Polisi Strategol – SP 3: Dosbarthu Cynaliadwy – Fframwaith Anheddu

10.21 Teifi Cluster
We support the Deposit LDP where it states: “The close cross border relationship
of the area to those communities in Ceredigion is noted, as is the role that
settlements such as Llandysul, Lampeter and Cardigan play to the communities in
this area. This relationship is recognised in various policy documents, and is a key
consideration in the distribution and supply of homes within the 2nd Deposit LDP” continued

Land area to form part of the Development Limits for
Betws/Ammanford so as to facilitate development of no
more than two dwellings.

The land has been identified as forming part of the settlement of Betws, Ammanford for in excess of 30+ years and there has been no material change in terms of its relationship to the settlement.

The land is currently within the development limits and allocated for housing(GA3/h15) in the current LDP with the number of units based on an approved planning application for 6 dwellings which was extant at that time. It has been subject to a number of planning applications, E/25557, E30908 etc plus the most recent E/37271. The latter one was subject to a non-determination appeal (App/M6825/A/19/3236012). A considerable amount of time and funds has been spent looking at ecological and arboricultural matters in order to devise an acceptable solution for the allocated site. A scheme was drafted which was not dissimilar to a previous permission but that application (E/37271) became subject to a non-determination appeal that was eventually dismissed by the Inspector (see attached appeal decision). In terms of the trees and ecological matters the Inspector concluded that these did not preclude the development of part of the site subject to a revised approach. Since the appeal decision we have appointed a new architect to consider the site and housing design for a smaller number of units (2 dwellings) with a “softer touch” approach with minimal ground reconfiguration.
That application will be submitted shortly given the principle of development would be in accord with the current LDP. Details of the new revised scheme will be provided to the LDP Inspector shortly.

Accompanying this submission we have included the Inspector’s appeal decision and copies of the Ecological and arboricultuarl reports upon which the Inspector reached his appeal decision on application E/37271.

Having spent so much time and funds on this scheme it was disappointing to see that the replacement Draft LDP has removed the land from the development limits. At the candidate site stage the LPA indicated in the Initial Assessment that "The location of the site relates to a settlement identified as a principal centre within the Preferred Strategy. Specific consideration will be given to its inclusion or otherwise as part of the preparation of the Deposit LDP."

As a consequence I wrote to the LPA seeking a detailed and specific explanation of why the land is being removed from the development limits given there has been no material change in circumstances?

In response the LPA replied as following;
“The site has been assessed in accordance with the Site Assessment Methodology and it was considered that there are sufficient and more suitable sites available to meet the housing needs of the area. This is due to the site’s
characteristics, namely its sloping topography, the fact that it is densely vegetated and that development on the site could negatively impact upon trees subject to Tree Preservation Orders.

As you are aware, the Deposit LDP is now subject to consultation and so this would be the opportunity for you to object to the site’s exclusion. This can be done through our website.

I should also point out that the current LDP remains to be the Local Authority’s adopted plan until the Revised LDP is adopted and supersedes it; this is anticipated to take place next year. In the meantime, you could submit an application for an appropriate scheme for the site and this would be measured against the provision of the current adopted plan.” In response I would state that within the community of Betws/Ammanford there are very few opportunities for residents to develop a bespoke self-build house to meet their family needs. Historically, Betws has been a popular location for self build properties and with land being available there is no reason to assume that will not continue to be the case. The inclusion of this area within the development limits for such a modest proposal does not undermine the strategic aims of the Revised LDP but does provide some much needed choice within an area that has been acknowledged as falling within the development limits for many years.

It is acknowledged that it would no longer be appropriate to consider the site as a housing allocation site as the approach being taken to respond to the site and have full regard to the planning appeal Inspectors view will reduce the number of units to two dwellings. In terms of the protected trees and ecological matters the planning appeal Inspector concluded that these did not preclude the development of part of the site subject to a revised design
approach. For the LPA therefore, to object to part of this land being developed on such grounds cannot be supported by the evidence. Within Wales the
topography does inevitably mean that some development will take place on sloping sites but that is indeed often a key characteristic of development in the Principality and is not a legitimate reason to resist development.

It should also be noted that in terms of a sustainable location the land is ideally placed given the locality as identified in the accompanying sustainability report. Furthermore, the planning appeal Inspector made reference to section 3 and 5 of the Well Being of Future Generations (Wales) Act 2015 and acknowledged the well-being benefits of development in this area through the provision of new housing with good access to footpaths and the countryside. Those well–being attributes enhanced by the proximity of public transport services.

In the light of my submission I respectfully request that consideration be given to the continued inclusion of the land within the development limits for Betws/Ammanford.

Having reviewed the 2nd Deposit Revised Carmarthenshire Local Development Plan 2018-2033
(hereinafter referred to as the LDP), via:
https://www.carmarthenshire.gov.wales/home/council-services/planning/local-development-plan2018-2033/second-deposit-revised-local-development-plan/#.Y-9SSWTP1D8
I have been instructed by my client to make general representations to a number of the LDP’s Policies
and paragraphs; and specific representations to Policy HOM1, relating to housing allocation ref.
PrC3/h4, on Land at Tirychen Farm, Dyffryn Road, Ammanford. I have therefore enclosed a
Representation Form, completed as necessary, which should be read in conjunction with this letter
setting out my client’s representations to the 2nd Deposit Revised LDP.

General Representations to Section 8, Paragraphs 8.6 to 8.8 and 8.20
Section 8 of the LDP considers a number of alternative Strategic Growth and Spatial Options to support
the delivery of housing and employment growth in the County.
Regarding Strategic Growth Options, paragraphs 8.6 to 8.8 of the LDP confirm a preferred ‘Ten Year
Trend Based Projection’, forecast to deliver 8,822 new dwellings (588 new dwellings per year) and 276
new jobs per year over the LDP period 2018-2033. Regarding Spatial Options, paragraph 8.20 of the
LDP confirms a preferred ‘Balanced Community and Sustainable Growth Strategy’, whose key
components are summarised in paragraph 9.57 of the LDP to include these targets for new dwellings
and new jobs, distributed to the County’s most sustainable locations in accordance with a Settlement
Hierarchy, whilst recognising the need to support the County’s rural areas and rural economy.
My client supports the LDP’s preferred Strategic Growth and Spatial Options – they will deliver new
housing in line with requirements and new jobs to match the same; and represent an optimistic, though
not unrealistic set of assumptions and aspirations, geared towards encouraging housing and economic
growth in the County over the LDP period.

General Representations to Section 11, Strategic Policy SP1
Strategic Policy SP1 reflects the LDP’s preferred Strategic Growth and Spatial Options, confirming inter
alia provision of 9,704 new dwellings to meet a requirement of 8,822 new dwellings over the LDP
period, distributed in a sustainable manner consistent with the LDP’s Spatial Strategy and Settlement
Hierarchy. My client supports Strategic Policy SP1 – it sets the context for delivering new housing in
line with requirements; and represents a sustainable and optimistic, though not unrealistic strategy
geared towards encouraging and delivering new housing in the County over the LDP period.

General Representations to Section 11, Strategic Policy SP3
Strategic Policy SP3 builds on Strategic Policy SP1 by confirming that the provision of growth and
development will be directed to sustainable locations in accordance with a Spatial Framework based
upon a four Tier Settlement Hierarchy, with the County divided into six Settlement Clusters. My client
supports Strategic Policy SP3, in particular the designation of Ammanford/Crosshands as a ‘Tier 1
Principal Centre’ at the top of the Settlement Hierarchy in the County’s Settlement Cluster 3. In this
respect, Ammanford/Crosshands is a highly sustainable location to which new housing and employment
development should be directed; and it is entirely appropriate for the settlement to be positioned at
the top of the County’s Settlement Hierarchy.

General Representations to Section 11, Strategic Policy SP4 and Paragraphs 11.71 to 11.74
Strategic Policy SP4 confirms that in order to meet the requirement for 8,822 dwellings over the LDP
period, 9,704 new dwellings will be provided between 2018-2033, in accordance with the LDP’s
Settlement Framework. My client supports Strategic Policy SP4 - it sets the context for delivering new
housing in line with requirements, with a reasonable and realistic ‘buffer’ to ensure those requirements
are satisfied; and therefore represents a sustainable and achievable strategy for meeting the County’s
housing needs over the LDP period.
Moreover, my client supports paragraphs 11.71 to 11.74 of the LDP, which confirm that the majority
of new residential development, including housing allocations (defined in paragraph 11.79 of the LDP
as sites capable of yielding 5 dwellings or more), will be directed to the County’s Tier 1 Principal Centres.

Specific Representations to Policy HOM1 and Housing Allocation Ref. PrC3/h4, on Land at
Tirychen Farm, Dyffryn Road, Ammanford
I made representations for my client on 13 August 2018, in response to your Authority’s ‘Call for
Candidate Sites’, requesting that land at Tirychen Farm, Dyffryn Road, Ammanford, be considered as a
‘Candidate Site’ for allocation for housing in the Revised LDP. My client is the Freehold owner of the
land, as edged in red and blue on the enclosed Location Plan ref. 09-012/01 REV B.
In response to these representations, land owned by my client at Tirychen Farm, Dyffryn Road,
Ammanford, was included within your Authority’s Candidate Sites Register of December 2018 under
refs. CA0326 and SR/004/012, as in principle suitable and appropriate for allocation for housing. The
extent of land concerned is shown shaded in red on the enclosed extract from your Authority’s
interactive Candidate Sites map, which is available via:
http://carmarthenshire.opus4.co.uk/planning/localplan/maps/candidatesites#/x:261756/y:212431/z:10/b:14/o:2305

I made further representations for my client on 14 January 2019, in response to your Authority’s
Candidate Sites Register consultation, putting forward the case for allocating Candidate Site ref. CA0326
(Site Ref. SR/004/012) in the LDP for circa 330 dwellings. Having reviewed the 2nd Deposit Revised LDP
and in particular Policy HOM1, I note that land owned by my client at Tirychen Farm, Dyffryn Road,
Ammanford, is proposed as an allocation for 150 dwellings, under ref. PrC3/h4 and as shaded in brown
on the enclosed extract from the LDP’s interactive Proposals Map, which is available via:
https://carmarthenshire.opus4.co.uk/planning/localplan/maps/2nd-deposit-revised-carmarthenshirelocal-development-plan-2018-2033-proposals-map#/center/51.7938,-
4.0059/zoom/16/baselayer/b:31/layers/o:9423,o:9424,o:9435,o:9436,o:9437,o:9446,o:9447,o:9448,
o:9449,o:9524,o:9525,o:9526,o:9527,o:9528,o:9529,o:9530,o:9531,o:9532,o:9533,o:9560,o:9561,o:
9562,o:9563,o:9564,o:9579,o:9580

