is made under RD5 Equestrian facilities but refers to menage provision and not access to communities or greenspace, social inclusion or health and well being and leisure facilities.
15. Since the submission of the Deposit LDP, horse riders have been officially classified as vulnerable road users under the Wales Road Safety Strategy. There has also been changes made to the Highway Code and a hierarchy of users with equestrians shown as vulnerable as cyclists. There should therefore be a significant reflection of this in the LDP to assist in safegarding horseriders through planning and development to give them as much protection from danger on the roads as other vulnerable road users. ie walkers and cyclists.
16. Equestrians rely heavily in Carmarthenshire, on road links to get to bridleways, byways and unsurfaced roads. Unfortunately unsurfaced roads used for leisure are at the bottom of the “highway hierarchy” for resources meaning they have no priority for maintenance but form important links in Equestrian circular routes that link bridleways. Byways and other vehicular routes subject of a traffic regulation order to prevent vehicular use, receive no maintenance for decades and become obstructed, falling between the Highways Dept and Countryside Dept for responsibility. This has a significant effect on equestrian access.
17. Active Travel routes that include cycles, using public rights of way need to be made truly multi user by being awarded bridleway or restricted byway status to preserve access for all. Any development should include access opportunities for all users, not just walkers and cyclists so links within the community are accessible to all to obtain best value for public money. If this is not feasible then alternative routes are required for horses.
Horse riders are not considered under TAN18 as transport for consideration in planning applications and although the planning system requires equestrians to be considered and included in risk assessments as road users, in reality, this is not effective consideration. There is insufficient inclusion of equestrians in the LDP and it doesnt go far enough to provide safe on and off road opportunities for the equestrian community or protect them when planning road schemes and active travel improvements. There are more than 22,000 registered/passported horses in the county. Nationally equestrian routes form 22% of the rights of way network but in Carmarthenshire its less than 7%. There needs to be a much more positive and active statement to provide land and development for multi user routes that include horse riders and carriage drivers.

No change specified.

Please consider my comments below to include equestrians in the LDP plan as currently they are vulnerable and excluded.

1. Equestrians are officially classed as vulnerable road users and need provision to keep them safe which is not being adequately assessed currently. Carmarthenshire is predominantly rural and has a high horse population.

2. Equestrians are not being included as active travellers on AT routes in Carmarthenshire so they require suitable parking space so they can transport horses to safe places to ride. Currently we are restricted by height and length in many council carparks. The LDP is not addressing current or future needs of equestrians. Where safe sites exist, riders feel unsafe riding to the site and often cannot park there.

3. Risk assessments for equestrians are not adequate when planning Active Travel improvements and alternative options are not provided for them where traffic/population growth is planned. This is evident in Cross Hands where there is significant development and a high horse population. Developments could require access suitable for horses but instead offer only shared use paths.

4. Equestrians are not positively included in any policy other than the Rights of Way Improvement Plan. They have been marginalised because they do not fit into any single portfolio. Their needs span, rural affairs, tourism, transport and leisure business areas and touch on others and risk assessments are not realistic if they are included at all.

5. The highway hierarchy to prioritise resources is discriminatory because although it places bridleways as a priority, there are very few of them; these do not connect and vehicular routes like unsurfaced highways, and byways provide essential parts of an equestrian network which are “no priority” under the hierarchy. This essentially makes it impossible to get to the bridleways on horseback because they are not kept open or maintained.

6. The LDP makes considerable reference to walking and cycling with projects and funding and policies referring to Active Travel and The Well Being and Future Generations Act. The LDP needs to allocate space and facilities for the same movement of equestrians, for local riders and tourists, where there is a significant interest in travelling a trail by tourists and access to local beaches, forests and parks. Removing all legal issues and opening all of the 165km kms of bridleway in the county will not provide sufficient access for the 22,000 horses residing here or the visitors that come on horseback because the routes are fragmented. This is a tourism opportunity that is not being realised and that could improve the local economy.

7. Many horse riders and carriage drivers are older people who have disabilities due to age. They are predominantly female and using a horse is a sustainable method of transport to access the country side for health and well being. Many would not be able to access the countryside otherwise, due to heath limitations but the lack of facilities for them in a rural county needs addressing.

8. Pembrey- There are specific issues relating to inadequate parking for horse transport to access the beach, other rights of way, and the forestry for permit holders. Equestrians are also refused access to the Pembrey Park and Millennium Coast Park despite significant land available and development for others that could incorporate horse use. There should be provision for all residents on the peninsular and this is very popular place for horses given the all weather sandy surfaces and numerous byways and other access opportunities.

9. Gwendraeth Railway- proposals to develop this line for walking and cycling do not include horse use despite historic use of the old railway corridor and other railway corridors that have already been made active travel routes and equestrians excluded. The excuses for lack of inclusion name the cost and inability to obtain the land required to make these routes wide enough. This needs addressing by policy as bridleways are the original Active Travel routes open to all non motorised users and are 3m wide. Cyclists were granted access to bridleways in 1968 so there should be no objection to horses sharing cycle paths.

