SD1: Terfynau Datblygu

See Rep 5215.

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.

See Rep 5215.

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.

See Rep 5125.

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.

We want the developmental boundary line as shown on the map attached to the petition Appendix A to be put back to how it was previously, as shown by the black line in Map 1 in Appendix A and in the “Deposit Revised Carmarthenshire Local Development Plan 2018 – 2033 Proposals”.

The attached petition is signed by 34 concerned citizens who strongly OBJECT to the developmental limit change on the Plan (see map).
Our objection comes under Policy SD1 relating to developmental limits.
We believe that the Plan is unsound and should be changed because it does not conform to the test of soundness with regards to Procedural Requirements, i.e. the way in which the Plan has been prepared and consulted on because it has been done without public consultation. We believe that the Procedural Requirements have not been met for the same reason.

Include objection site within the development limits for Temple Bar.

This representation is to propose a new site for residential development.

This candidate site lies within the villages of Carmel / Temple Bar. Both these villages are conjoined as one community which straddles the A476 road which
passes through both settlements. Over past decades residential properties have been constructed primarily alongside this road.

The revised local development plan 2018-2033 makes provision, under policy SP3 and within HOM 3: Homes in Rural Villages, for small developments of 1 - 4 dwellings to be permitted so long as they meet certain criteria in relation to infill sites, or sites adjacent to a rural village within physical boundaries, logical extension/rounding off, all so long as ribbon development does not take place.

In particular in respect of housing allocation, HOM 3 and HOM 4 appear to enable the creation of small sites of either single or just a few dwellings, so as to cater for the strong demand from those seeking to build themselves a family and/or retirement home. The main towns of the county appear to be well provided for with large allocations of new housing, and well suited to the
requirements of national developers, with HOM 3 and 4 enabling small local builders to flourish.

The revised LDP plan 2018-2033 seeks additional land suited for residential development and we would submit that this candidate site as eminently suited for such future residential development.

1. The site, which is edged red on the attached plan, lies adjacent to the main
road and has good frontage to this road with no adverse highway concerns.
There is an existing access which could easily be improved in order to create a
safe vehicular access to serve the site with ample visibility to the latest highway
requirements.

2. The site is directly adjacent to existing dwellings, and would not constitute a
ribbon development. It meets the criteria of acceptable plots set out in Policy
HOM3; Homes in Rural Villages.

3. Mains water electricity and drainage serve the village and pass adjacent to the site, so services are readily available.

4, The site has strong physical boundaries of existing mature hedges containing
the site on two sides so as not to be an intrusion into open countryside. It is
currently an amenity area used with our bungalow home nearby. It is ideally
suited to two individual building plots to enable the construction of
houses/bungalows. There is ample demand for such plots, but a shortage of
them, and this site would be ideal and in keeping with the HOM 3 policy of
homes in rural villages.

We do hope you will consider this site as a suitable candidate for a new site
allocation.

Include site within development limits for Temble Bar.

This representation is to propose a new site for residential development to
incorporate a small area already within the existing development limits.

This candidate site lies within the villages of Carmel / Temple Bar. Both these
villages are conjoined as one community which straddles the A476 road which
passes through both settlements. Over past decades residential properties have
been constructed primarily alongside this road.

The revised local development plan 2018-2033 makes provision, under policy
SP3 and within HOM 3: Homes in Rural Villages, for small developments of 1 - 4
dwellings to be permitted so long as they meet certain criteria in relation to infill
sites, or sites adjacent to a rural village within physical boundaries, logical
extension/rounding off, all so long as ribbon development does not take place.
In particular in respect of housing allocation, HOM 3 and HOM 4 appear to
enable the creation of small sites of either single or just a few dwellings, so as to
cater for the strong demand from those seeking to build themselves a family
and/or retirement home. The main towns of the county appear to be well
provided for with large allocations of new housing, and well suited to the
requirements of national developers, with HOM 3 and 4 enabling small local
builders to flourish.

The revised LDP plan 2018-2033 seeks additional land suited for residential
development and we would submit that this candidate site as eminently suited
for such future residential development.

1. The site, which is edged red on the attached plan, lies adjacent to the main
road and has good frontage to this road with no adverse highway concerns.
There is a detached single garage already on the site and part of the site [to the
rear of the garage] is already included within existing development limits. There
is an existing access to the garage which could easily be improved in order to
create a safe vehicular access to serve the site with ample visibility to the latest
highway requirements.

2. The site is directly adjacent to existing dwellings, and would not constitute a
ribbon development. It meets the criteria of acceptable plots set out in Policy HOM3; Homes in Rural Villages. Part of the site is already included within
development limits but this area is inadequate for a single plot, and a further
area to the rear[ that is behind the garage] would be needed to create a small
single plot. The garage is at present a store as we already have a larger existing
garage to serve our bungalow home which is next door. The loss of the garage
would therefore be of no consequence as we have other access, parking and
garage to our bungalow nearby.

3. Mains water electricity and drainage serve the village and pass adjacent to the
site, so services are readily available.

4, The site has strong physical boundaries of a fence to one side adjacent to a
house named Greenhill, and on the other side is an existing mature hedge which
would be a natural boundary, as recognized already by it being the development
limit boundary. The addition of a small area to the rear would not be any
intrusion into the countryside, and would then be ideally suited to a single
individual building plot to enable the construction of a house/bungalow. There is
ample demand for such plots, but a shortage of them, and this site would be
ideal and in keeping with the HOM 3 policy of homes in rural villages.
We do hope you will consider this site as a suitable candidate for a new site
allocation.

Include site within development limits

This representation is to propose a new site for residential development.

This candidate site lies within the villages of Carmel / Temple Bar. Both these
villages are conjoined as one community which straddles the A476 road which
passes through both settlements. Over past decades residential properties have
been constructed primarily alongside this road.

The revised local development plan 2018-2033 makes provision, under policy
SP3 and within HOM 3: Homes in Rural Villages, for small developments of 1 - 4 dwellings to be permitted so long as they meet certain criteria in relation to infill sites, or sites adjacent to a rural village within physical boundaries, logical extension/rounding off, all so long as ribbon development does not take place.

In particular in respect of housing allocation, HOM 3 and HOM 4 appear to enable the creation of small sites of either single or just a few dwellings, so as to cater for the strong demand from those seeking to build themselves a family and/or retirement home. The main towns of the county appear to be well provided for with large allocations of new housing, and well suited to the
requirements of national developers, with HOM 3 and 4 enabling small local builders to flourish.

The revised LDP plan 2018-2033 seeks additional land suited for residential development and we would submit that this candidate site as eminently suited for such future residential development.

1. The site, which is edged red on the attached plan, lies adjacent to the main
road and has good frontage to this road with no adverse highway concerns.
There is an existing access which could easily be improved in order to create a
safe vehicular access to serve the site with ample visibility to the latest highway
requirements.

2. The site is directly adjacent to existing dwellings, and would not constitute a
ribbon development. It meets the criteria of acceptable plots set out in Policy
HOM3; Homes in Rural Villages.

3. Mains water electricity and drainage serve the village and pass adjacent to the site, so services are readily available.

4. The site has strong physical boundaries of existing mature hedges containing
the site on three sides so as not to be an intrusion into open countryside. It is
currently an amenity area used with our bungalow home nearby. It is ideally
suited to two individual building plots to enable the construction of
houses/bungalows. There is ample demand for such plots, but a shortage of
them, and this site would be ideal and in keeping with the HOM 3 policy of
homes in rural villages.

We do hope you will consider this site as a suitable candidate for a new site
allocation.

For the reasons stated in these representations, Dylan Coastal Resort, including future allocations, should be included within the development limits of the settlement of Laugharne.

The proposed boundary of Laugharne is shown within the draft proposals map. It remains the same as the first deposit plan draft proposals map. The Development Limits boundary includes the existing built development of the settlement of Laugharne as well as the proposed new allocations for housing (3 x sites). The purpose of Policy (SD1), which guides Development Limits, is to prevent inappropriate development in the countryside; prevent coalescence of settlements and; to identify areas where development proposals would be permitted.

The existing Laugharne Park Estate, is not open countryside, does not border or close a strategic gap between settlements, and is an existing development site with extant and implemented permission for C1 use.

Dylan Coastal Resort operates much like a hotel, it has independent accommodation, to which you can be served meals, it has a reception, central hub including spa, and restaurant facilities and expansive open grounds. The fact the hotel accommodation is spread across the grounds rather than within one single building, does not make it a caravan park or static homes park. As a hotel use, it should logically be included within the development limits of that settlement in the same way that hotel uses adjoining settlements are elsewhere in the County.

The fact that the resort is not shown as being within the development limits makes the Plan inconsistent in how it treats main town centre uses. It limits further development that would assist economic growth at the site, meaning it would not be effective, and as a result should not be found sound.