Whilst the principle of housing allocation ref. PrC3/h4 is supported by my client, it is considered that
the current terms of the allocation must be improved upon. In this respect, my client’s objections to
housing allocation ref. PrC3/h4 are set out in the following paragraphs.
You will be aware that land owned by my client at Tirychen Farm, Dyffryn Road, Ammanford is currently
allocated for 250 dwellings in the Carmarthenshire Local Development Plan (LDP) 2006-2021, under
ref. GA3/h17 in Policy H1. Moreover, the site benefits from an extant outline consent ref. E/38686
granted on 8 October 2019 (as a renewal of outline consent ref. E/21663 granted on 10 October 2014)
for 289 dwellings, with access and layout granted in detail at the outline stage, as per the enclosed
copy of consented Planning Layout ref. 09-012/05 REV F.
The site’s existing allocation ref. GA3/h17 for 250 dwellings in Policy H1 of the Carmarthenshire Local
Development Plan 2006-2021; and the terms of the site’s extant outline consent ref. E/38686 for 289
dwellings clearly and unequivocally demonstrate that the site is suitable and sustainable, and available
and achievable. At the very least, therefore, allocation ref. PrC3/h4 in the 2nd Deposit Revised LDP
should be increased from 150 dwellings to 289 dwellings, to reflect the fact that the site is a consented
‘commitment’ for 289 dwellings in Ammanford - a highly sustainable Tier 1 Principal Centre at the top
of the County’s Settlement Hierarchy.
However, the site’s allocation ref. PrC3/h4 in the 2nd Deposit Revised LDP can easily be enlarged to
match the boundaries of Candidate Site ref. CA0326 (Site Ref. SR/004/012) included within your
Authority’s Candidate Sites Register of December 2018, making best use of available land that is mostly
already allocated and indeed, already consented for housing. Planning Layout ref. 09-012/05 REV E
enclosed, showing a detailed layout for a total of 336 dwellings, was first submitted with outline
application ref. E/21663 on 20 August 2009; and demonstrates that enlarging the site’s allocation ref.
PrC3/h4 to match the boundaries of Candidate Site ref. CA0326 (Site Ref. SR/004/012) could be
achieved without any harmful impacts upon the locality – the enlarged allocation would be contained
in the landscape and by retained woodland in my client’s ownership; and would be integrated with the
289 dwellings already consented under the terms of outline consent ref. E/38686. In this regard, please
refer to the enclosed Landscape Masterplan ref. SP17000 10A, which was also first submitted with
outline application ref. E/21663 on 20 August 2009.
Furthermore, enlarging allocation ref. PrC3/h4 to yield circa 80 additional dwellings over and above the
‘committed’ 289 dwellings that are already consented on the site would avoid the need to make an
equivalent housing allocation elsewhere in the County. As such, my client requests that housing
allocation ref. PrC3/h4 in Policy HOM1 of the 2nd Deposit Revised LDP is confirmed for circa 330
dwellings, using the boundaries of Candidate Site ref. CA0326 (Site Ref. SR/004/012) contained within
your Authority’s Candidate Sites Register of December 2018.

I hope you will find this letter and the enclosed helpful and that you will take account of and act upon
my client’s representations when progressing the 2nd Deposit Revised LDP. I would be grateful if you
would keep me updated with the LDP’s progress and in the meantime, please contact me if you have
any queries with this letter, or if you need to discuss any matter in more detail.
I look forward to hearing from you in due course.

We are instructed by Mr. M. Thomas to make a formal representation in relation to the
settlement of Cross Inn within the Second Deposit Draft of the Carmarthenshire Local
Development Plan.
Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/166/005, seeking the inclusion of their land within the development limits of Cross Inn as
part of the Replacement Local Development Plan.
The Council published a First Deposit Draft of the Replacement Local Development Plan in
January 2020. At that time, the Council revealed its analysis of a new “Settlement
Framework” as referred to within Policy SP3 “Sustainable Distribution – Settlement
Framework”, which categorised settlements in the County into Clusters and subsequently
into Tiers. We note that the Candidate Site Register has distinguished Cross Inn (SR/166)
as a separate settlement from Laugharne (SR/075) for the purposes of assessment of
representations. “Cross Inn” is accordingly listed as a Tier 4 “Rural Village”
The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission. We note that
our client’s land was considered as part of this process and as a result the Authority
concluded as follows: “The site is within a Tier 4 settlement and therefore any site proposal
will be considered under policies set out within the revised LDP.”

We note that Cross Inn continues in the Second Draft to be categorised as one of the Tier 4
“Rural Villages”, under Policy SP3. It forms one of a number of Rural Villages named, and
reproduced below, within “Cluster 6 – Western Carmarthenshire.”

Policy HOM3 of the Deposit Draft deals with small extensions to existing rural villages and
so provides a useful series of criteria in determining where such extensions would be
acceptable, namely the following:
• Minor infill or a small gap between the existing built form; or
• Logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
• Conversion or the sub-division of large dwellings.
Our clients land lies as part of the small holding of Parson’s Leys and is noted for fronting
the southern flank of the A4066 St. Clears to Laugharne main road, as shown below as
edged in red upon the location plan at Figure 1. It is notable that the opposite, northern flank
of the road is conspicuous by a continuous built-up frontage of individual residential
properties, all orientated to front the road. Parson’s Leys Cottage lies to the immediate
eastern side of the field frontage, and the main farmhouse and compacted range of holiday
cottages lie to the south off a separate vehicular driveway access. Established woodland lies
bordering the western perimeter of the field frontage.
The field frontage accordingly lies as an ideal small-scale residential opportunity to provide a
“logical extension / rounding-off to the development pattern that fits in with the character of
the village form and landscape” as required above under the provisions of Policy HOM3.

Our client has therefore given careful consideration to the categorisation of Cross Inn as a
Tier 4 “Rural Village”, and accordingly wholeheartedly welcomes and supports the decision
of the Authority to include the village in those settlements listed under Tier 4 within Cluster 6
of the Carmarthenshire Local Development Plan.

see attachments

Policy SP1: Strategic Growth
We support Policy SP1 which includes provision for 9,704 new homes to meet the identified housing requirement of 8,822 and consider this to be an achievable level of growth for the County.
We would reiterate the importance of enabling appopriate levels of growth in smaller sustainable villages, such as Pendine, in addition to larger key settlements, to ensure these housing targets for the Plan period can be achieved.

Policy SP3: Sustainable Distribution – Settlement Framework
The categorisation of Pendine as a ‘Tier 3 Sustainable Village’ within the Settlement Framework is supported. We agree that locations in this tier are
suitable for housing allocations, as per paragaph 11.74 of the Written Statement. In terms of the distribution of growth in Carmarthenshire, we support the notion at
paragraph 11.72, which recognises that much of the County is rural and housing is needed in these locations, not just in the larger top tier settlements. Accordingly,
the Plan should enable and encourage incremental growth of smaller sustainable villages, such as Pendine, to support their local population and economy.
Increased housing supply should be supported in locations where people already live, to ensure that local people have the opportunity to buy homes and continue to live in these areas, rather than needing to move elsewhere within or outside the
County. This will be crucial to address one of Carmarthenshire’s key issues: ageing population and out-migration of younger and working age people.

Policy SD1: Development Limits
We wholly support the alterations proposed to the development limit boundary of Pendine, which now includes Curtilage of Nieuport Farmhouse (Candidate Site Ref: SR/126/004); the western part of Land adjacent to Crofters Rest (Candidate Site Ref: SR/126/001); and a small area of Land rear of St Margarets Park (Candidate Site Ref: SR/126/002), to form a slightly larger housing allocation at Nieuport Yard (ref: SuV61/h1).
The inclusion of these sites ensures that the organic growth of Pendine can be supported through deliverable, viable and policy-compliant housing schemes,
which will contribute towards meeting the RLDP’s objectives. The above sites (as well as additional adjacent land) lie within the ownership of the site promoter, Mr T. Pearce, and represent logical extensions to the existing built form of Pendine. We
therefore support that these sites present valuable opportunities for a suitable level of growth within this ‘sustainable village’ (Tier 3 as per Policy SP3).
Notwithstanding the above, we propose that the development limit should be extended further to also include the remaining part of Land adjacent to Crofters
Rest, to encompass the full site as per the candidate site submission originally submitted in 2018 (ref: SR/126/001). Inclusion of the full extent of the Land adjacent to Crofters Rest presents an opportunity to provide a modest amount of additional housing. The site is also entirely within the site promoter’s ownership, thereby eliminating any land ownership constraints to delivery. The total site is a rectangular parcel of land comprising approximately 0.5ha, which is currently arable/general agricultural land. The site is relatively free from physical constraints, with a flat topography. There is
an existing hedgerow bounding the site to the north, separating the site from the B4314 road. Other than this hedgerow, the site is free from other landscape
constraints. The site is not subject to any statutory nature conservation or archaeological designations, nor tree preservations orders. The site does not lie
within a defined flood plain (TAN 15 Development Advice Maps). We note that the site is located within a Special Landscape Area, however so is the majority of the built settlement of Pendine. Considering this, together with the
partial inclusion of the site within the amended development limits, the landscape designation is not considered to unacceptably constrain the future development of the whole site at Crofters Rest.
As demonstrated for the western part of the site (now proposed to be included within the settlement) the access track off B4314 can suitably be extended
eastwards to accommodate further housing. Inclusion of this land would represent a logical extension to Pendine that would provide symmetry with the existing
housing located immediately north of B4314 (detached bungalows) yet would not extend the built settlement any further eastwards than the existing situation to the
north. The site lies in close proximity to existing residential development in Pendine and
is therefore assumed to be capable of providing appropriate services and utilities
connections. In our view, the extension of the development limit to include the remaining land
adjacent to Crofters Rest within the forthcoming LDP, represents a viable and deliverable opportunity to provide an appropriate range and choice of housing to
meet small scale additional growth within Pendine. The allocation of the full extent of the site would also provide additional flexibility as to the size and range of units
that could be offered on site, to meet local demand in a sustainable manner.

Policy HOM1: Housing Allocations
In particular, we support the allocation of site ref: SuV61/h1 - Land at Nieuport Yard, for the delivery of 10 units. Part of the site already benefits from an
implemented planning permission for 5 units (planning permission ref: 2/21251).

Policy HOM2: Housing within Development Limits
We support Policy HOM2, which notes that whilst sites capable of delivering 5 or more dwellings are allocated for housing, there are smaller unallocated sites within
the settlement limits throughout the County which may be available for the delivery of small scale housing development. We support that proposals on such sites
should be permitted provided they accord with the relevant RLDP policies. Policy AHOM1: Provision of Affordable Homes We support the RLDP objectives for delivery of affordable housing in meeting the
needs of Carmarthenshire. We note that on-site AH contributions will be sought on developments of 10 or more dwellings, based on a percentage that rises
incrementally depending on the total number of dwellings proposed. Policy AHOM1 states that: “The affordable housing target percentage noted is a target
to be used as a starting point for affordable housing negotiations.” We would agree that among other considerations, viability should be taken into account when negotiating the amount of affordable housing contribution that should be sought for
any given scheme, to ensure the deliverability of market housing schemes.Policy AHOM1 also notes that: “Where adjacent and related residential proposals
result in combined numbers meeting or exceeding the above thresholds, the council will seek an element of affordable housing based on applying the above
target percentages to the aggregate number of dwellings.” Again, we would reiterate that this policy should be applied with careful consideration of the overall
viability of housing developments between the LPA and developers.

Policy SP16: Climate Change
We support this policy and recognise the importance of the Council’s wider goals to address climate change, including reducing greenhouse gas emissions.
However we would suggest that, in terms of Policy SP16, the design requirements for small-scale housing developments should be no more onerous than the
relevant Building Regulations requirements, in order to ensure that proposals remain deliverable and viable to meet the identified housing need over the Plan period.