10.Tywi Valley Path- This is being developed as a leisure route and has attracted leisure funding but horse riders re not being included on it. If the Authority is insisting that horse riders are predominantly leisure users and do not fall under Active Travel funding then any leisure funding should incorporate equestrian access in order to satisfy the improvement of equestrian access. The ROWIP contains reference to the lack of equestrian access in the county . but the Authority but is not making reference to postitive steps in the LDP to do anything to retain past/present access had by horses and is more importantly not creating safe access for the future either on or off road. This means current and future needs of horse riders are not being met under the Well Being and Future Generations Act. Parents are not willing to risk the lives of their children by teaching them to ride on the road and this is affecting the numbers of children being able to ride at a young age.

11.Equestrians should be included in all road schemes under Government road safety legislation but the new link road built at Cross Hands has done nothing to improve the safety of equestrians accessing Llyn Lech Owain- where parking for horses has been denied- or Mynydd Mawr Woodland Park. Access is denied to a roadside cycle path and the grass path apparently provided is substantially inadequate and unusable.

12.As horse riders are not “Transport” in TAN18 there is insufficient assessment of their needs within local communities under planning of any sort. There may not be bridleways in the locality but there are horses so the road needs to be safe for them as well as walkers and cyclists. Making a quiet lane much busier will affect the route used by horses as does crossing of busier roads. This can be achieved by allocating sufficient land to accommodate them where horses are living, where there are equestrian facilities like riding clubs and livery yards or resident horses or equestrian businesses. Safe access both on and off road to where they want to go, like beaches, forests, parks and bridleways/byways is also a necessity and making sure that provision for others is not compromising safety of horse riders.

13. Horses are mentioned as leisure users briefly in TAN 16 in association with walking and cycling in relation to access to facilities. This needs to be more robust in the LDP as walking and cycling is being addressed under active travel but horse riders are not. Much of the reason given for not sharing routes, is lack of space to accommodate. Segregation is not always the best arrangement as it encourages fast moving cycles and lack of respect. This should be thought about on a case by case basis depending on expected numbers of users.

14.TAN 16 Sport Recreation and Open Space 2009 mentions horses in the following context but the mention of horse riders and carriage drivers has little mention in the current plan to support the need for facilities for equestrians as leisure users, raised in the ROWIP.

2.6 In order to encourage walking, cycling and horse riding and other low carbon modes of travel which can help tackle climate change, particular attention should be given to

opportunities to use disused railway corridors and canal towpaths to provide local and long distance routes and to enhance and extend linear open space corridors, including circular routes which can help reduce equestrian use of roads. This reference to horses is not robust enough to get adequate assessment or inclusion of horse riders needs for the future under Well Being and Future Generations Act.

3.42 The LDP should also consider the potential for extending and enhancing local and long distance recreational routes for walking, cycling and horse riding. This reference to horses is not robust enough to get adequate assessment or inclusion of horse riders needs for the future under Well Being and Future Generations Act.

.

4.12 Local planning authorities should seek to promote and provide better facilities for walkers, cyclists and horse-riders, including people from ethnic minorities, disadvantaged and disabled people. This reference to horses is not robust enough to get adequate assessment or inclusion of horse riders needs for the future under Well Being and Future Generations Act.

Mention is made under RD5 Equestrian facilities but refers to menage provision and not access to communities or greenspace, social inclusion or health and well being and leisure facilities.

15. Since the submission of the Deposit LDP, horse riders have been officially classified as vulnerable road users under the Wales Road Safety Strategy. There has also been changes made to the Highway Code and a hierarchy of users with equestrians shown as vulnerable as cyclists. There should therefore be a significant reflection of this in the LDP to assist in safegarding horseriders through planning and development to give them as much protection from danger on the roads as other vulnerable road users. ie walkers and cyclists.

16. Equestrians rely heavily in Carmarthenshire, on road links to get to bridleways, byways and unsurfaced roads. Unfortunately unsurfaced roads used for leisure are at the bottom of the “highway hierarchy” for resources meaning they have no priority for maintenance but form important links in Equestrian circular routes that link bridleways. Byways and other vehicular routes subject of a traffic regulation order to prevent vehicular use, receive no maintenance for decades and become obstructed, falling between the Highways Dept and Countryside Dept for responsibility. This has a significant effect on equestrian access.

17. Active Travel routes that include cycles, using public rights of way need to be made truly multi user by being awarded bridleway or restricted byway status to preserve access for all. Any development should include access opportunities for all users, not just walkers and cyclists so links within the community are accessible to all to obtain best value for public money. If this is not feasible then alternative routes are required for horses.

Horse riders are not considered under TAN18 as transport for consideration in planning applications and although the planning system requires equestrians to be considered and included in risk assessments as road users, in reality, this is not effective consideration. There is insufficient inclusion of equestrians in the LDP and it doesnt go far enough to provide safe on and off road opportunities for the equestrian community or protect them when planning road schemes and active travel improvements. There are more than 22,000 registered/passported horses in the county. Nationally equestrian routes form 22% of the rights of way network but in Carmarthenshire its less than 7%. There needs to be a much more positive and active statement to provide land and development for multi user routes that include horse riders and carriage drivers.