Dylan Coastal Resort, as noted above, represents an entirely different form of accommodation to the usual static home holiday accommodation. It is a hotel spread across a larger site, which offers year round accommodation. It therefore is an entirely suitable use to be included within a development limits boundary in a service centre such at Laugharne. The modification proposed would therefore be sound.

Furthermore, as with the allocation, the boundary amendment provides additional certainty for the owners should they choose to invest further in Dylan Coastal Resort to improve facilities and create jobs.

That the two parcels be removed from development limits and be awarded the same status as the adjacent protected open space.

x1/

I think the LDP is unsound and should be changed

I feel this is the case as the two parcels of land situate in Heel Brown between No4
and No6 and alongside No8 form part of the conveyance of 1988 from the coal board, with spcific covenants as to the future use of the land being specified as for
“recreation and amenity”, Any intended use other than the above to be notified to
the coal board, and consent sought, the coal board have not been notified that
these two parcels of land are now proposed to be included inside the LDP
development limit, and need to be removed from being contained within these proposed development limits, to be reinstated as intebded in the original I
conveyance, not for development, or sale,

Attachments 1/ and 2/

I enclose attachments showing the two parcels of land shaded in red

and a copy of coal board map showing All the land in the conveyance of 1988

x 2/

Pocedural requirements have not been met
This comment is because CCC have in their possesion the conveyance document
containing the covenants mentioned in x 1) above, yet have proceeded to propose
changes to the LDP development limits, that would include parcels of land in
contravention to those covenants, without conforming to the required procedure in
infornmlng te coal board as required in the original conveyance.

I attach highlighted sections of the conveyance document to confirm the above and clarify the intended future use of the land conveyed by the coal board for community use

Attachment 3/

x 3/

New Policy

I think that the "new policy" needs to establish and clarify the “recreation and
amenity" status of the large parcel of land sited at Heol Brown park between the
two green shaded areas in the current LDP proposal,

It's important to state that in last 2 years via the FOTP (Friends Of Tycroes Parks)
there has been extensive work carried out in both woodland sections of the
parkland, in as much as that a comprehensive footpath development has been
carried out by a contracting company for the benefit of our community use, and all
gravelled paths are wheelchair user friendly, and has had a tremendous benefit as
witnessed by the huge increase in users, this development has inclded installation
of boardwalks and drainage systems

In the open grassed area between the scouts hall and the refurbished childrens play area several large picnic tables have been laid out. and the increased footfall in the
parknand woodlands is quite incredible,

as a result of the above improvements and numbers of community events held on
the site

It is asked that this area be awarded the same status as the current green shaded area that is, “protected from development”

This would also establish the land donated in the 1988 conveyance, being
recognised, and established, on record within the LDP , to be retained in perpetuity
for the community as intended by the coal board conveyance for community
"recreation and Amenity”

l attach a copy of a section of the current LDP plan,and hatched in red the area of
land which needs to be established as “protecred from development” status.

Attachment 4/

x 4/

New paragraph or supporting text,

If appropriate a new paragraph or text might be beneficial in explaining the status
of the parcel of land conveyed in 1988 from the coal board and the exploit content
describing its intended use by the communituy

it would clarify both the coal boards generosity (sold for £1) '

and CCC compliance via the LDP to honour the vendors intentions regarding use

Remove the two strips of land in question from development limits and protect as part of the original conveyance from the Coal Board.

In the 2018 LDP sites map, the whole of the land conveyed by the coal board was confirmed as being protected from development, and a 700+ residents petition delivered to Mr Ian R Llewelyn at the Carmarthenshire council offices confirmed the community support for this protection.

It is still necessary to include as protected from development the area bordered in red on

Attachment 2

There is an error in the current ldp map development outline ,

the two strips of land identified in

Attachment 3

formed part of the original conveyance of 1988 see

Attachment 4

these two parcels of land need to be placed outside the development limits and
included as being protected from development

Attachment 5

is an extract supplied by the coal board estates dept with a red hatched area clearly
showing the areas bordering Heol Brown, including the two strips of land referred to
above, as being included in the conveyance and hence covered by the relevant
covenant

Attachment 6

This land registry document confirms the registration of these two strips as being
part of the main parkland contained in the conveyance, and need to be registered as
protected from development along with the previously explained section within the
main green park area.

This needs to be confirmed as being the intention to comply with the perpetuity
period stipulated by the coal board to 2068 to safeguard from development this much
used and enjoyed open green space.

Change to plan to remove undeveloped plots.

Llanedi Community Council would like to see the whole of the block of land at Tycroes Park and woodland allocated as Playspace and Amenity greenspace. The Council would also wish that all the remaining plots located adjacent to the park at Heol Brown are removed from development limits.

Development Limits for Rhandirmwyn, and the inclusion of site.

The site proposed is essentially in- fill, between the established line of existing dwellings. With access and frontage to the existing council road and provides an opportunity for a small number of smaller dwellings appropriate to the village location, without extending the development area.

Sewerage, water, and electricity are all available - for instance the mains sewer apparently runs across the proposed site. Mains water and electricity are supplied to neigbouring properties. It is envisaged the site boundary hedges etc would be unchanged apart from changes necessary to facilitate access.
The intention would be to place perhaps 3 modest properties sympathetically on the site .I would be happy to discuss potential development with a housing association or to commit to a third of the development being designated affordable, though the intention is only to build modest homes of the sort that will appeal to young families. This modest development would help the village grow in a sustainable manner and support local services.

This application is to include the area as permitted for housing development. The modest area is infill within the existing settlement of Rhandirmwyn and lends itself to modest housing for local people who wish to continue to live and work in the area.
This is a housing opportunity that will not have a detrimental effect. This assertion is supported by a planning consent granted in 2010 for a house subject to a S106 agreement (E/19958). Such a local needs restriction meant that in practice it was not financially viable and limited the future utility for the community.
As a lifelong farmer and resident of the Upper Towy Valley I would like to enable others to be able to live and work in the area in suitable cost-effective housing. I believe small sympathetic development will be beneficial for the community and help it to be sustainable in the long term.
The use of this land for housing will have minimal impact on visual or environmental amenity but will contribute to Rhandirmwyn being a viable community.
I am prepared to offer the area in green on Plan A to enable the road to be widened, and access be improved, there is little traffic on this road and it does does not travel at high speed.
I have completed this application my self and hope that I have satisfied your requirements but, in the event, that I have omitted anything you need or made any other errors I would be keen to supply whatever you need.

Include site within development limits

This document contains a proposal to assess, revise and adjust the Local Development Plan for Carmarthenshire, Specifically within the village of Capel Dewi.
I have provided images of the Land at Capel Dewi Lodge before and after the removal of overgrowth/trees which I believe is the reason the land was never included in previous drafts of the development plan. Only now is it clear how suitable this piece of land is for development.
Please also find attacthed to scale images from google earth.
Given the settlement boundaries of Capel Dewi are in two main sections, East and West, my proposal will not affect this as the piece of land joining them is not owned by neighbours.
The Land at Capel Dewi Lodge appears to be the last piece of suitable, undeveloped land within the village. The proposed site would be for one property, with the remaining used as the garden.
Since the first subbisson of this proposal March 2020, there have been numereous new properties built withing Capel Dewi. Of the five Applications I believe only one can be considered as infill (SR/017/004) where as the other four appear to be extending the village, which has, and would inevitably result in the loss of valuable agricultual land. (SR/017/002) and (SR/017/005) also current build site (SuV16/h1).
I have spoken to my immediate neighbours, and as a new dwelling built on the Land at Capel Dewi Lodge will not affect them and can only be seen as a positive, they are all on board with and are excited about the prospect of a new dwelling and bring new neighbours into the ever evolving community.
Other properties within Capel Dewi are built on lesser ground.
The small brook that flows behind all the current properties has never burst its banks and each property it flows past has its own defence and/or flood protection in place.
Original access was uncovered when I purchsed Capel Dewi Lodge in 2013 allowing great visablity splays and line of sight, turning onto B4300 which enforces a strict 30mph speed limit thorughout the village, often patrolled by mobile speed cameras and soon to be lowered to 20mph.
Before the removal of severe overgrowth, the Land at Capel Dewi Lodge could have be mistaken as waste/woodland. However since being cleared it has presented an idilic location for a property with beautiful surroundings, in an historic village, with the opportunity to build the community.
I welcome and highly recommend a site visit.
Any fees for land registary and/or planning application with building regulations will be paid immediately when due.
Thank you for your time please consider my proposal look forward to hearing fromk you. I am open to ideas.



Land at Capel Dewi Lodge (highlighted in blue)



Proposed boundary evaluation application (highlighted in red)



Current Planning Applications for the village of Capel Dewi.