Introduction

Persimmon Homes West Wales write to submit these representations in respect of the current Carmarthenshire Deposit Local Development Plan (2018 to 2033) (“Deposit Plan”) consultation. As the Council will be aware, Persimmon Homes West Wales are actively promoting two additional candidate sites for residential allocation in the Deposit Plan, both of which have Option Agreements in place:

Land off Church Road, Gorslas (SR/067/002)
This submitted site is 2.7 hectares of undeveloped land, located to the north of Gorslas.

Land at Fforest Road, Fforest (SR/069/003)
Two options have been submitted for the site. The first forms 15.24 hectares and the second 4.5 hectares of undeveloped land which is situated directly adjacent to the eastern boundary and settlement building line of Fforest. Part of the site is allocated for housing in the adopted Carmarthenshire Local Development Plan (Site T3/7/h8).

Promotional documents were submitted as part of the candidate site submission which provide a full overview of each site.

Persimmon Homes are currently within the planning application process and delivering units on a number of sites which are detailed in the Deposit Plan – of which are relevant commentary on these is provided below.

This letter focuses on the key concerns with the Deposit Plan and overall housing strategy, reflecting on each matter with regard to the ‘tests of soundness’, to ensure compliance with the requirements of the Planning and Compulsory Purchase Act 2004 and Planning Policy Wales 11 (PPW 11) (February 2021).

Soundness
The fundamental requirement for a Local Development Plan to be sound is prescribed in the Planning and Compulsory Purchase Act 2004. With regard to the ‘tests of soundness’, whilst there is no statutory definition of ‘soundness’ the Development Plans Manual (Edition 3) (March 2020) advises that the following criteria should be considered:

Test 1. Does the plan fit?
Test 2. Is the Plan appropriate?
Test 3. Will the Plan deliver?

Policies and comments

Persimmon Homes West Wales raise concern regarding the Plan Period, noting that if adopted in 2024 as targeted, the Plan will effectively only cover a relatively short Plan Period Post Adoption of 10 years. It is considered a more proactive approach would be to Plan for a 15 year period from the point of adoption to allow for greater certainty over the longer-term (particularly if a future LDP is likely to suffer from such delays and to align the Plan with Future Wales: the National Plan (2040). Such an approach would call for the allocation of additional sites to meet the housing need for the extended Plan Period.

The Deposit Plan as currently drafted fails Test 1 and 3 in terms of the current Plan Period, with regard to the effectiveness of the Plan Period and the need to fit with other plans and policies. We consider a 15 year plan period from the anticipated point of adoption should be implemented and additional residential site allocations which are available and deliverable should be allocated to meet housing need (Church Road, Gorslas and Land at Forest).

SP3: Sustainable Distribution – Settlement Framework
SP3 directs the provision of growth and development to sustainable locations. This takes a 4 tiered approach in terms of the settlement framework. These include the principal centres, the service centres, sustainable villages and rural villages. The principal centres remain as Carmarthen, Llanelli and Ammanford/Cross Hands, which includes Gorslas, where the majority of development will be directed. Fforest/Hendy is defined as a Service Centre in Cluster 2 where 15-20% of development will be directed. We support the provision of Housing Allocations in Principal Centres and Service Centres

As part of the review process, Persimmon Homes are promoting the inclusion of sites SR/069/003 (Option 1 and 2) in Fforest and SR/067/002 in Gorslas in the Deposit Plan.

It is considered that the future development of the residential sites at both Gorslas and Fforest (option 1 and 2) which have been submitted as Candidate Sites would be coherent and consistent with the Local Development Plan vision, objectives, preferred strategy and Deposit Plan Policies.

SP4: A Sustainable Approach to Providing New Homes
This Deposit Plan proposes to use the ten-year based projection from Turley’s Housing and Economic Growth Report and utilise the Council Tax vacancy rate of 3.8% to underpin the future growth requirements for this revised Deposit LDP. This results in the following for the plan period:
- Projected population change between 2018-2033: +14,468
- New homes requirement: + 588 per year
- New Homes requirement during the plan period: 8,822
- Jobs creation value per annum: +276

This will result in 13 units less over the plan period from the original Deposit Plan which was consulted upon.
This Deposit Plan’s strategic policy (SP1) outlines the LDP will provide for the future growth of a sustainable economy and housing requirement through the provision of:
- 9,704 new homes to meet the identified housing requirement of 8,822 with a 10% flexibility allowance.
- The focus on regeneration and growth reflects the Council’s core strategic ambitions with development distributed in a sustainable manner consistent with the spatial strategy and settlement framework.

This will result in 456 less new homes in the plan period from the original Deposit Plan which was consulted upon. A more ambitious housing requirement would facilitate the economic growth required in the county and will be more effective in achieving the Council’s vision and objectives. Persimmon Homes considers that the plan lacks ambition in regards to the housing numbers.

The removal of the 5 year housing land supply policy within PPW 11 and TAN 1 and the replacement with the housing trajectory approach to monitor the delivery of LDP housing requirements, places even greater importance on ensuring that the housing trajectory is credible and realistic and it is critical that the housing allocations proposed in emerging Local Development Plans are appropriately and robustly evidenced to ensure that they are realistically deliverable.

Planning Policy Wales Edition 11 sets out the land use planning policies of the Welsh Government with its primary objective being to ensure that the planning system contributes towards the delivery of sustainable development and improves the social, economic, environmental and cultural well-being of Wales.

PPW 11 states that the ‘planning system must:
- Identify a supply of land to support the delivery of the housing requirement to meet the differing needs of communities across all tenures;
- Enable provision of a range of well-designed, energy efficient, good quality market and affordable housing that will contribute to the creation of sustainable places; and
- Focus on the delivery of the identified housing requirement and the related land supply’.

‘The supply of land to meet the housing requirement proposed in a development plant must be deliverable. To achieve this, development plans must include a supply of land which delivers the identified housing requirement figure and makes a locally appropriate additional flexibility allowance for sites not coming forward during the plan period. The ability to deliver requirements must be demonstrated through a housing trajectory. The trajectory should be prepared as part of the development plan process and form part of the plan. The trajectory will illustrate the expected rate of housing delivery for both market and affordable housing for the plan period. To be ‘deliverable’, sites must be free, or readily freed, from planning, physical and ownership constraints and be economically viable at the point in the trajectory when they are due to come forward for development in order to support the creation of sustainable communities’.

‘As part of demonstrating the deliverability of housing sites, financial viability must be assessed prior to their inclusion as allocations in a development plan. At the ‘Candidate Site’ stage of development plan preparation land owners/developers must carry out an initial site viability assessment and provide evidence to demonstrate the financial deliverability of their sites. At the ‘Deposit’ stage, there must be a high level plan-wide viability appraisal undertaken to give certainty that the development plan and its policies can be delivered in principle, taking into account affordable housing targets, infrastructure and other policy requirements’.

Flexibility Allowance
The flexibility allowance in terms of housing numbers is to be included in a Plan to ensure it will remain effective in the event of changing circumstance such as non-delivery of key sites and / or other unforeseen issues. The Development Plan Manual indicates that a 10% flexibility allowance should be the starting point in terms of housing provision. Persimmon Homes West Wales are of the view that the appropriate rate should be set based on local circumstances. We consider that a greater level of flexibility should be allowed for in the Plan to increase the change of meeting the housing needs of the County. Such a flexibility allowance will assist in overcoming uncertainties regarding housing deliverability and viability and would also allow additional flexibility given the shorter time period on which the Plan is proposed (10 years from adoption). The provision of 15% flexibility would increase the housing supply to 10,145 and increase the allocated plots by 441 dwellings.

Site Allocations
Persimmon Homes supports the allocation of the Strategic Site at Carmarthen West and would like to provide confirmation that as one of the largest house builders in West Wales, we are currently going through the Planning Application and Design process for 343 dwellings on Carmarthen West and are also actively working to obtain an Option Agreement for an additional 300 units. The site is considered deliverable and viable and we therefore support the inclusion of the site in the Plan under reference PrC1/MU1.

Persimmon Homes supports the allocation of Dafen East Gateway for the delivery of housing under reference PrC2/h23. We are currently within the Planning Process for the development scheme and intend to begin construction on site as soon as we are able. We are confident that the development site will be delivered in line with the Housing Trajectory as set out in the Deposit Plan. In regards to this allocation, the site is currently 20% affordable housing with the planning application complying with this policy level, we therefore request that the affordable housing requirement is reduced from 30% (which does not fall in line with AHOM1 at 25%) to the current level of 20%.

AHOM1: Affordable Housing
Persimmon Homes West Wales Object to the nature of the Affordable Housing Provision Policy AHOM1. The changes to the Affordable Housing percentages at a blanket of 25% on sites which are over 101 plots does not consider the changes in viability and locality of a site across the County Council area.

If you require any further information on the above or would like to discuss any points, please do not hesitate to contact me.

Further to the publication of the above document, we have been asked by our Client to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the
proposed provisions of Policy HOM3 are of particular interest to our Client and indeed the
Community they form part of. As a result, we offer the following for the Authority’s
consideration, and Inspector’s in due course.

Policy HOM3 – Homes in Rural Villages
It is clear that Policy HOM3 seeks to rectify the deficiency of previous Development Plans
and their policies when it comes to addressing the housing needs and requirements of all
members of a rural community, in addition to those in direct social housing need. In order to
sustain, preserve or recover a community’s level of sustainability, it is vital that provision for
new housing is made available for all its members, irrespective of their social or economic
backgrounds. This then ensures a positive balance within such communities that will secure
their sustainability for the future, as under-provision of new housing in such settlements has
been a key factor in the decline and removal of many key community facilities (e.g. schools)
within them during previous Plan periods. It is considered that Policy HOM3, by in large
therefore, now makes a significant move towards ensuring that local planning policy in
Carmarthenshire goes some way to assist in securing this objective.

Notwithstanding the above, such rural communities and the settlements they relate to or
revolve around are somewhat smaller than established satellite villages and their associated
larger towns. Growth is therefore needed, but in a controlled manner to preserve
environmental aspects of a geographic area. Again, we and our Client welcome Policy
HOM3 criteria related aspects that allow, but at the same time control, growth of the related
Rural Villages. We also welcome that such growth should be limited to take place in the
following circumstances:

 Minor infill or a small gap between the existing built form; or
 Logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
 Conversion or the sub-division of large dwellings.

Support is therefore offered to the principle for supporting growth set out in Policy HOM3,
although concerns are raised with regards to the proposed level and calculation of the ‘cap’
set out within its provisions, and this is the subject of a separate representation.

Rural Village – Maesybont
The inclusion of Maesybont as a Rural Village of Cluster 3 is both welcomed and supported.
Maesybont is located at a sustainable location, being close to a number of community
facilities and local services it and surrounding settlements benefit from. It also has good
access to nearby larger settlements that contain a wider range of local services and
community facilities. Its position on a regular bus service route also further contributes to its
sustainability level and as a suitable location for further housing development to serve the
immediate rural community.

In addition to the above, we would highlight that our Client’s land (edged red in Plan A)
represents one such opportunity for new housing development and being well related to the
existing form of the village, it would represent a logical round-off opportunity (as supported
by Policy HOM3) in the settlement.