Proposed Planning Application (highlighted in red)



Scale images of Land at Capel Dewi Lodge via Google Earth approximately 80metres with access for the potential one property.



Scale images of land at Capel Dewi Lodge via Google Earth 28 metres







Hedgerow of proposed site access before removal of overgrowth 2013 (B4300)



Hedgerow of proposed site after removal of overgrowth 2013 revealing access (B4300) showing access



Image from google earth of the most recent developed plots in Capel Dewi (SuV16/h1) 5 properties over 90metres of land.

No Change to the Plan

We are instructed by Mrs A. M. Morgans to make a formal representation with regards to the
above land and the Second Deposit Draft of the Carmarthenshire Replacement Local
Development Plan.
Our client made a formal Candidate Site Submission in August 2018, which was referenced
SR/039/006, seeking the inclusion of her land for residential development within the
settlement limits of Cwmffrwd as part of the Replacement Local Development Plan.

The Candidate Site comprises the remaining part of the former Bolahaul Nurseries, which
was located off the rear of residential properties, which front the western flank of Bolahaul
Road in Cwmffrwd. Most of that site has been developed with recently completed bungalows
and estate road, known as Clos Bolahaul. The Candidate lies off its western extremity. The
proposals seek inclusion of a small-scale extension to that cul-de-sac to provide a handful of
properties up to the western perimeter of the site which borders the Nant Pibwr watercourse.

The land therefore clearly represented a logical extension opportunity to the existing
settlement and its extents are illustrated by the red line below at Plan A.

Following due consideration, the Council included the roadside frontage part of the land in
question within the draft settlement limits of Cwmffrwd in its First Deposit Draft of the Local
Development Plan, published in January 2020. However, for reasons outlined by the Council
in their current submissions, a revised Second Deposit Local Development Plan has now
been prepared and published in January 2023. It is subject to public consultation.
As part of the current consultation process into the Second Deposit Local Development Plan,
the Council have again 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 clients’ land was considered as part of this process and as a result the Authority
concluded as follows: “A large part of the site is located within the flood risk zone. The
remainder of the site cannot accommodate 5 or more dwellings, however the development
limits will be extended to include part of this area. Any proposal will be considered against
the policies set out within the revised LDP.”

Plan A- Location Plan of Candidate Site

Plan B represents an extract of the Second Deposit LDP Proposals Map for Cwmffrwd, and
identifying our client’s rear field enclosure as land within the defined settlement limits:

Plan B – Extract from part of the Proposals Map for Cwmffrwd

Our client therefore welcome and SUPPORT the decision of the Authority to partly concur with the representations previously made in relation to our clients’ land.

We can also confirm that the land continues to not face any ecological, flood risk related, highway, infrastructure or land ownership constraints that would restrict its ability to be delivered during the Plan period.

We therefore fully support the decision of the Authority to include the land for the purposes of Residential Development as part of the Carmarthenshire Replacement Local Development Plan.

No change to the Plan.

We are instructed by Mr & Mrs J. Evans to make a formal representation with regards to the
above land and the Second Deposit Draft of the Carmarthenshire Replacement Local
Development Plan.

Our client made a formal Candidate Site Submission in August 2018, which was referenced
SR/019/009, seeking the allocation of their land for residential development within the
settlement limits of Capel Iwan as part of the Replacement Local Development Plan.

The Candidate Site comprises part of an equine grazing paddock set off the southern flank
of the minor road that runs north to south from the centre of the village of Capel Iwan. The
proposals seek inclusion of the frontage part of the enclosure to provide a small-scale
development of one detached house to complement established properties which lie directly
opposite, being frontage houses off the western and eastern flanks of the road.

The land therefore clearly represented a logical extension opportunity to the existing
settlement and its extents are illustrated by the red line below at Plan A.
Following due consideration, the Council included the roadside frontage part of the land in
question within the draft settlement limits of Capel Iwan in its First Deposit Draft of the Local
Development Plan, published in January 2020. However, for reasons outlined by the Council
in their current submissions, a revised Second Deposit Local Development Plan has now
been prepared and published in January 2023. It is subject to public consultation.

As part of the current consultation process into the Second Deposit Local Development Plan,
the Council have again 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 clients’ land was considered as part of this process and as a result the Authority
concluded as follows: “The site is unable to deliver 5 units, however it is appropriate as
small-scale development, and the development limits will be drawn to reflect this.”

Plan A- Location Plan of Candidate Site

Plan B represents an extract of the Second Deposit LDP Proposals Map for Capel Iwan,
clearly now identifying our clients’ field frontage as land within the defined settlement limits:

Plan B – Extract from part of the Proposals Map for Capel Iwan

Our clients therefore welcome and SUPPORT the decision of the Authority to concur with
the representations previously made in relation to our clients’ land.

We can also confirm that the land continues to not face any ecological, flood risk related,
highway, infrastructure or land ownership constraints that would restrict its ability to be
delivered during the Plan period.

We therefore fully support the decision of the Authority to include the land for the purposes
of Residential Development as part of the Carmarthenshire Replacement Local
Development Plan.

No change to Plan.

We are instructed by Mrs H. Chambers to make a formal representation with regards to the
above land and the Second Deposit Draft of the Carmarthenshire Replacement Local
Development Plan.

Our client made a formal Candidate Site Submission in August 2018, which was referenced
SR/106/007, seeking the allocation of their land for residential development within the
settlement limits of Llansteffan as part of the Replacement Local Development Plan.

The Candidate Site comprises of an undeveloped paddock set off the western flank of
School Road, as that minor road runs north from the centre of the village of Llansteffan. The
proposals seek inclusion of part of the enclosure to provide a small-scale development of
frontage houses to complement established properties off its southern side. It also lies
directly opposite further frontage houses off the eastern flank of the road.

The land therefore clearly represented a logical extension opportunity to the existing
settlement and its extents are illustrated by the red line below at Plan A.

Following due consideration, the Council included the roadside frontage part of the land in
question within the draft settlement limits of Llansteffan in its First Deposit Draft of the Local
Development Plan, published in January 2020. However, for reasons outlined by the Council
in their current submissions, a revised Second Deposit Local Development Plan has now
been prepared and published in January 2023. It is subject to public consultation.

As part of the current consultation process into the Second Deposit Local Development Plan,
the Council have again 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 clients’ land was considered as part of this process and as a result the Authority
concluded as follows: “The whole site is not allocated. The development limits will be
amended to allow the potential for small scale development.”

Plan A- Location Plan of Candidate Site

Plan B represents an extract of the Second Deposit LDP Proposals Map for Llansteffan,
clearly now identifying our client’s field frontage as land within the defined settlement limits:

Plan B – Extract from part of the Proposals Map for Llansteffan

Our client therefore welcome and SUPPORT the decision of the Authority to partly concur
with the representations previously made in relation to our clients’ land.

We can also confirm that the land continues to not face any ecological, flood risk related,
highway, infrastructure or land ownership constraints that would restrict its ability to be
delivered during the Plan period.

We therefore fully support the decision of the Authority to include the land for the purposes
of Residential Development as part of the Carmarthenshire Replacement Local
Development Plan.

No change to the Plan.

We are instructed by Mrs E. Howell to make a formal representation with regards to the
above land and the Second Deposit Draft of the Carmarthenshire Replacement Local
Development Plan.

Our client made a formal Candidate Site Submission in August 2018, which was referenced
SR/129/004, seeking the allocation of their land for residential development within the
settlement limits of Pentrecwrt as part of the Replacement Local Development Plan.

The Candidate Site comprises part of the road frontage of grazing paddock set off the southeastern
flank of the A486 road that runs through of the village of Pentrecwrt. The proposals
seek inclusion of the well-defined enclosure to provide a small-scale development of
detached houses to complement established properties which lie directly opposite off the
north-western flank of the road, to the south-west extremity of the settlement.

The land therefore clearly represented a logical extension opportunity to the existing
settlement and its extents are illustrated by the red line below at Plan A.

Following due consideration, the Council included the roadside frontage part of the land in
question within the draft settlement limits of Pentrecwrt in its First Deposit Draft of the Local
Development Plan, published in January 2020. However, for reasons outlined by the Council
in their current submissions, a revised Second Deposit Local Development Plan has now
been prepared and published in January 2023. It is subject to public consultation.

As part of the current consultation process into the Second Deposit Local Development Plan,
the Council have again 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 clients’ land was considered as part of this process and as a result the Authority
concluded as follows: “Part of the site is considered appropriate for small scale rounding off,
and the development limits will be drawn to incorporate a few plots. In terms of the
remainder of the site, it is considered that there is sufficient and more suitable land available
for development within the settlement to accommodate the housing need.”

Plan A- Location Plan of Candidate Site

Plan B represents an extract of the Second Deposit LDP Proposals Map for Pentrecwrt,
clearly now identifying our client’s field frontage as land within the defined settlement limits:

Plan B – Extract from part of the Proposals Map for Pentrecwrt

Our client therefore welcome and SUPPORT the decision of the Authority to actually concur with all the Candidate Site representations previously made in relation to our clients’ land.

We can also confirm that the land continues to not face any ecological, flood risk related, highway, infrastructure or land ownership constraints that would restrict its ability to be delivered during the Plan period.

We therefore fully support the decision of the Authority to include the land for the purposes of Residential Development as part of the Carmarthenshire Replacement Local Development Plan.

No change to the Plan.

We are instructed by Mr and Mrs Conner to make a formal representation with regards to the
above land and the Deposit Draft of the Carmarthenshire Local Development Plan.

Our Clients made a formal Candidate Site Submission in August 2018, seeking the inclusion
of their land within the development limits of Brechfa as part of the Replacement Local
Development Plan. The Candidate Site comprised of two parcels of land – one relating to
our Clients home and associated curtilage, with the second then relating to an undeveloped
plot between our Clients home to the south and the former School House to the north. Both
elements were strongly defined by existing established means of enclosure, with access on
both accounts being gained from the adjoining public highway to the west. The extent of the
submitted Candidate Site is illustrated by the red line below.

Plan A

We understand that the site was considered and assessment by the Council as part of its
broader assessment of Candidate Sites it received. As part of this assessment, it determined
to include part of the land in question within the development limits with Plan B providing an
extract of the Deposit Proposal Map for the area in questions:

Plan B

Following careful consideration of the Authority’s response and discussion with our Client,
we therefore welcome the decision of the Authority to concur in part with the representation
previously made in relation to our Clients land and so fully support their decision to include
the above land within the development limits.

Include the site within the development limits for Llandybie.

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 SD1 are of particular interest to our Client. As a result, we
offer the following for the Authority’s consideration, and Inspector’s in due course.

Our Client made a formal Candidate Site Submission in August 2018, which was referenced
SR/082/006, seeking the inclusion of the land within the defined development limits of
Llandybie as part of the Replacement Local Development Plan. The Candidate Site centred
mainly on a small agricultural paddock that fronted onto Kings Road, edged red on Plan A.

Plan A

Further agricultural enclosures are positioned to the east, but residential development is
located directly to the land’s south and on the opposite side of Kings Road to the west. The
Site is also within walking distance to the range of community facilities and local services the
settlement has to offer, as well as well serviced bus stops that provide access to those
services and facilities in the wider growth area.

As part of the preparation of the 1st Deposit LDP, the Council then considered the
submissions made and provided a summary of its assessment in its ‘Site Assessment Table’
(January 2020), which read as follows:

““Inclusion of the site would result in extending a ribbon pattern of development contrary to
general planning principles.”

As a result, the proposed 1st Deposit LDP made no changes to the development limits in the
environs of the Candidate Site to those forming part of the current adopted LDP, as
illustrated by the Proposals Map extract below.

Plan B

As part of the current consultation process into the 2nd Deposit LDP, the Council have again
published a “Site Assessment Table” (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 Council concluded as follows:

“The site cannot accommodate 5 or more dwellings. Inclusion of the site would result
extending a ribbon pattern of development contrary to general planning principles.

As can be seen, the process of assessment of our Client’s land by the Council has remained
unchanged, as has its exclusion from the development limits. We however consider the
exclusion of the site to be an erroneous decision by the Council, as well as being an
inconsistent approach taken by it in the assessment of such sites. We therefore consider
that the LDP is “unsound” and should be changed, as it fails to meet the tests for
“soundness”.

Specifically, we consider the approach of assessment taken by the Council has been
inconsistent in terms of (a) other policy approaches taken by the Deposit LDP and (b) in
relation to other examples that were successfully included within defined development limits
of the 2nd Deposit LDP. We consider therefore that the whole of the land edged red in Plan
A, should be included within the defined development limits for Llandybie under the provision
of Policy SD1 of the Carmarthenshire Local Development Plan.

This formal representation letter supplements the following documents which comprise a
complete submission to the 2nd Deposit LDP Consultation stage:

- Completed 2nd Deposit LDP Representation Form
- Copy of Candidate Site Supporting Letter (August 2018)
- Copy of Candidate Site Location and Layout Plan (August 2018)

Response to Council’s Reasons for Non-Allocationof Site

Consistency with Other Policies of the Deposit LDP
The Council has provided no specific indication or guidance on how it has determined and
defined development limits within the 2nd Deposit LDP. It has therefore been difficult to
ascertain why some sites have been successfully included and others haven’t, which is
discussed further below. 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 a candidate site would make an acceptable addition to existing development
limits (A separate representation with regards to Policy SD1 has been made on this basis).

Taking our Client’s land into consideration, together with the actual ‘on-the-ground’ physical
attributes of adjoining and nearby land and its use, it is clear that it would adhere to the
second criteria listed above and so should in turn have been included within the defined
development limits of Llandybie. Its exclusion would be inconsistent with the provisions of
Policy HOM3 and indeed decisions taken by the Council with regard to other sites within the
Plan area. As a result and on this basis alone, the Plan as it currently stands is unsound.

Consistency with Other Development Limits
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 Llandybie and other
settlements, the Council has been found to be inconsistent.
The plans below are an extract of the 2nd Deposit LDP Proposals Maps for two areas
(indicated by the red star) in the settlement of Llandybie, Glanamman and Llanwrda.

Plan C
(Llandybie)

Plan D
(Llanwrda)

Plan E
(Glanamman)

In the case of the Llandybie example, two separate parcels of undeveloped land have been
included within the defined development limits, that extend the existing form of the
settlement in a southern ‘ribbon-like’ manner, and the Garnant example follows a similar
pattern. The Llanwrda example is then an element of an existing larger agricultural
enclosure, with two of its boundaries therefore currently undefined and so extending the
existing settlement’s limits beyond existing boundaries.

It should be noted that we do not object to the form of alteration to the development limits as
referred to above, as it secures a varied form of available housing development opportunities
for a community. However, their inclusion is in direct contrast and inconsistency to the
Council’s decision to exclude our Client’s land and the aforementioned existing properties
from the development limits. Combined with our Client’s land representing a logical
rounding-off of the respective area of the settlement (particularly when the on-the-ground
position is given full consideration), the exclusion of it would represent a clear inconsistency
in approach taken by the Council, resulting in the Plan as it stands being unsound.

In conclusion, this Representation to the 2nd Deposit Draft of the Revised LDP has sought to
examine the Council’s reasons for non-inclusion of a Candidate Site within the defined
development limits. It has successfully addressed the reason put forward by the Council for
its exclusion and highlighted that its continued exclusion would represent a dangerous
inconsistency.

We therefore respectfully request that this Representation be given careful examination, and
consequently the land in question be included within the defined development limits as part
of the Carmarthenshire Local Development Plan to ensure that the document passes all the
relevant tests of soundness.

Include the full candidate site withing the Plan.

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 SD1 are of particular interest to our Client. As a result, we
offer the following for the Authority’s consideration, and Inspector’s in due course.

Our client made a formal Candidate Site Submission in August 2018, which was referenced
SR/064/004, seeking the inclusion of the land within the defined development limits of
Glanaman as part of the Replacement Local Development Plan. The Candidate Site (edged
red below) included two small parcels of land, set either side an existing residential property
with its associated hardstandings and outbuildings, being the core of an associated
smallholding.

Plan A

All boundaries of the Candidate Site were and continue to be well defined, with the public
highway (Mountain Road) then running along its north eastern boundary. The site then
continues to be within walking distance to the range of community facilities and local
services the adjoining settlement has to offer, as well as well serviced bus stops that provide
access to those services and facilities in the wider growth area.

Following its due consideration, the Council then included within the development limits the
south eastern two thirds of the land in question in its 1st Deposit LDP, published in January
2020 (Plan B).

Plan B

In explaining its decision to exclude part of the site, the Council advised in its ‘Site
Assessment Table’ (January 2020) as follows:
“Part of the site is considered appropriate for small scale rounding off, and the development
limits will be drawn to incorporate this element. In terms of the remainder of the site, it is
considered that there is sufficient and more suitable land available for development within
the settlement to accommodate the housing need.”

What was apparent therefore from the above was that the Council had assessed the
Candidate Site on the basis of its potential as a residential allocation – i.e. a site capable of
accommodating 5 units. Those sites put forward for less than this number by means of
seeking an amendment to the defined development limits therefore largely failed a number
of the stages of the assessment by default.