Plan A

On behalf of our Client, we therefore fully support the designation of Maesybont as a Rural
Village under the provisions of Policy HOM3 capable of accommodating further open market
housing development following the adoption of the Carmarthenshire Local Development
Plan.

We are instructed by Mr M. Baggott to a make a formal representation to the “soundness” of
the Second Deposit Draft of the Carmarthenshire Local Development Plan.
Our client made a formal Candidate Site Submission in August 2018, which was referenced
SR/037/003, seeking the inclusion of the land within the defined development limits of
Cwmdwyfran as part of the Replacement Local Development Plan. The Candidate Site
sought frontage development of detached bungalows off the eastern flank of the A484 road
in the village, to mirror established development off the western flank of the road. Further
residential development lies immediately south of the site, and on the same, eastern flank of
the main road.
The northern extent of this field frontage is terminated by the physical presence of the Gwili
Valley Railway line which runs parallel to the rear of the frontage field and tapers to its
northern extremity, reducing its depth back from the highway to a level where no built
development can continue. It therefore represented a logical opportunity for rounding-off
within the settlement and providing a much-need and deliverable residential opportunity
which can generate a small number of modest bungalows. Its extents are illustrated by the
site edged in red, being a site location plan, at Figure 1 below.
The Council published a First Deposit Draft of the Replacement Local Development Plan in
January 2020. At that time, the Council revealed its analysis of a new “Settlement
Framework” as referred to within Policy SP3 “Sustainable Distribution – Settlement
Framework”, which categorised settlements in the County into Clusters and subsequently
into Tiers. We note that the Candidate Site Register has distinguished Cwmdwyfran
(SR/037) as a separate settlement from Bronwydd (SR/014) for the purposes of assessment of representations. “Bronwydd” is accordingly listed as a Tier 3 “Sustainable
Village.” “Cwmdwyfran” was not listed, and neither was it listed as a Tier 4 “Rural
Village”. However, the First Deposit Draft LDP proposed settlement limits about the physical
form of Cwmdwyfran.
The Second Deposit Draft has been published in January 2023, and we note that in
response to our client’s formal representation under the First Deposit Draft consultation
process, the Council have reverted their decision, and now named “Cwmdwyfran” as a Tier 3
settlement. Defined settlement limits are shown upon the Proposals Map and encircling the
existing built development in the village. Our client’s Candidate Site is shown excluded from
those draft settlement limits.
The Council have again published a “Site Assessment Table” (January 2023). We note at
this time that our client’s land was considered as part of this process and as a result the
Authority concluded that the site had successfully passed through Stage 1 (site compatible
against the location of future growth presented in the Preferred Strategy), and Stage 2A
(Initial Detailed Site Assessment). However, the Council failed the submission under
consideration of Stage 2b (Further Detailed Site Assessment). The Council reported its
conclusions as follows: “Development of the site would result in a ribbon pattern of
development changing the character of the area.”

We consider that omission is tantamount to the LDP being “unsound” and should be
changed, as it fails to meet the tests for “soundness,” in that the Plan “is not appropriate,” as
defined by the Planning Inspectorate’s LDP Examinations Procedural Guidance.
Specifically, we consider the approach of assessment taken by the Authority to such a
categorisation has been inconsistent in terms of (a) other policy approaches taken by the
Deposit LDP and (b) in relation to other Rural Village named as Tier 4 settlements within
the Carmarthen Cluster. We submit that Cwmdwyfran should not therefore be afforded
defined development limits within the Deposit LDP and accordingly be named as a Tier 4
“Rural Village”. We consider therefore that the settlement should be included within the
settlements listed under Tier 4, AND NOT TIER 3, under the provision of Policy SP3 of the
Carmarthenshire Local Development Plan.
This formal representation letter supplements the following documents which comprise a
complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form

Reasons for Representation to Deposit Draft

Consistency with Other Policies of the Deposit LDP
The Authority has provided no specific indication or guidance on how it has determined and
defined development limits within the Deposit LDP. It has therefore been difficult to ascertain
why some sites have been successfully included and others have not. Policy SP3 defines
Tier 3 “Sustainable Villages” as being distinct those where settlement limits are defined and
Paragraph 11.73 states “the settlement framework will, in conjunction with specific policies,
also guide the consideration of appropriate sustainable locations - with access to services
and facilities - and scale of other developments.”
The following paragraph (11.74) indicates that Policy SP3 “sets out an indicative outline on
the nature of development likely by tier including their scale and type.”
Tier 3 “Sustainable Villages” are identified and will possess –
Housing Allocations
Affordable housing on sites of 5 or more units
Small housing sites (under 5 homes).
Windfall housing opportunities
Small Scale Rural Exceptions Schemes for Affordable Housing adjoining settlement
boundaries
This is in contrast to Tier 4 “Rural Villages”, which are defined to contribute by means of:
Small sites – housing through infill or logical extensions/rounding off.
Small Scale Rural Exceptions Schemes for Affordable Housing
However, Policy HOM3 deals with small extensions to existing rural villages and so provides
a useful series of criteria in determining where such extensions would be acceptable, namely
the following:

Minor infill or a small gap between the existing built form; or
• Logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
• Conversion or the sub-division of large dwellings.
It is logical therefore that the same assessment criteria should be utilised in assessing
whether or not development would be acceptable in Cwmdwyfran, as at present the draft
settlement limit is so tightly drawn that it prohibits any development of even a single dwelling
which would make an acceptable addition to existing development limits.
Cwmdwyfran is now categorised as a Tier 3 settlement but there is no available,
undeveloped, or “white land” within the defined settlement limits to allow for a “housing
allocation”, nor “Affordable housing on sites of 5 or more units,” “Small housing sites (under
5 homes)” and finally any possible “Windfall housing opportunities.”
It other words, Cwmdwyfran does not possess any of the identifications or definitions
of a Tier 3 settlement.
Consistency with Other Tier 4 Settlements

Consistency in approach and application is critical in order for the planning system to be
both effective and credible to all its users. Without it, the system itself becomes unsound and
in the case of the determination of the development limits for Cwmdwyfran, the Authority has
been found to be inconsistent. Cluster 1 “Carmarthen” defines which settlements will not be
afforded settlement limits, but small scale, minor growth is adjudged acceptable in line with
criteria provided in Policy HOM3. The named Tier 4 settlements are listed overleaf.

Figures 3 & 4 below are extracts of the Second Deposit LDP Proposals Map of two of those
settlements, being equivalent in scale to Cwmdwyfran with some 30 or so dwellings –
namely Pontantwn and Whitemill. Like Cwmdwyfran they are located upon primary A roads
linked to Local Service Centres but are notably defined as Tier 4 settlements.

As can be seen, two separate settlements, each with multiple numbers of houses- circa 30
units, have been categorised as Tier 4 settlements and thus will be allowed to expand in
minor proportions of up to an additional 10% of the total number of dwellings from the
Plan base date, provided those proposals constitute infilling or rounding off.
We submit that Cwmdwyfran is comparable with these two examples, if not all the 17
villages listed in Cluster 1 as Tier 4 settlements. However, the Authority’s reverted decision
to classify Cwmdwyfran now as a Tier 3 settlement is perverse. The Village resembles those
listed Tier 4 Rural Villages in that it also does not possess any community facilities, such as
primary school, convenience shop / post office, public house or village / community hall. The
tight setting of draft limits at Cwmdwyfran is such that NO Development or minor housing
growth is achievable for the next 10 years. This decision represents a clear inconsistency in
approach taken by the Authority, resulting in the Plan as it stands being unsound.
In conclusion, we submit that the draft settlement limits for Cwmdwyfran be omitted from the
Deposit Draft of the Revised LDP, and that the village be added to those settlements listed
under Tier 4 within Cluster 1 of the Carmarthenshire Local Development Plan to ensure that
the document passes all the relevant tests of soundness.

Further to the publication of the above document, we have been asked by our Client to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the
proposed provisions of Policy HOM3 are of particular interest to our Client and indeed the
Community they form part of. As a result, we offer the following for the Authority’s
consideration, and Inspector’s in due course.

Policy HOM3 – Homes in Rural Villages
It is clear that Policy HOM3 seeks to rectify the deficiency of previous Development Plans
and their policies when it comes to addressing the housing needs and requirements of all
members of a rural community, in addition to those in direct social housing need. In order to
sustain, preserve or recover a community’s level of sustainability, it is vital that provision for
new housing is made available for all its members, irrespective of their social or economic
backgrounds. This then ensures a positive balance within such communities that will secure
their sustainability for the future, as under-provision of new housing in such settlements has
been a key factor in the decline and removal of many key community facilities (e.g. schools)
within them during previous Plan periods. It is considered that Policy HOM3, by in large
therefore, now makes a significant move towards ensuring that local planning policy in
Carmarthenshire goes some way to assist in securing this objective.

Notwithstanding the above, such rural communities and the settlements they relate to or
revolve around are somewhat smaller than established satellite villages and their associated
larger towns. Growth is therefore needed, but in a controlled manner to preserve
environmental aspects of a geographic area. Again, we and our Client welcome Policy
HOM3 criteria related aspects that allow, but at the same time control, growth of the related
Rural Villages. We also welcome that such growth should be limited to take place in the
following circumstances:

 Minor infill or a small gap between the existing built form; or
 Logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
 Conversion or the sub-division of large dwellings.

Support is therefore offered to the principle’s for supporting growth set out in Policy HOM3,
although concerns are raised with regards to the proposed level and calculation of the ‘cap’
set out within its provisions, and this is the subject of a separate representation.

Rural Village – Pentregwenlais

The inclusion of Pentregwenlais as a Rural Village of Cluster 3 is both welcomed and
supported. Pentregwenlais is located at a sustainable location with good access to nearby
larger settlements that contain a wide range of local services and community facilities.

Access to these is possible by non-motorised means and the village is also positioned on a
regular bus service route, giving it good access to further settlements of the County and their
associated facilities and services. Its sustainable location therefore merits its designation as
a Rural Village to enable it to facilitate further housing development to serve the immediate
rural community.

In addition to the above, we would highlight that our Client’s land (edged red in Plan A and
circled in Photograph 1) represents one such opportunity for new housing development and
being well related to the existing form of the village, it would represent a logical extension
opportunity (as supported by Policy HOM3) in the settlement.

Plan A

Photograph 1

On behalf of our Client, we therefore fully support the designation of Pentregwenlais as a
Rural Village under the provisions of Policy HOM3 capable of accommodating further open
market housing development following the adoption of the Carmarthenshire Local
Development Plan.