As part of the current consultation process into the 2nd Deposit LDP, the Council have again
published a “Site Assessment Table” (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 Council concluded as follows:
“Part of the site is considered appropriate for small scale rounding off, and the development
limits will be drawn to incorporate this element. In terms of the remainder of the site, it is
considered that there is sufficient and more suitable land available for development within
the settlement to accommodate the housing need.”

As can be seen, the process of assessment of our Client’s land by the Council has remained
unchanged, and whilst we support the inclusion of part of the land within the development
limits defined by Policy SD1, we consider the exclusion of the remainder of the site to be an
erroneous decision by the Council, as well as being an inconsistent approach taken by it in
the assessment of such sites. We therefore consider that the LDP is “unsound” and should
be changed, as it fails to meet the tests for “soundness”.

Specifically, we consider the approach of assessment taken by the Authority has been
inconsistent in terms of (a) other policy approaches taken by the Deposit LDP and (b) in
relation to other examples that were successfully included within defined development limits
of the 2nd Deposit LDP. We consider therefore that the whole of the land edged red in Plan
A, should be included within the defined development limits for Glanaman under the
provision of Policy SD1 of the Carmarthenshire Local Development Plan.

This formal representation letter supplements the following documents which comprise a
complete submission to the 2nd Deposit LDP Consultation stage:

- Completed 2nd Deposit LDP Representation Form
- Copy of Candidate Site Supporting Letter (August 2018)
- Copy of Candidate Site Location and Layout Plan (August 2018)

Response to Council’s Reasons for Non-Allocationof Site
Consistency with Other Policies of the Deposit LDP
The Council has provided no specific indication or guidance on how it has determined and
defined development limits within the 2nd Deposit LDP. It has therefore been difficult to
ascertain why some sites have been successfully included and others haven’t, which is
discussed further below. 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 a candidate site would make an acceptable addition to existing development
limits (A separate representation with regards to Policy SD1 has been made on this basis).

Taking all our Client’s land into consideration, together with the actual ‘on-the-ground’
physical attributes of adjoining and nearby land and its use, it is clear that it would adhere to
the second criteria listed above and so should in turn have been included within the defined
development limits of Glanaman. Its exclusion would be inconsistent with the provisions of
Policy HOM3 and indeed decisions taken by the Council with regard to other sites within the
Plan area. As a result and on this basis alone, the Plan as it currently stands is unsound.

Consistency with Other Settlement Limits
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 Glanaman, the Council has
been found to be inconsistent.
The plans below are an extract of the 2nd Deposit LDP Proposals Maps for two areas
(indicated by the red star) at the eastern and western edges of Garnant.

Plan C

Plan D

As can be seen, although both areas are defined by strong boundary features, neither have
a developed form. In addition, the area shown on Plan C, the land on the opposite side of
the adjoining public highway from the site is predominantly undeveloped and the area of
‘white land’ in question also does not have any planning history, but its inclusion within the
limits will extend the existing form of the settlement in a western ‘ribbon-like’ manner.

It should be noted that we do not object to the form of alteration to the development limits as
referred to above, as it secures a varied form of available housing development opportunities
for a community. However, their inclusion are in direct contrast and inconsistency to the
Council’s decision to exclude our Client’s land as a whole from the development limits.
Combined with our Client’s land representing a logical rounding-off of the respective area of
the settlement, the exclusion of it would represent a clear inconsistency in approach taken
by the Council, resulting in the Plan as it stands being unsound.

In conclusion, this Representation to the 2nd Deposit Draft of the Revised LDP has sought to
examine the Council’s reasons for non-inclusion of a Candidate Site within the defined
development limits. It has successfully addressed the reason put forward by the Council for
its exclusion and highlighted that its continued exclusion would represent a dangerous
inconsistency.

We therefore respectfully request that this Representation be given careful examination, and
consequently the land in question be included within the defined development limits as part
of the Carmarthenshire Local Development Plan to ensure that the document passes all the
relevant tests of soundness.

Include site within development limits

Land off Black Lion Road, Gorslas.

Further to the publication of the above document, we have been asked by our Clients 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 SD1 are of particular interest to our Clients. As a result, we
offer the following for the Authority’s consideration, and Inspector’s in due course.
Our Clients made a formal Candidate Site Submission in August 2018, which was
referenced SR/067/006, seeking the inclusion of the land within the defined development
limits of Gorslas as part of the Replacement Local Development Plan. The Candidate Site
centred mainly on a small paddock of poor agricultural land that fronted onto Black Lion
Road (edged red on Plan A), together with existing residential properties on the opposite
side of the highway.

Further agricultural enclosures are positioned to the east, but residential development is
located directly to the land’s north and on the opposite side of Black Lion Road to the west.
The site is also within walking distance to the range of community facilities and local services
the settlement and larger settlement of Cross Hands has to offer, as well as well serviced
bus stops that provide access to those services and facilities in the wider growth area.
As part of the preparation of the 1st Deposit LDP, the Council then considered the
submissions made and provided a summary of its assessment in its ‘Site Assessment Table’
(January 2020), which read as follows:
“Development of the site would result in a ribbon pattern of development contrary to general planning principles.”
As a result, the proposed 1st Deposit LDP made no changes to the development limits in the
environs of the Candidate Site to those forming part of the current adopted LDP, as illustrated by the Proposals Map extract below.

As part of the current consultation process into the 2nd Deposit LDP, the Council have again
published a “Site Assessment Table” (2023), which provides details of the Council’s analysis
of each received Candidate Site submission. We note that our Clients land was considered
as part of this process and as a result the Council concluded as follows:
“Development of the site would result in a ribbon pattern of development contrary to general
planning principles.”

As can be seen, the process of assessment of our Client’s land by the Council has remained
unchanged, as has its and the properties opposite’s exclusion from the development limits.
We however consider the exclusion of the remainder of the site to be an erroneous decision
by the Council, as well as being an inconsistent approach taken by it in the assessment of
such sites. We therefore consider that the LDP is “unsound” and should be changed, as it
fails to meet the tests for “soundness”.

Specifically, we consider the approach of assessment taken by the Council has been
inconsistent in terms of (a) other policy approaches taken by the Deposit LDP and (b) in
relation to other examples that were successfully included within defined development limits
of the 2nd Deposit LDP. We consider therefore that the whole of the land edged red in Plan A
and the existing 4 properties opposite, should be included within the defined development limits for Gorslas under the provision of Policy SD1 of the Carmarthenshire Local Development Plan.
This formal representation letter supplements the following documents which comprise a complete submission to the 2
nd Deposit LDP Consultation stage

Completed 2nd Deposit LDP Representation Form
- Copy of Candidate Site Supporting Letter (August 2018)
- Copy of Candidate Site Location and Layout Plan (August 2018)
Response to Council’s Reasons for Non-Allocationof Site
Consistency with Other Policies of the Deposit LDP
The Council has provided no specific indication or guidance on how it has determined and
defined development limits within the 2nd Deposit LDP. It has therefore been difficult to
ascertain why some sites have been successfully included and others haven’t, which is
discussed further below. 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 a candidate site would make an acceptable addition to existing development
limits (A separate representation with regards to Policy SD1 has been made on this basis).

Taking our Clients land into consideration, together with the actual ‘on-the-ground’ physical
attributes of adjoining and nearby land and its use, it is clear that it would adhere to the
second criteria listed above and so should in turn have been included within the defined
development limits of Gorslas. Its exclusion would be inconsistent with the provisions of
Policy HOM3 and indeed decisions taken by the Council with regard to other sites within the
Plan area. As a result and on this basis alone, the Plan as it currently stands is unsound.

Consistency with Other Development Limits
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 Gorslas and other settlements,
the Council has been found to be inconsistent.

The plans below are an extract of the 2
nd Deposit LDP Proposals Maps for two areas
(indicated by the red star) in the settlement of Llandybie and Llanwrda.

In the case of the Llandybie example, two separate parcels of undeveloped land have been included within the defined development limits, that extend the existing form of the
settlement in a southern ‘ribbon-like’ manner. The Llanwrda example is then an element of an existing larger agricultural enclosure, with two of its boundaries therefore currently
undefined and so extending the existing settlement’s limits beyond existing boundaries.

It should be noted that we do not object to the form of alteration to the development limits as
referred to above, as it secures a varied form of available housing development opportunities
for a community. However, their inclusion is in direct contrast and inconsistency to the
Council’s decision to exclude our Clients land and the aforementioned existing properties

Include site within development limits.

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 SD1 are of particular interest to our Client. As a result, we
offer the following for the Council’s consideration, and Inspector’s in due course.

The Site and Adjoining Area
This submission relates to the land edged red on Plan A below.

Plan A

The land relates to a small element of rear curtilage associated with 153 Heol Meinciau,
pictured below and circled red in Photograph 1.