1. Introduction
1.1. Pegasus Group is instructed by the Co-operative Group (the ‘Co-op’) to submit
representations to the Carmarthenshire Second Deposit Revised LDP consultation.
1.2. The Co-op own a Site referred to as ‘Land south of Penygroes Road, Gorslas’ (the ‘Site') and
are promoting the Site for residential development. A copy of the Site Location Plan is
enclosed with a copy of these representations (Appendix 1) and the extent of the land is
shown below:
1.3. The Site comprises an area of c. 6.5ha and is considered to be capable of accommodating
approximately 120 dwellings.1
1.4. A call for sites form was submitted to the Council in August 2019 by Pegasus Group on behalf
of the Co-op. A copy of this submission is also appended to these representations
(Appendix 2).
1.5. Representations were submitted to the Deposit LDP in March 2020 and these are
resubmitted here and amended as necessary. The Site has not been included as a candidate
site in the Second Deposit Revised LDP and we consider that it should be included as a
residential allocation for the reasons given in these representations.
1 Assuming 30dph on 60% of the site.
R002 | CE | April 2023 2
Executive Summary
1.6. These representations respond directly to the following policies and paragraph references,
as set out in the Second Deposit Revised LDP:
 Preferred Spatial Option (Chapter 8);
 Paragraph 8.20;
 A New Strategy (Chapter 9);
 Policy SP1: Strategic Growth;
 Policy SP3: Sustainable Distribution – Settlement Framework;
 Policy SP4 – A sustainable Approach to Providing New Homes; and
 Policy SD1: Sustainable Distribution - Development Limits.
1.7. Our comments on the above policies would support a higher quantum of growth to the Tier
1 settlements in the interests of making the plan more effective in delivering its key aims and
more appropriate in terms of delivering sustainable development and mitigating its impact
on climate change.
1.8. This will, in turn, require the identification of additional sites for housing at these settlements
and we consider that the Site should be allocated for residential development as part of this
process, based on the updated sustainability appraisal we have undertaken using the
Integrated Sustainability Appraisal (ISA) template provided for developers. This
demonstrates that the Site is a sustainable, deliverable and logical location for housing.
R002 | CE | April 2023 3
2. Preferred Spatial Option (Chapter 8)
2.1. Paragraph 8.20 sets out the preferred Spatial Option and is unchanged from the Deposit
Draft LDP. The Option is stated as being a hybrid of a Balanced Community and Sustainable
Growth Strategy. The Spatial Option acknowledges the need to recognise and reflect
investment/economic benefits and opportunities, seeks to be community led, and will aim to
allocate development in a sustainable way.
2.2. Whilst we are broadly supportive of the preferred Spatial Option, we feel that it needs to be
more explicit in stating that the strategy needs to align with the ambitious economic
aspirations of the plan.
2.3. At present, we do not feel that this is reflected in the proposed Spatial Option and, therefore,
it has not been fully justified in the context of the Council's economic growth ambitions.
2.4. We would stress that this does not require wholesale changes to the proposed Spatial Option
as this could still be community led and the delivery of sustainable development should be
at the heart of all Plan strategies. However, we would wish to see it reflect the Council's
ambitious economic growth aspirations and acknowledge that this will influence the spatial
distribution of development.
R002 | CE | April 2023 4
3. A New Strategy (Chapter 9)
3.1. We are broadly supportive of the Plan's ambitions to deliver economic growth and an uplifted
housing requirement to support this. However, the perceived reduced importance of
delivering the Council's ambitious economic growth targets within the Preferred Spatial
Option has manifested in what we consider to be an ineffective Plan Strategy.
3.2. This is because the Second Deposit Revised LDP seeks to take a balanced approach to the
distribution of housing supply (paragraph 9.4), despite the fact that it will be reliant on only
a few key centres to deliver the vast majority of the economic growth it aspires to (namely,
Llanelli, Ammanford/Cross Hands and Carmarthen).
3.3. We accept that growth will need to come forward at all levels of the settlement hierarchy
(including rural areas) to support the vitality and viability of the diverse communities across
the county. However, the Plan's focus on delivering economic growth and a balanced
approach to the distribution of development are unlikely to be an effective combination in
meeting the plan's aspirations.
3.4. The plan acknowledges that the Tier 1 settlements are the strongest economic drivers from
a market demand and delivery perspective and states that they will receive an "appropriate
proportion" of the anticipated growth. However, this should be quantified within the plan
(which it is not at present) alongside the level of housing and other types of development
needed to be delivered in conjunction with it.
3.5. The Plan Strategy needs to be more realistic in acknowledging that it cannot rely on lower
order settlements and rural areas to deliver the economic growth it aspires to and that the
Tier 1 settlements will likely need to play a greater role than is currently identified.
3.6. It also needs to acknowledge that employment sites will only come forward where they have
access to good services, facilities and infrastructure. Furthermore, they will also need to be
accessible for the local/regional labour market.
3.7. It is, therefore, essential that the Plan identifies the supporting development and
infrastructure that needs to be delivered alongside employment sites in order to stimulate
investment and economic growth. The plan currently fails to do this, and this has resulted in
deficient policies which are discussed further below.
R002 | CE | April 2023 5
4. Policy SP1: Strategic Growth and Policy SP4: A
Sustainable Approach to Providing New Homes
4.1. As stated above, we support the Council's decision to deliver a higher quantum of dwellings
over the plan period to align with the Council's economic growth ambitions. We support the
proposed 10% flexibility applied to the housing requirement as this will provide a reasonable
(albeit not optimal) level of flexibility to improve the prospects of meeting the minimum
housing requirement.
4.2. However, we question why this has been reduced from the 15% flexibility applied in the First
Deposit Revised LDP. This is particularly important in the context where one of the reserve
sites under Policy SG2 has been removed.
4.3. In addition, we are not convinced the distribution of housing has been properly justified in
the context of the ambition to deliver higher levels of economic growth. Our principal concern
is that the ambitions to deliver economic growth will be jeopardised by the balanced
approach to distributing growth across the county.
4.4. This has, in turn, resulted in a distribution pattern that does not appear to appreciate the
importance of the spatial relationship between employment growth and housing delivery as
they support the delivery of one another.
4.5. In simple terms, the distribution strategy does not take a realistic view of the capacity of
lower order settlements to deliver economic growth, relative to the Tier 1 settlements and
has, accordingly, failed to allocate a sufficient level of housing in close proximity to key
employment areas.
4.6. It is important for housing to be delivered in close proximity to key employment areas for a
number of reasons. Two particularly pertinent reasons are as follows:
1. It encourages commuting via alternative modes of transport to the private motor
vehicle in the interests of sustainability and mitigating impacts on climate change;
2. Housing delivery creates a critical mass and local workforce which stimulates
investment and job creation.
4.7. Policies SP1 and SP4 (including their supporting text) need to clearly justify the overall
quantum of development to be delivered at each settlement tier and then explain how it will
be distributed to support the economic aspirations of the plan, alongside its sustainability
and community aspirations. Its failure to do so at present is a significant deficiency with the
plan that needs to be addressed.
R002 | CE | April 2023 6
5. Strategic Policy SP3: Sustainable Distribution –
Settlement Framework
5.1. Policy SP3 sets out the settlement hierarchy and settlement clusters. We largely agree with
the structure and support the Ammanford/Cross Hands area being included within the first
tier – Principal Settlements.
5.2. We also agree with the assertion that growth and development will be directed to sustainable
locations in accordance with the spatial framework; however, as mentioned above, we have
some reservations with how this has been implemented.
5.3. Whilst we note that the highest proportion of development is due to be delivered at the Tier
1 settlements (a principle we support), we consider that too great a proportion of growth has
been allocated to lower order settlements. As stated above, the Plan is unrealistic in the way
it proposes to distribute growth to deliver its economic aspirations and the allocation of
housing sites to support this is also unsuitable as a result.
5.4. If the Plan is serious about delivering economic growth, sustainable development and
mitigating its impacts on the environment to combat climate change, then it needs to rethink
its distribution framework and allocate higher levels of development to the Tier 1
settlements.
R002 | CE | April 2023 7
6. Policy SD1: Development Limits
6.1. This policy states that development within the identified development of Tier 1-3 settlements
will be acceptable, provided that they accord with other relevant policies of the LDP.
6.2. Whilst there are exceptions to this rule (for example, Policy HOM6), the policy does not set
out a scenario whereby development for traditional housing can come forward beyond the
development limits. This will be problematic in circumstances where the Council's housing
delivery fails to keep pace with their proposed annual requirement.
6.3. Whilst we support the principle of identifying specific sites to meet the development needs
of the district within the LDP to guard against excessive unplanned development, Local Plans
still need to be sufficiently flexible to ensure that housing and other types of development
can come forward to meet the needs of the population. This is especially important in
situations when delivery does not match up with the plan's target levels of growth. This could
be due to any number of reasons, from deficiencies with the plan, unforeseen technical issues
affecting the delivery of certain sites or broader macro-economic factors.
6.4. We note the identification of Reserve Sites (Policy SG2) and acknowledge that this will go
some way to securing supply in the event allocated sites cannot come forward albeit one of
the reserve sites has been removed from the Second Deposit Revised LDP over the Revised
Deposit version. However, we would question whether this is a sufficiently flexible approach
that will help to guarantee the delivery of the plan's housing requirement. We note that the
delivery of a reserve site will need to be subject to a masterplanning exercise. This
requirement is something that would potentially delay its delivery and prevent it from
addressing a specific need (e.g. housing shortfall) in a timely manner.
6.5. As such, we consider that this policy should incorporate wording to allow for development in
sustainable locations that would otherwise comply with the relevant policies of the LDP in
the event that the supply and delivery of housing failed to keep pace with the Local Plan
Housing Requirement (i.e. the absence of a five-year supply of housing land).
6.6. We would suggest additional wording to the policy to make it clear to prospective applicants
when it would be acceptable to propose development on unallocated sites. This would
provide certainty and allow for windfall sites to come forward in accordance with the LDP to
meet shortfalls when they arise.
6.7. We acknowledge that the plan has attempted to plan positively for housing growth in
particular and sought to incorporate measures to secure this (10% buffer to the housing
requirement (albeit reduced from 15%) and the identification of reserve sites) over the plan
period. However, we consider that policy SD1 should incorporate additional flexibility to allow
development to come forward under certain circumstances (as specified above) in order the
ensure the plan can remain as effective as possible for its duration.
R002 | CE | April 2023 8
7. Land to the south of Penygroes Road, Gorslas,
Llanelli
7.1. As stated in the Introduction, the Co-op controls an area of land to the south of Penygroes
Road, Gorslas comprising a number of fields which cover an area of around 6.5ha and would
be capable of delivering c. 120 dwellings.
7.2. Vehicular access could be taken from the B4556 to the east with an emergency/pedestrian
access being taken from the north via an existing driveway/access.
7.3. The Site is well related to development around the 6-way junction along the A476 which is
home to a number of services and facilities that would meet the day to day needs of future
residents.
7.4. The Site is also well related to existing and future large-scale employment and commercial
development areas at Cross Hands.
7.5. The Site's proximity to these services, facilities and employment opportunities would reduce
the reliance on the private motor vehicle to meet the day to day needs of future residents
and would encourage the use of active modes of travel such as walking and cycling.
7.6. The Site is free from any land use allocation or other designations that would otherwise
constrain development; it could be made available for development in the short-term and
be built out comfortably within a five-year time frame once detailed planning permission is
granted.
R002 | CE | April 2023 9
8. Integrated Sustainability Appraisal
8.1. Our representations to the Deposit LDP in March 2020 included an assessment of the
sustainability of the Site with regard to the guidance available at that time. Since then, the
Council has published an Integrated Sustainability Appraisal (ISA) document for consultation
alongside the Second Deposit LDP.
8.2. Paragraph 1.7 of the ISA states that:
“The Council strongly advises that in responding to the Deposit rLDP, any relevant new,
site(s) proposed should be accompanied by an integrated Sustainability Appraisal
(incorporating Strategic Environmental Assessment). A site not subject to ISA is unlikely
to be considered suitable for allocation in the plan.”
8.3. As a result, we have provided an assessment of the sustainability of the Site against this
updated criteria in the below table.
8.4. As shown by our responses, the Site performs extremely well against the various elements of
the SA with only the fact that the Site is a greenfield site and may contain high carbon soils
being the only constraints affecting the Site's development.
9. Summary Representations
9.1. These representations have been submitted on behalf of the Co-op in respect of its land to
the south of Penygroes Road, Gorslas. The Co-op is promoting the Site for residential
development and consider it to be a sustainably located, deliverable and logical site for the
proposed use. The Co-op has a good track record of promoting sites for development and
working with developers and house builders to ensure that sites are sold on and deliverable.
It does not sit on sites or ‘land bank.’
9.2. Whilst we are broadly supportive of the economic aspirations of the LDP and agree with the
uplift to the housing requirement accordingly, we have reservations with the proposed
strategy to deliver this ambitions targets.
9.3. This is namely down to the following reasons:
 The Preferred Spatial Option and Plan Strategy appear to have diminished the
importance of delivering these said economic aspirations;
 They are unrealistic in their view that lower order settlements will be able to deliver the
currently proposed economic growth and role Tier 1 settlements will need to play has
been underestimated;
 There is a disconnect with the spatial distribution of employment development and
residential development and it is not clear how they will support the delivery of one
another; and
 The proposed flexibility measures notwithstanding, we consider that the plan should
include a policy to facilitate development beyond the defined settlement limits in the
case of severe plan failure.
9.4. We suspect that when the plan is reviewed in light of these issues, a higher proportion of
growth will be identified at the Tier 1 settlements and this will require additional housing
allocations to be included.
9.5. Our client's Site is available, deliverable and sustainably located. We have assessed it against
the Council's ISA template and it has performed very well with few minor issues. We would,
therefore, support a new policy allocating the Site for residential development in the final
version of the LDP.

1 General Description
1.1 This LDP Representation relates to the potential revision of the
defined settlement limits to include a new site for residential
development in the Carmarthenshire Revised Local Development
Plan 2018 – 2033.
2 LDP Representation
2.1 The statement has been prepared by Ceri Davies BA Hons, Dip UP,
MRTPI, (Director of Ceri Davies Planning Ltd). The statement is
based on information provided by the client and other consultants.
All stated dimensions and distances are approximates and based on
the best information available at the time. Please refer to the
submission plans for detailed information.
2.2 The LDP Representation details include:
• 2
nd Deposit Revised LDP Representation Form
• Location & Site Plans
• Planning Statement
3 Client Details
3.1 The client is Gwyn Lewis of Gilfach Stables, Broadway, Laugharne,
Carmarthenshire, SA33 4NS.
4 The Site
4.1 The site consists of broadly rectangular shaped piece of land which
is currently used for grazing and keeping of horses. The site lies
immediately adjacent to existing dwellings in Broadway, just west
of Laugharne.
4.2 The block of land lies on the northern flank of the A4066, between
an established row of road frontage dwellings to the east, fronting
onto the adjacent highway and a caravan park to the west. The site
represents part of a wider gap between the row of houses and the
caravan site.
4
4.3 The site fronts directly onto the A4066 and is occupies a position
below the road level. Directly opposite is arow of more recently built
dwellings on the southern flank of the A4066. There are a number
of dwellings beyond the block of land to the west.
4.5 The proximity of the site to neighbouring dwellings and its proximity
to the existing built form associated with this part of the village of
Broadway, particularly along the highway is illustrated on the map
extract below (Figure i).
Figure i – Location Plan
4.6 Whilst the site currently occupies an open countryside location, it
lies immediately adjacent to and opposite existing houses and in
close proximity to the heart of the rural village.
4.7 The actual proximity of the site to the predominantly residential
area within the village is clearly shown on the aerial photograph
below (Figure ii).
5
Figure ii – Aerial Photograph
4.7 Vehicular access into the site is currently gained via the existing field
entrance which serves the stable-block and come directly off the
adjacent public highway.
5 The Development
5.1 The aim of this representation is to challenge the removal of the
defined settlement development limits associated with Broadway
and also to challenge its designation as a Tier 4 Rural Village within
Cluster 6, as outlined in the draft Strategic Policy SP3: Sustainable
Distribution – Settlement Framework. In re-introducing the
settlement limits to Broadway and re-designating it as a Tier 3 –
Sustainable Village, this representation also seeks to incorporate
the aforementioned site, edged in red, in the said defined limits.
5.2 Both the Location and Site plans below (Figures iii and iv) illustrate
the extent of land the client considers ought to be included in the
revised settlement development limits associated with the village of
Broadway, if the said limits are to be re-introduced.
The Site
6
5.3 The built up area consists predominantly of residential dwellings
and also consists of a public house which provides a communal
place for congregating.
Figure iii – Location Plan – Suggested revised limits for Broadway
5.4 The site plan below illustrates in greater detail the extent of the land
deemed appropriate for inclusion in the revised settlement limits
for the village.
7
Figure iv – Site Plan
6 Policy Context
6.1 A review of the planning policy context associated with the site and
the proposed development (at national and local level) is provided
within this section of the Statement.
National Planning Policy
6.2 Well-Being of Future Generations (Wales) Act (2015)
6.2.1 The Act places a duty upon public bodies to produce well-being
objectives that contribute to achieving a set of overarching wellbeing goals:
• A Prosperous Wales;
• A Resilient Wales;
• A Healthier Wales;
• A More Equal Wales;
• A Wales of Cohesive Communities;
• A Wales of Vibrant Culture and Thriving Welsh Language; and
• A Globally Responsible Wales.
6.2.2 Each public body is then required to take reasonable steps to meet
their objectives in the context of the principle of sustainable
development and whilst following a set of five ways of working.
8
6.2.3 The 'Resilient Wales' and 'Healthier Wales' goals are the key goals
that open space and greenspace, as part of the planning process will
contribute towards delivering.
6.3 Planning Policy Wales : Edition 11 (February 2021)
6.3.1 Planning Policy Wales (PPW) forms the overarching national
planning policy document for Wales and sets out the land use
planning policies of the Welsh Government. It is supplemented by a
suite of Technical Advice Notes (TANs), Welsh Government
Circulars, and policy clarification letters which together with PPW
provide the national planning policy framework for Wales. The main
objective of PPW is to promote place-making and sustainable forms
of development.
6.3.2 The primary objective of PPW is to ensure that the planning system
contributes towards the delivery of sustainable development and
improves the social, economic, environmental and cultural wellbeing of Wales, as required by the Planning (Wales) Act 2015,
the Well-being of Future Generations (Wales) Act 2015 and other
key legislation. PPW and National Development Framework (NDF)
set out how the planning system at a national. Regional and local
level can assist in delivering these requirements through strategic
Development Plans(SDPs) and Local development Plans (LDPs).
6.3.3 There are a number of key planning principles indicated within
Planning Policy Wales (PPW) to achieve the right development in
the right place.
6.3.4 Paragraph 1.18 emphasises that the legislation secures a
presumption in favour of sustainable development in accordance
with the development plan, unless material considerations indicate
otherwise. The principles of sustainable development are defined in
the Well-being of Future Generations Act.
6.3.5 Paragraph 1.22 of PPW states that up-to-date development plans
are the basis of the planning system and that these set the context
for rational and consistent decision making, where they have been
prepared in accordance with up to date national planning policies.
6.3.6 These key planning principles are set out with a view to achieve a
number of national sustainable placemaking outcomes, as
9
explained in paragraphs 2.15-2.20 and outlined in Figure 4. The
national sustainable placemaking outcomes are:
People and Places: Achieving Well-being Through Placemaking
• Growing our economy in a sustainable manner
• Making best use of resources
• Maximising environmental protection and limiting environmental
impact
• Creating and sustaining communities
• Facilitating accessible and healthy environments
6.3.7 Paragraph 2.17 states “In responding to the key principles for the
planning system, the creation of sustainable places and in
recognition of the need to contribute to the well-being of future
generations in Wales through placemaking, development plans and
development proposals must seek to deliver development that
address the national sustainable placemaking outcomes”.
6.3.8 Sustainable development forms a key consideration central to all
policies contained within Planning Policy Wales (PPW). Paragraph
1.2 states: “The primary objective of PPW is to ensure that the
planning system contributes towards the delivery of sustainable
development and improves the social, economic, environmental
and cultural well-being of Wales, as required by the Planning
(Wales) Act 2015, the Wellbeing of Future Generations (Wales) Act
2015 and other key legislation.”
6.3.9 Paragraph 2.27 sets out how to assess the sustainable benefits of
development: “Planning authorities should ensure that social,
economic, environmental and cultural benefits are considered in
the decision-making process and assessed in accordance with the
five ways of working to ensure a balanced assessment is carried out
to implement the Well-being of Future Generations Act and the
Sustainable Development Principle. There may be occasions when
one benefit of a development proposal or site allocation outweighs
others, and in such cases robust evidence should be presented to
support these decisions, whilst seeking to maximise contributions
against all the well-being goals.”
10
6.3.10 Paragraph 2.17 states that “in responding to the key principles for
the planning system, the creation of sustainable places and in
recognition of the need to contribute to the well-being of future
generations in Wales through placemaking, development plans and
development proposals must seek to deliver developments that
address the national sustainable placemaking outcomes.”
6.4 Future Wales: The National Plan 2040
6.4.1 Future Wales – The National Plan 2040 is Wales’ national
development framework which sets out the direction for
development in Wales to 2040. It is a development plan that sets
out a strategy for addressing key national priorities including
sustaining and developing a vibrant economy, achieving
decarbonisation and climate-resilience, developing strong
ecosystems and improving the health and wellbeing of our
communities.
6.4.2 The spatial strategy is a guiding framework which sets out the key
national policies that will guide and encourage development which
supports sustainable growth in both urban and rural areas across
Wales.
Policy 1 – Where Wales will grow
6.4.3 Policy 1 is the overarching policy which sets out where sustainable
growth will take place in Wales. Three National Growth Areas have
been established where there will 14 be growth in employment and
housing opportunities and investment in infrastructure. The
National Growth Areas are:
• Cardiff, Newport and the Valleys;
• Swansea Bat and Llanelli; and
• Wrexham and Deeside.
6.3.4 These National Growth Areas are complemented by Regional
Growth Areas, which will grow, develop and offer a variety of public
and commercial services at regional scale. There are Regional
Growth Areas in three regions:
• The South West;
• Mid Wales; and
• The North.
11
6.3.5 In addition to the above growth areas, there are a mix of smaller
towns and villages and large areas of countryside. The policy states
that ‘development in towns and villages in rural areas will support
local aspirations and need, complementing rather than competing
with efforts to grow our cities and towns.’
Local Planning Policy
6.4 The proximity of the proposed housing allocation to the defined
settlement development limits for Broadway in the current Local
Development Plan 2006-2021 (LDP) is illustrated in the map extract
below, Figure (v).
Figure v – Proposals Map (LDP 2006-2021)