Photograph 1

Photograph 2

As can be seen, the land in question consists of a managed area of grass and provides rear
access to an outbuilding serving No. 153. Access to the land is gained directly off Heol
Meinciau to the east, in between two further residential properties.

Immediately to the south and east of the site are existing residential properties and their
associated curtilages. To the west, as can be seen in Photograph 2 is a mature woodland,
with the land to the north then benefiting from an extant planning permission for 21
residential properties. The land edged red on Plan A is therefore completely encapsulated by
strongly defined boundaries and established land uses.
A short distance to the south then is the core of the settlement of Pontyates, with its
associated community facilities and local services and bus stops, all of which are within
walking distance of the site subject of this submission.
Under the provisions of the current adopted Carmarthenshire Local Development Plan, the
site (indicated by a red star in Plan B) adjoins, but remains outside of the currently defined
development limits, as illustrated by Plan B.

Plan B

Having reviewed the evidence base for the current adopted LDP, it is not apparent as to why
the site edged red in Plan A was excluded from the defined development limits.

2nd Deposit Local Development Plan
Although no submission was made by or on behalf of our Client at the Candidate Stage for
the inclusion of the land edged red in Plan A within the defined development limits for
Pontyates, we understand that the Council undertook a comprehensive review of the
development limits of all settlements within the County as part of its preparation of the 2nd
Deposit LDP. Notwithstanding this assessment, from reviewing the Proposals Map for the
2nd Deposit LDP, the situation with regards to the land in question appears to be unchanged,
as illustrated in Plan C below.

Plan C

Notwithstanding the above, the land directly to the south and north of the site edged red on
Plan A, is now proposed for inclusion within the development limits and allocated for housing
development respectively.

Consistency with Other Policies of the 2nd Deposit LDP
The Council 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 haven’t, which is discussed
further below. 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 a candidate site would make an acceptable addition to existing development
limits.

Taking the land edged red in Plan A into consideration, together with the actual ‘on-theground’
physical attributes of the two residential properties in question, adjoining and nearby
land and its use, it is clear that it would adhere to the second criteria listed above and so
should in turn have logically been included within the defined development limits of
Pontyates. Its exclusion would be inconsistent with the assessment provisions of Policy
HOM3 and indeed decisions taken by the Authority with regard to other sites within the Plan
area in terms of Policy SD1. As a result and on this basis alone, the Plan as it currently
stands is unsound.

Consistency with Other Development Limits
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 Pontyates and other
settlements, the Council has been found to be inconsistent.

The plans below are an extract of the 2nd Deposit LDP Proposals Maps for two areas
(indicated by the red star) in the settlement of Garnant and Pontyates, where the entirety of
a residential curtilage has been included within Development Limits, despite its shape and
size.

Plan C
(Garnant)

Plan D
(Pontyates)

There are of course numerous examples of similar situations throughout the Proposals Map
and so it is unclear why the land edged red on Plan A has been excluded from the
development limits for Pontyates, particularly when adjoining land to its north and south has.
The exclusion of it would therefore represent a clear inconsistency in approach taken by the
Council, resulting in the Plan as it stands being unsound.

In conclusion, this representation to the 2nd Deposit Draft of the Revised LDP has sought to
assess the suitability of the inclusion of the land edged red on Plan A, based on the current
provisions of the Plan and its decisions taken with respect to similar circumstances
elsewhere. In conclusions, it has successfully highlighted that its continued exclusion would
represent a dangerous inconsistency.

We therefore respectfully request that this Representation be given careful examination, and
consequently the land in question be included within the defined development limits as part
of the Carmarthenshire Local Development Plan to ensure that the document passes all the
relevant tests of soundness.

Include site within development limits

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 SD1 are of particular interest to our Client. As a result, we
offer the following for the Council’s consideration, and Inspector’s in due course.

The Site and Adjoining Area
This submission relates to the land edged red on Plan A below.

Plan A

The land relates to two residential properties and their associated garden areas (circled red
in Photograph 1 below), positioned to the north and south respectively of Maesglas Road,
Penygroes.

Photograph 1

As can be seen form the photograph above, each property contains a series of outbuildings
manicured lawns and ornamental plants, presenting therefore a very different appearance to
the agricultural enclosures to their north and west. Both properties then gain access directly
off Maesglas Road.

Immediately to the west of each property are two existing residential estates (Brynglas and
Cwrt y Ffynnon), with their associated domestic curtilages. Again, the site subject of this
submission is therefore clearly more akin to the land use to its west, as opposed to that to its
east.

A short distance to the west then is the core of the settlement of Penygroes, with its
associated community facilities and local services and bus stops, all of which are within
walking distance of the site subject of this submission.
Under the provisions of the current adopted Carmarthenshire Local Development Plan, the
site adjoins, but remains outside of the currently defined development limits, as illustrated by
Plan B.

Plan B

Having reviewed the evidence base for the current adopted LDP, it is not apparent as to why
the site edged red in Plan A was excluded from the defined development limits.
2nd Deposit Local Development Plan
Although no submission was made by or on behalf of our Client at the Candidate Stage for
the inclusion of the land edged red in Plan A within the defined development limits for
Penygroes, we understand that the Council undertook a comprehensive review of the
development limits of all settlements within the County as part of its preparation of the 2nd
Deposit LDP. Notwithstanding this assessment, from reviewing the Proposals Map for the
2nd Deposit LDP, the situation with regards to the land in question appears to be unchanged,
as illustrated in Plan C below.

Plan C

As can be seen, despite the ‘on-the-ground’ factual situation of the land in question, it
continues to be excluded from the development limits of the settlement of Penygroes.

Consistency with Other Policies of the 2nd Deposit LDP
The Council 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 haven’t, which is discussed
further below. 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 a candidate site would make an acceptable addition to existing development
limits.

Taking the land edged red in Plan A into consideration, together with the actual ‘on-theground’
physical attributes of the two residential properties in question, adjoining and nearby
land and its use, it is clear that it would adhere to the second criteria listed above and so
should in turn have logically been included within the defined development limits of
Penygroes. Its exclusion would be inconsistent with the assessment provisions of Policy
HOM3 and indeed decisions taken by the Authority with regard to other sites within the Plan
area in terms of Policy SD1. As a result and on this basis alone, the Plan as it currently
stands is unsound.

Consistency with Other Development Limits
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 Penygroes and other
settlements, the Council has been found to be inconsistent.

The plans below are an extract of the 2nd Deposit LDP Proposals Maps for two areas
(indicated by the red star) in the settlement of Garnant and Llanwrda.

Plan C
(Garnant)

Plan D
(Llanwrda)

In the case of the Garnant example, the property is a modest residential dwelling in a
substantial domestic curtilage, which of course is undeveloped. The property represents the
last in a line of properties, beyond to the east of which is agricultural land and so defined as
‘open countryside’. The Llanwrda example is then an element of an existing larger
agricultural enclosure, with two of its boundaries therefore currently undefined and so
extending the existing settlement’s limits beyond existing boundaries.

It should be noted that we do not object to the form of alteration to the development limits as
referred to above, as it secures a varied form of available housing development opportunities
for a community. However, their inclusion is in direct contrast and inconsistency to the
Council’s decision to exclude the land edged red on Plan A from the development limits,
which consists of existing residential properties. The exclusion of it would therefore
represent a clear inconsistency in approach taken by the Council, resulting in the Plan as it
stands being unsound.

In conclusion, this representation to the 2nd Deposit Draft of the Revised LDP has sought to
assess the suitability of the inclusion of the land edged red on Plan A, based on the current
provisions of the Plan and its decisions taken with respect to similar circumstances
elsewhere. In conclusions, it has successfully highlighted that its continued exclusion would
represent a dangerous inconsistency.

We therefore respectfully request that this Representation be given careful examination, and
consequently the land in question be included within the defined development limits as part
of the Carmarthenshire Local Development Plan to ensure that the document passes all the
relevant tests of soundness.

Include site within development limits in Llandybie

Gwernego Home Limited (”the company") was incorporated to and subsequently undertook
residential developments principally in the village of Llandybie.
These sites were substantiality completed and the company has been dormant for over thirty
years. it has been left holding the two parcels of land at Tanylan and Caeffynnon shown
respectively on the plans attached to the applications now made for the inclusion of parts of
those sites in the current version of the Local Development Plan.
The sites have no current use; It is highly unlikely that the company will ever trade again.
The applications are made on the following basis:
1. The company proposes that three or four properties should be constructed off what
is the existing hammerhead at Tanyian.
2. The company proposes that a single property should be constructed at Caeffynnon.
3. in each case the development suggested would amount to infill literally between the
existing properties.
4. The remaining land at both sites could become useful amenity land attached to the
new or any of the existing properties.
5. The proposal would effectively ’finish of? the developments and put the residual
land to good use.
6. The company wishes to work cooperatively with the local authority and is open to its
informed guidance as to how this land can be put to best use for the benefit of all
concerned.