6.5 The proximity of the proposed housing allocation to the existing
village with its undefined boundaries in the 2
nd Deposit Revised
Carmarthenshire Local Development Plan (LDP) is illustrated in the
map extract below, Figure (vi).
12
Figure vi – Proposals Map (Revised LDP 2018-2033)
7 Detailed Consideration
7.1 It is asserted that the incorporation of defined settlement limits for
Broadway would be compatible with Strategic Policy SP3 of the
revised LDP which seeks to ensure the provision of growth and
development is directed to sustainable locations in accordance with
the spatial framework.
7.2 Given the close proximity of Broadway to the to the town of
Laugharne which is classed as a Tier 2 Service Centre, it is asserted
that Broadway could potentially play an important role in facilitating
any future growth which would assist in sustaining Laugharne as a
recognised service centre.
7.3 Given the well documented physical constraints associated with
Laugharne, particularly its location with a C2 Flood Zone together
with the topography of the surrounding area, evidently there is no
scope whatsoever to accommodate any further housing. The DAM
map extract below (Figure vii) highlights the extent of the flooding
hazard.
13
Figure vii – DAM Map extract (Source:NRW)
7.4 In contrast, Broadway, in occupying an elevated position is well
placed to accommodate any future residential development which
would be of significant benefit given its close links to Laugharne. The
proximity of the housing site being promoted as part of this
representation, to both Broadway and Laugharne, means ISA
Objective 1 (Sustainable Development) is satisfied in this instance.
7.5 It is asserted that the consequence of not allowing any future
housing expansion to be accommodated within Broadway would
have a negative impact on the township of Laugharne itself.
7.6 It is considered the highlighted land for potential residential
development represents a sustainable location given its close
proximity to existing housing in Broadway as well as its proximity to
Laugharne which is classed as a Service Centre in Strategic Policy SP3
of the LDP.
7.7 Natural Resources Wales Development Advice Maps indicate that
the land does not lie within a Zone C1 or C2 flood area as defined by
the development advice maps referred to in Technical Advice Note
15, Development and Flood Risk (TAN 15), as illustrated in the DAM
extract below (Figure ix).
7.8 TAN15 states that new development should be directed away from
Zone C and towards zone A, otherwise to zone B, where river or
14
coastal flooding will be less of an issue. The site is not considered to
be at risk of flooding during at least the 1 in 1000 year event.
7.9 The development advice maps supplemented by sediment data,
held by the British Geological Survey (BGS), of historical flooding.
The maps adopt a precautionary principle and are based on the best
known information available at the time. It is noted that the NRW
flood maps show the site as being flood free during the Q100 event
and Q1000 event.
Figure ix – DAM Map
7.10 The Flood Map for Planning Wales also indicates that the rear of the
land subject of this representation is at risk from localised or surface
water flooding; this is illustrated on the FMfP extract below (Figure
x).
7.11 However, the intention would be to develop along the front part of
the site as this part of the site falls outside of Flood Zone 2 and Flood
Zone 3, as such falls within and an area deemed at low flood risk
from rivers. The land will not be affected during the 1 in 1000 fluvial
(Q1000 event or 0.1% event) and would also be flood free during
the 1 in 100 (Q100) flood event.
The Site
15
Figure x – FMfP
7.12 The land does not fall within a C1 or C2 flood risk zone as delineated
by TAN15 DAM flood maps. Neither does the part of the site to be
developed fall within a Flood Zone 2 or Flood Zone 3 as delineated
by FMfP (Flood Map for Planning Wales). As such, ISA Objective 4
(Climatic Factors) and ISA Objective 5 (Water) are both satisfied in
this instance.
7.13 The land is not located within or immediately any of the following
designated sites:
• Sites of Special Scientific Interest (SSSI)
• Special Areas of Conservation (SAC)
• Special Protection Areas (SPA)
• National Nature Reserves (NNR)
• Local Nature Reserves (LNR)
• Common Land or registered village green
As such, ISA Objective 2 (Biodiversity) is satisfied in this instance.
7.14 The land is not located within or immediately adjacent to any
Scheduled Monuments. As such, ISA Objective 8 (Cultural Heritage
and Historic Environment) is satisfied in this instance.
7.15 The proposed inclusion of additional land within the redefined
settlement development limits is deemed appropriate at this
location in that it would not impact on any core planning principles.
The land would be located immediately adjacent to existing
residential dwellings, and would represent a natural rounding off
the existing built form.
Land under consideration
16
7.16 It is asserted that the addition of further residential plots would not
lead to unacceptable ribbon development as it is sited within a
defined and mature hedgerow boundary. It would not be deemed
tandem development, it would not lead to unacceptable
coalescence of settlements and it cannot be described as
unacceptable sporadic development or an unacceptable extension
to the settlement. If anything the inclusion of these house along
with the vacant plot represents a logical extension do the
settlement.
7.17 In addition it would not result in the loss of areas of public open
space or formal recreational land. Given the aforementioned, it is
asserted that the development would not be contrary to general
planning principles.
7.18 Additional residential plots would sit comfortably at this location
without having any detrimental impact whatsoever on the character
or setting of the settlement. Furthermore, the development would
not have any detrimental impact on any features of the settlement
such as landscapes, townscapes or buildings of importance as a
result of its scale, density and prominence. As such, ISA Objective 8
(Cultural Heritage and Historic Environment) along with ISA
Objective 9 (Landscape) are both satisfied in this instance.
7.19 The proposal would not involve the re-use of suitable previously
developed land, hence it is acknowledged that the land is a
greenfield site, as such, ISA Objective 7 (Soil) is not satisfied in this
instance.
7.20 The site has a road frontage boundary that fronts onto the A4066.
As such, the site is readily accessible from the existing public
highway. The site has existing and established entrances with
adequate visibility splays, which allows direct access into the site
from the adjacent highway.
7.21 The map below (Figure xi) illustrates the number of crashes in the
immediate vicinity of the site.
17
Figure xi (Source:Crashmap.co.uk)
7.22 Data obtained from Crashmap.co.uk confirms that in the last 10
years, there have been no slight, serious or fatal crash incidents
along this part of the A4066 County Road. This would suggest that
there are no highway issues relating to the site or the public road(s)
which serve the site.
7.23 The site lies in very close proximity to National Cycle Network Route
4, which is approximately 1km away. This proximity of the site to
this cycle route is illustrated on the Sustrans National Cycle Network
Map extract below (Figure xii).
Figure xii (Source:Sustrans)
7.24 The site is readily accessible to a local bus services (First Cymru
South & West Wales) Route. There’s a regular bus service which
links the village to Laugharne and commercial centres beyond.
18
7.25 It is considered the site has suitable access to public transport as
well as identified active travel routes, as such, satisfies the following
ISA Objectives; ISA 3 (Air Quality), ISA 4 (Climatic Factors), ISA 6
(Material Assets), ISA 12 (Health & Well-being), ISA 13 (Education
s& Skills), ISA 15 (Social Fabric).
7.26 Given its location, the site lies immediately adjacent to an accessible
green space. In addition, the site is very accessible to an identified
recreation play area in the settlement of Laugharne. As such, it is
considered the site satisfies ISA Objective 12 (Health & Well-being)
and ISA Objective 15 (Social Fabric) .
7.27 The site along with the existing houses are within a reasonable
walking distance of a number of retail and employment provisions;
and services and facilities that can be found in Laugharne service
centre. Whilst the site occupies a rural location, it represents a very
sustainable location given its close proximity to the service centre.
As such, the site satisfies the following ISA Objectives; ISA 6
(Material Assets), ISA 10 (Population), ISA 14 (Economy), ISA 15
(Social Fabric).
7.28 The site represents a sustainable location in terms of its proximity
to nearby nursery schools and Primary School. As such, ISA
Objective 13 (Education & Skills) is satisfied in this instance.
7.29 The site is not located within or adjacent to a mineral buffer zone,
as such, ISA Objective 6 (Material Assets) is satisfied in this instance.
The site is not located within a Mineral Safeguarding Area, as such,
ISA Objective 6 (Material Assets) is satisfied in this instance. The site
is not located within or immediately adjacent to an a Air Quality
Management Area (AQMA), as such, ISA Objective 3 (Air Quality) is
satisfied in this instance.
7.30 The site does not contain high carbon e.g. peatlands, as such, ISA
Objective 7 (Soil) is satisfied in this instance. The site does not
contain high quality agricultural land (grades 1,2 or 3A, as identified
within the Agricultural Land Classification Maps). As such, ISA
Objective 7 (Soil) is satisfied in this instance.
7.31 The site is not located within or immediately adjacent to any
Regionally Important Geological or Geomorphological Sites. As
19
such, ISA Objective 9 (Landscape) is satisfied in this instance.
7.32 The site is located within close proximity to a viable water
connection and is also located within close proximity to other viable
infrastructure requirements such as electricity and main sewer.
7.33 The site is not located within or adjacent to a phosphate sensitive
SAC catchment. A such, As such, the site satisfies the following ISA
Objectives; ISA 2 (Biodiversity), ISA 5 (Water) & ISA 7 (Soil).
7.34 The site by virtue of its scale and location, would not have the
potential to have a detrimental impact on the Welsh Language. As
such, ISA Objective 11 (Welsh Language) is satisfied in this instance.
7.35 The traffic movements associated with additional residential plots
will be marginal and the development could be accommodated on
the highway network and will not have a detrimental impact on the
free flow of traffic due to the existing volumes of traffic using the
local highway network. There are no access or transport constraints
to prevent the development of the site for residential purposes.
7.36 It is asserted that owing to the nature of the development proposal
being advanced, the development has due regard to the existing
built form and also character and appearance of the surrounding
area. Careful consideration has been given to the proposed layout
to ensure the relationship between the proposed dwelling and
existing development in close proximity is acceptable.
7.37 It is not disputed that the siting of an additional dwellings at this
location would introduce built form at an otherwise undeveloped
site. However, the dwellinsg would not represent a prominent or
conspicuous form of development. While the proposed
development would inevitably change the character of the site
itself, the proposed changes would not be to the extent that would
result in an unacceptable impact on the surrounding landscape.
7.39 Given the aforementioned, it is considered that any resulting
development would not be inappropriate or disproportionate in
scale. It is on this basis that it is considered that the proposal would
represent a sensitive form of development, commensurate with the
existing built form, hence would not adversely affect the spatial
character of the village.
7.40 The development would not have a significant impact on the
amenity of adjacent land uses, properties, residents or the
20
community. The impact on the amenity of nearby residents has
been fully considered and duly discounted, particularly given the
separation distance between the site and the nearest residential
properties.
7.41 Overall, the proposed development would satisfy PPW’s objective
of achieving sustainable development both by ensuring that the
local community has access to sufficient housing and affordable
options whilst also working to facilitate a modal shift to more
sustainable methods of transport and reducing car borne journeys.
8 Summary and Conclusion
8.1 This Planning Statement has been completed on behalf of Gwyn
Lewis and provides planning support for the inclusion of additional
land in the revised Local Development Plan to accommodate
potential residential development in Broadway.
8.2 It has been established that the principle of residential development
is compliant with both national and local policy and represents an
acceptable form of infill development at this location. The
development would assist with the housing land supply situation in
the county.
8.3 While residential development at this location would inevitably
change the character of the site itself, the proposed change would
not result in an unacceptable impact on the surrounding landscape
nor would they have an adverse impact on the existing neighbouring
development, highway network or local infrastructure.
8.4 In conclusion, it has been demonstrated that there are significant
material considerations weighing in favour of the inclusion of the
existing group of dwellings along with the inclusion of one additional
site for residential development in the upcoming revised local plan.