Include the alternative site within the development limits for Saron (Ammanford) within the Revised LDP.

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Mr D Thomas to prepare and
submit an Alternative Allocation Report for the inclusion of land off Saron Road,
Saron within the proposed Development Limits (Policy SD1) of the settlement, (with
the intentions of it then being developed for residential purposes) in the forthcoming
replacement Carmarthenshire Local Development Plan (LDP).
1.2 At this stage it is estimated that the Site is capable of accommodating 4 units,
although further detailed investigation is currently underway, which may result in the
Site being capable of accommodating more. As a result and in the absence of any
detailed guidance prepared by the Council on how it has assessed Development
Limits, this report has , where appropriate, been prepared in line with the Authority’s
published site assessment and selection documents, with regarded to full housing
allocations (5+ units). The contents of this report therefore address each point raised
within these documents, where relevant.
1.3 The contents of this report therefore provide a comprehensive case for the inclusion
of the land within the defined Development Limits for Saron to enable its future
development for residential development purposes as a windfall site, and it should
also be read in conjunction with the accompanying information and indicative drawing
package, as well as a sustainability assessment undertaken in-line with the
Authority’s requirements.
Alternative Allocation Report April 2023
Land off Saron Road, Saron

2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Alternative Site relates to an elongated parcel of land measuring approximately
1.3 acres in area in total, edged red on the plan and the photograph below.
Plan A
Photograph 1
Alternative Allocation Report April 2023
Land off Saron Road, Saron
2.1.2 At present, the site currently has a cleared appearance, as illustrated by the
photographs below:
Photograph 2 Photograph 3
2.1.3 As can be seen from the above photographs, the site is generally level. In addition, all
it’s boundaries are clearly and well defined, by a mix of domestic fences and some
trees. The southern boundary also then includes an open drainage feature. Finally, as
can be seen from Photograph1 and 2, the Site is separated from the more open
landscape to the north by a line of mature coniferous trees.
2.1.4 Access to the site is currently gained via a gateway that leads onto the adjoining
adopted highway (Saron Road), pictured below.
Photograph 4
Alternative Allocation Report April 2023
Land off Saron Road, Saron
2.1.5 As can be seen from Photograph 1, the Site directly adjoins the existing form of the
settlement of Saron on three sides, with the more open landscape (a former opencast
site) positioned then to the north east, beyond a private access road that runs along
the northern edge of the Site.
2.1.6 Under the provisions of the current Carmarthenshire LDP, the Site presently lies
within the defined Development Limits for Saron, as illustrated below.
Plan B
2.1.7 As can be seen, the current Development Limits follow that of the existing settlement
and features that separate its associated areas with the wider open landscape pattern
beyond. However, in the 2nd Deposit LDP, the Council have proposed to amend the
Development Limits for Saron to those illustrated in Plan C.
Alternative Allocation Report April 2023
Land off Saron Road, Saron
Plan C
2.1.8 As can be seen, the Alternative Site has now been removed, which appears to be the
only amendment to the Limits for the area in question. However, no explanation has
been provided within the published documentation for this decision by the Council,
which appears inconsistent with others taken for other settlements in the County,
such as those examples below:
Plan D
(Folland Road, Garnant)
Alternative Allocation Report April 2023
Land off Saron Road, Saron
Plan E
(Land off A483, Llanwrda)
2.1.9 The inclusion of the Alternative Site would therefore be consistent with other
decisions taken by the Council in the preparation of its Replacement LDP, particularly
as its position represent a natural and logical location for the settlement’s expansion.
2.2 THE ADJOINING SETTLEMENT
2.2.1 As detailed above, the Alternative Site adjoins the existing built form of the settlement
of Saron. Saron is primarily a linear style development in form, with its historic
development having taken place along Saron Road and Nant-y-Ci Road. In more
recent times, development has then occurred ‘in-depth’ off both these routes in the
form of Clos Nant-y-Ci, Parc y Mynydd and Y Hafod.
2.2.2 In terms of community facilities and local services, the settlement of Saron includes a
village hall, play area, places of worship, as well as a regularly served bus stop.
However, the site (indicated by the red star on Plan F) is in close proximity to the a
number of nearby settlements such as Capel Hendre, Penygroes, Tycroes and
Ammanford beyond.
Alternative Allocation Report April 2023
Land off Saron Road, Saron
Plan F
2.2.3 The strong sustainable position of the Alternative Site should therefore be given full
consideration when considering potential future growth options of all scales.
Alternative Allocation Report April 2023
Land off Saron Road, Saron

3.0 THE PROPOSAL
3.1.1 As detailed previously, this submission seeks an amendment to the currently
proposed Development Limits for the settlement of Saron, to include the land edged
red on Plan A. As detailed previously, the Site represents a logical part of the existing
settlement, having a greater affinity to its form than the open wider landscape to its
north east.
3.1.2 In addition to its inclusion being consistent with other decisions taken by the Council
with regards to Development Limits for other settlements in the County, the inclusion
of the Site would also represent a deliverable windfall housing site, capable of
delivering at least 4 units, as illustrated in the indicative site layout drawing
reproduced below.
Plan G
3.1.3 Access to serve the site would be directly off Saron Road and compliant with current
highway authority requirements. The Site would also have easy connection to all
Alternative Allocation Report April 2023
Land off Saron Road, Saron
services and utilities, as well as being capable of dealing with surface water in a
sustainable manner due to on-site attributes.
3.1.4 The following sections of this Report therefore now provide further confirmation that
the Alternative Site represents a windfall site capable of providing a deliverable
contribution to the local housing supply.
Alternative Allocation Report April 2023
Land off Saron Road, Saron

4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 The Site does not contain any protected flora or fauna, or signs of their presence.
Notwithstanding this, any potential biodiversity assets the Site may include have been
given full consideration with regards to exploring its potential for residential
development. This has included the proposed retention and management of existing
site boundary features.
4.1.2 The Alternative Site has been assessed against data held on the “Magic Map”
website which details statutory and non-statutory National and Local sites of
ecological importance. Plan H below provides an extract of those records applied to
the Saron locality, with the red star denoting the position of the Alternative Site.
Plan H
4.1.3 As can be seen from the above, the Alternative Site does not form part of and neither
is it near any national or local designations. Although a number are within 2-4km of
the site, due to the intervening distance and topography, the development of the
Alternative Site will not have any detrimental impact on these features.
Alternative Allocation Report April 2023
Land off Saron Road, Saron
4.2 HISTORICAL ASSETS
4.2.1 Below is an extract from the ‘Archwilio’ website that represents a resource for the
Historic Environment Records of Wales, with the Alternative Site indicated by a red
star.
Plan I
4.2.2 As can be seen, neither the Alternative Site nor immediately adjoining settlement
includes any Scheduled Ancient Monuments, Listed Buildings or Conservation
Area’s. As a result, the development of the Site would not have any detrimental
impact on the setting or interest of any nearby historical asset.
4.3 ENVIRONMENTAL CONSTRAINTS
4.3.1 The Candidate Site is not categorised as being at risk of flooding in terms of the
Development Advice Maps or those produced by Natural Resources Wales, as
illustrated by the plans below (Alternative Site indicated by the red star).
Alternative Allocation Report April 2023
Land off Saron Road, Saron
Plan J
(Development Advice Maps)
Plan K
(Flood Maps for Planning)
4.3.2 Due to its greenfield nature, the Candidate Site has no ground contamination related
constraints.
Alternative Allocation Report April 2023
Land off Saron Road, Saron

5.0 CONCLUSION
5.1 Although currently undeveloped, the Alternative Site forms a logical extension to an
existing settlement, being well related to it and being positioned at a location within
the wider landscape to not form a prominent or logical part of the surrounding open
countryside. In fact, the Council’s current adopted development plan shares this
viewpoint and assessment, having included it within the Development Limits for the
settlement of Saron. Notwithstanding this, the Council has now determined to exclude
the Site from the Limits, but with no clear explanation as to why this has been done.
5.2 As discussed above, the Alternative Site is adjoined by the existing settlement and its
built form on three sides, with its remaining separated from the wider open landscape
by a strong natural feature in the form of mature trees. Its inclusion within the defined
Development Limits would on this basis alone represent a logical and consistent
decision.
5.3 The Alternative Site also does not face any constraints to its potential development in
terms of any ecological, flood risk, historic or ground condition interests. Combined
with this, the Site is also positioned in a sustainable location in terms of immediate
and wider community facilities and local services.
5.4 In view of the above and information provided in this Statement, it is respectfully
requested that the Alternative Site be included with the Development Limits for the
settlement of Saron.