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.

This representation is made in response to the ‘Carmarthenshire County Council Second Deposit Revised
Local Development Plan’ (“the LDP”) consultation and is submitted on behalf of Mr James George.
Mr George owns “Llwyndu” Land at Milo, Llandybie (‘the site’) which has been considered in the Candidate
Sites Register Assessment for potential inclusion within the LDP. The site can be seen, outlined in red, on
the plan found at Appendix 1.
It is respectfully suggested that the site should be allocated in the LDP, to provide confidence that houses
can be delivered to meet local needs in Milo. Alternatively, the site is capable of meeting the criteria set out
in the proposed policy framework of the LDP to allow its development for new homes, so long as some
flexibility and judgment can be applied.
THE SCALE OF PROPOSED GROWTH
We support the ambition and principle of the LDP, and specifically the targets set out in Policy SP1:
Strategic Policy - SP1: Strategic Growth
The LDP will provide for the future growth of a sustainable economy and housing
requirement through the provision of:
a. 9,704 new homes to meet the identified housing requirement of 8,822.
b. A minimum of 71.21ha of allocated employment land.
The focus on regeneration and growth reflects the Council's core strategic ambitions with
development distributed in a sustainable manner consistent with the spatial strategy and
settlement framework.
It is clear that the Council has taken seriously its responsibility to support he delivery of the homes and jobs
which are needed in Carmarthenshire. The targets appear aspirational, but realistic. What should not be
overlooked in these strategic targets however is the very real need to support the more rural parts of the
community and meeting their needs.
Sites like “Llwyndu” Land at Milo, Llandybie provide a valuable opportunity to deliver new homes in a rural
hinterland which supports an overall network of social and economic growth. This growth is set out in the
LDP, and the site could be delivered through an allocation, or as a windfall – and either way, it would
contribute to the overall housing target set by the Council.
MILO AS A LOCATION FOR GROWTH
Introduced in chapter 10 of the LDP is the concept of “Clusters” and Milo falls within the settlements grouped
in “Cluster 3: Amman and Upper Gwendraeth.”
We note with interest the way in which Cluster 3 is described in the LDP. In particular, we note the following
elements of the spatial portrait, and that the cluster:
“…is characterised by a series of interrelated settlements; [and]
…has grown as a centre with a focus for investment in jobs, homes, and services.”
And specifically, that:
“Ammanford …plays an important service centre role by providing localised retail, employment,
education, and leisure facilities.”
We also note that:
Cross Hands as a former mining community has developed over recent decades through its position
on the A48 strategic transport route.
Regarding Cross Hands, it is exciting to see a range of significant economic growth is planned to include:
• PrC3/E1 – Employment allocation of some 8.31 Ha
• PrC3/E3 - 4.76 Ha extension to business park
• SG2/3 – reserved expansion area for large scale employment uses.
This growth will also be accompanied by:
TRA1: Transport and Highways Infrastructural Improvements
Transport routes, improvements and associated infrastructural facilities which deliver the objectives
and priorities of the Joint Transport Plan for South West Wales (2015 – 2020) will be supported.
The improvements to the highway infrastructure as part of the Cross Hands Economic Link Road will
be safeguarded with the route identified on the proposals map.
Proposals which maintain and enhance an integrated sustainable transport network will also be
supported where they accord with the policies and provisions of this Plan. Development proposals
which do not prejudice the efficient implementation of any identified improvement or scheme will be
permitted.
Land at Milo, Llandybie is approximately 4 miles from Cross Hands via the A476 and the new Cross Hands
relief road, avoiding additional traffic on the congestion pinch points of the Cross Hands roundabout and
Gorslas.
These points suggest that each settlement in the cluster has a role to play in supporting the successful social
and economic activity in the area, and that the services and facilities of the larger settlements, support a
hinterland of slightly dispersed but nonetheless connected communities.
To maintain this success, and to ensure the continued vitality of the more rural communities it is vital that
development is allowed to happen at all tiers (and sizes) of settlement in the cluster.
We note that potential development in Milo is proposed to be manged primarily through two policies: SP3:
Sustainable Distribution, and HOM3: Homes in Rural Villages.
Therefore, taking each of these policies in turn:
STRATEGIC POLICY – SP3: SUSTAINABLE DISTRIBUTION – SETTLEMENT FRAMEWORK
We generally support the principle of this policy. Settlement hierarchies are a well-recognised way of
managing growth and directing it to the most sustainable locations, and it is important that the role of smaller
settlements such as Milo is not over looked, and that the needs of people who live in these more rural
locations are also met.
We note that Milo is listed as a “Tier 4 – Rural Villages (No development limits).” On the face of it, given the
size of Milo this is reasonable, and the fact that the village is a well-connected part of the ‘cluster’ is also
recognised.
Furthermore, we read with interest in the supporting text to Policy SP3 that in “Rural Villages (No
Development Limits)” the following scale of development will be acceptable:
• Small sites – housing through infill or logical extensions/rounding off.
• Small Scale Rural Exceptions Schemes for Affordable Housing
We respectfully suggest that Land at Milo, Llandybie represents a small infill site as presented in the
supporting text to Policy SP3. The site should be allocated as such in the LDP to provide confidence that it
will be delivered in the plan period to help meet both the strategic needs of Carmarthenshire and specifically
the local housing needs in “Cluster 3: Amman and Upper Gwendraeth” and Milo.
HOM3: HOMES IN RURAL VILLAGES
Should the Council decide that Land at Milo, Llandybie does not need to be allocated for development, the
site has the potential to be delivered as ‘windfall,’ broadly in conformity with proposed Policy HOM3.
There are, however, some element of this proposed policy which are somewhat arbitrary, and we suggest
that some flexibility and planning judgement is allowed, to ensure the most appropriate development
opportunities are delivered, and the most efficient use is made of land.
In particular we note that proposed Policy HOM3, suggests the following:
In those settlements identified as rural villages under Policy SP3, proposals for 1 to 4 dwellings will be
permitted for the following:
• minor infill of a small gap between the existing built form; or,
• logical extensions and/or rounding off of the development pattern that fits in with the character of the
village form and landscape; or
• conversion or the sub-division of large dwellings.
Such proposals will be subject to other detailed planning considerations set out within LDP policies.
As we have explained in response to proposed Policy SP3, and is elaborated upon in our site specific
comments - Land at Milo, Llandybie is a sensible and logical infill site. However, because the most logical
infill is for 6 new homes the potential to develop the site would – in principle – be contrary to proposed Policy
HOM3, but the 1 to 4 dwellings requirement is entirely arbitrary and does not appear to be justified in the
supporting text to the policy, or in any supporting evidence.
We suggest therefore that the reference to 1 to 4 dwellings is removed from the policy text, and this would
have a limited effect on how the policy operates. There is still sufficient scope for a ‘case by case’
assessment of the acceptability of infill sites, and for some flexibility to be applied where perhaps 6 houses
might be more appropriate and in character with a site’s surrounds, but equally importantly it makes an
efficient use of land.
The final paragraph of proposed Policy HOM3 is also arbitrary and not justified in evidence that we have
been able to identify. The following part of the pollciy is not necessary, and should be removed:
Proposals which exceed the 10% cap above the number of existing homes in the settlement, as at
the LDP base date, will not be permitted except where they conform to Policy AHOM1 in relation to
the provision of affordable homes.
By way of an example, there are currently 50 homes in Milo, and Land at Milo, Llandybie can deliver 6 infill
homes, but this would be apparently contrary to proposed policy HOM3 (by a factor of a single house) for no
reason other than it breaches an arbitrary 10% cap. This risks both the viability of schemes, and the efficient
use of land.
“LLWYNDU” LAND AT MILO, LLANDYBIE
Turning to the site which we are proposing should be allocated for development. This submission
commends to the Council, Land at Milo, Llandybie (‘the site’) which has been considered in the Candidate
Sites Register Assessment for potential inclusion within the LDP.
The site address is as follows:
Llwyndu
Milo
Llandybie
Ammanford
SA18 3NQ
The site has been assessed by the Council and the site reference is SR/114/001. The assessment of the
site states
“The site may comply with the provisions of the Preferred Strategy, however each individual site will
require assessment at application stage to ensure it complies with the relevant specific policy. In
respect of this settlement, the Preferred Strategy identifies it as a Tier 4 with no development limits”
We support the general assessment of the site and suggest that it should be allocated for development to
provide confidence in its delivery.
However, should the Council disagree with this position, we remain confident that the site is acceptable, and
achievable as infill development.
Site Context
The site comprises 4.64 acres of agricultural fields within the settlement of Milo, which is identified in Policy
proposed policy SP3 as a sustainable community. A site location plan, which was submitted with our initial
submissions to the candidate sites register is included again for completeness (Appendix 1).
The site benefits from an existing access with good visibility onto the main road running through Milo, as
shown in Figure 1 below.
Figure 1 – Access to the site from the main road through Milo (Google Street View - 2011)
The site is bound by agricultural fields to the south west, residential properties to the south east and a chapel
to the North West. The site is bounded by the road to the north east, whilst two and three storey residential
properties lie on the opposite side of the road.
There are two listed buildings to the north of the site: Capel Milo (ID: 22200) and Hen Gapel Milo (ID:
22199).
The village of Milo contains around 50 homes. Milo is approximately 4.5 miles north of Ammanford, which is
recognised as a growth area in proposed Policy SP3 and the heart of a cluster or network of connected
communities. Milo is approximately 5 miles south west of Llandeilo which is also identified as a service
centre. There is a bus service from Milo to Llandeilo.
Proposed Development
It is considered that the site could be developed along the road following the existing linear patter of built
form in Milo. In this case, it is considered that the site could comfortably accommodate approximately six
dwellings and utilise the existing access, as shown in Figure 1 above. Such development would mirror the
existing settlement and would constitute ‘infill’ development, as supported in proposed Policies SP3 and
HOM3.
As highlighted within our initial submission, an alternative option is to develop the whole of the site, again
utilising the existing access, which could accommodate approximately 15 dwellings, thus triggering the need
for affordable housing which would provide additional benefits to the locality.
Two broad indicative layouts were provided within our initial submission and have been included again for
completeness (see Appendix 2).
The site also lies within a sustainable location within Milo itself, located approximately 140m to the local bus
stops from the existing access into the site shown in Figure 1 above.

CONCLUSION
We are pleased to have had the opportunity to comment on the ‘Carmarthenshire County Council Second
Deposit Revised Local Development Plan.’ We support the general vision, and approach of the LDP but
suggest that some flexibility and room for judgement must be retained to allow for the continued vitality of
some of the more rural parts of the county.
“Llwyndu” Land at Milo should be allocated for development to provide some confidence that local housing
needs will be met. However, failing that the site is capable of providing a reasonable ‘windfall’ development
as infill.
As has been demonstrated above, the site (SR/114/001) constitutes a suitable and sustainable form of
development within the settlement of Milo.
Overall, it is considered that the site (SR/114/001) constitutes the only suitable and sustainable Candidate
Site within Milo for residential development. The site is capable of mirroring the linear form of development
that exists along the main road through Milo, and would therefore be a logical means of increasing housing
within this sustainable community (as promoted through proposed Policy SP3 Local Development Plan).
I trust the information provided in this submission is sufficient. Should you require any further information,
please do not hesitate to contact me.