Amend the Plan to include the site

We are instructed by Mr. J. Lewis & Mr S. Price to a make a formal representation to the
“soundness” of the Deposit Draft of the Carmarthenshire Local Development Plan.
Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/159/011, seeking inclusion of their land for future residential development within the
defined settlement limits of Tycroes within the Replacement Local Development Plan. The
Candidate Site comprises the frontage of a field enclosure set off the southern flank of
Pontardulais Road (A483 road) and lying immediately adjoining the Tycroes Business Park,
with its associated individual dwellinghouses fronting its access road.
The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our clients’ submission, reasons why the site was not selected for inclusion within the draft
settlement limits of Tycroes, as contained within the Second Deposit Draft.
We note that the submission successfully passed through all two Assessment Stages, being
Stage 1 (site compatible against the location of future growth presented in the Preferred
Strategy), and Stage 2A (Initial Detailed Site Assessment. It did not advance to Stage 2b
(Further Detailed Site Assessment) and Stage 3 (Sustainability Appraisal and Habitat
Regulation Assessment) of the Council’s site assessment.
The Site Assessment Table reports the reasons for non-inclusion as follows:
“There is sufficient and more suitable land available in Tycroes to meet its housing needs
which is better related and in closer proximity to the services and facilities in the village, the
site in question does not relate as well to these facilities."

Our clients consider the LDP is “unsound” and should be changed, as it fails to meet the
tests for “soundness”, in that the Plan “is not appropriate”, and “will not deliver”, as defined
by the Planning Inspectorate’s LDP Examinations Procedural Guidance.
Specifically, our clients consider that the draft settlement limits for Tycroes, as defined under
Policy SD1 “Settlement Limits”, should be amended to include the land as edged in red
upon the extract of the Proposals Map for Tycroes, as reproduced below in Figure 1.
The settlement limits should also include the adjoining Brynteg Garage cluster of
buildings and yard, and thus resemble the limits about Coopers to the west.

Figure 1 – Extract from Second Draft Proposals Map with site edged in red
This formal representation letter supplements the following documents which comprise a
complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Copy of Candidate Site Submission Report (August 2018)

Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits
1.0 Overall Housing Supply in Tycroes
1.1 The Council consider that the only reason for the Candidate Site at Pontardulais
Road not being included within the Second draft Plan as a Residential Allocation is
that they believe that there are sufficient residential sites allocated elsewhere in the
settlement. They also comment that this site is not well related to settlement facilities.
1.2 The proposals under this Representation merely seek the addition THREE residential
units to the overall housing supply of Tycroes, which forms part of the principal
service centre centred upon the Ammanford Cluster as defined within the draft LDP.
Figures 2 & 3 below provides an extract of the indicative site layout plan and location
plan for this Representation site.

Figure 3 – location plan of site, edged in red for identification
1.3 The field frontage in question lies at a highly sustainable position along the trunk
road, which would allow new residents to continue to access the excellent community
facilities in the locality, such as the nearby Capel Hendre Industrial Estate, Tycroes
Business Park, Tycroes and Saron Primary Schools, convenience shops at Tycroes
Square and main bus route that includes Pontardulais Road, with X13 services
calling every 20 minutes between Ammanford and Swansea.
2.0 Consistency with Other Policies of the Deposit LDP
2.1 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, which is discussed further below. 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
2.2 It is logical therefore that the same assessment criteria should be utilised in
assessing whether or not a candidate site would make an acceptable addition to
existing development limits. Taking our client’s land into consideration, together with
the actual ‘on-the-ground’ physical attributes of adjoining and nearby land and its
use, it is clear that it would adhere to the second criteria listed above and so should
in turn have been included within the defined development limits of Tycroes. The land
in question if developed is set within a small number of dwellings would appear as a
recognised grouping of established development immediately alongside the
remainder of the settlement. Its exclusion would be inconsistent with the provisions of
Policy HOM3 and indeed decisions taken by the Authority with regard to other sites
within the Plan area. As a result, and on this basis alone, the Plan as it currently
stands is unsound.
3.0 Housing Land Availability in Second LDP Draft

3.1 The Ammanford / Cross Hands Cluster aims to provide an additional 1257 residential
units over the Plan period to 2033, and thus the adjustment of the settlement limits to
provide an additional 3 units will not lead to an over-supply of dwellinghouses within
the Cluster. The Council consider there to better sites allocated for future
development within the Second LDP Draft.
3.2 We have therefore examined and researched sites which have been brought forward
as Residential Allocations with the Deposit Draft. Only two sites are allocated for
housing in Tycroes, but in both cases those allocations have already been fully
completed. Figure 4 below illustrates those two sites at Fforestfach, off Heol
Tycroes, and land off Ffordd y Deri by Pobl Group, adjoining the Rugby Club.

3.3 We have examined and researched sites which have been brought forward as
Residential Allocations with the Second Deposit Draft. On behalf of clients in this LDP
Cluster, we have made formal Representations seeking the omission of the following
draft Allocations:
Site PrC3/h4 - Tirychen Farm, Dyffryn Road, Penybanc - for 150 units.
Planning permission was last granted in 2014 for 289 dwellings, under Application
E/21633. However, that permission was only granted in outline form. It
subsequently lapsed, and the landowners sought to vary conditions upon that
permission to extend the validity of the outline permission. That Variation of Condition
application was finally approved in October 2019, under Application E/38686.
The recently approved Variation of Condition permission does little to display any real
progress in the deliverability of the site. It merely amounts to the landowners seeking
to continue to benefit from an outline planning permission at the site. Full planning
permission was granted as far back as 1992 (D6/19332), which subsequently lapsed.
The Land continued to be allocated within the Dinefwr Local Plan (1996), and
subsequent Carmarthenshire Unitary Development Plan (2003). No progress was
made in bringing the site forward, and yet it was allocated within the Local
Development Plan in 2014. Consequently, thirty years of Development Plan
allocations have elapsed without any signs of delivery of this site. Clearly, there is
no historic demand for a site of this scale in this part of the Ammanford area. More
physically challenging sites, such as the re-development of the Betws Colliery site at
Betws and Cae Pound at Cross Hands West Tip have come forward long before
Tirychen, and yet still the Council is prepared to allocate the site once again in a new
Development Plan.

The decision to retain Tirychen Farm after a period of 30 years within the LDP is
shown to be inconsistent, as does not sit with LDP Procedural Guidance which
encourages Local Planning Authorities to only re-allocate sites based upon firm
evidence of deliverability.
3.4 Site PrC3/h22 Land at Pant-y-Blodau in Penygroes for 79 units.
The site was allocated as GA3/h35 in the Adopted 2014 LDP for 90 units. Planning
Permission was granted in April 2015, and yet some 8 years later, no work has been
undertaken on the site, and the land remains undeveloped. No indication is provided
within the Site Assessment Report (January 2023) as to why the Council consider
this long-standing allocation to remain in the Plan?
3.5 We submit that the draft allocations at Tirychen and Pantyblodau be omitted from the
Plan, and that housing allocations be redistributed to modest Candidate Sites, such
as the additional 3 units proposed off Pontardulais Road.
3.6 There is clear evidence in Tycroes, Capel Hendre and Saron that such modest sites
are far more likely to be brought forward and developed in full by regional and small
housebuilders given that construction and development costs are more likely to be
viable in relation to house sales and the general housing market in this part of Carmarthenshire.

In conclusion, this Representation to the Second Deposit Draft of the Revised LDP has
sought to examine the Council’s reasons for non-inclusion of a Candidate Site.
Our clients have illustrated that their indicative proposals to construct three dwellinghouses
at a prominent junction of Pontardulais Road and the Tycroes Business Park, and which will
not appear at odds to the prevailing spatial pattern of development in Tycroes and Coopers.
The locality has numerous examples of modern clustered development being completed at
road frontages along the trunk road, which in turn, advocates that the form of development
proposed at Pontardulais is no different, resulting in it being respectful to the character and
setting of the locality.
We respectfully request that this Representation be given careful examination, and
consequently the defined settlement limits of this part of Tycroes realigned to include the
Representation Site in the Proposals Map of the adopted Local Development Plan.

See attachment for maps

Include site in the Plan.

I would like to submit observations on the Carmarthenshire Revised Local Development Plan 2018 – 2033 in relation to the development limit at Cynheidre, Llanelli, especially in the postal code area SA15 5YD. I have land in this area, part of which I would wish to develop.

My intention would be to construct a maximum of four dwellings which would not increase the village by 10% of the current numbers of dwellings. It is a logical extension to round off the development pattern that fits in with the character of the village form and landscape. The land is of a scrub nature and new development would be more aesthetically pleasing than it is at present. I do not wish to construct further dwellings creating a ribbon development and, as I own the land beyond the requested area marked in red on the attached map for around 150 yards, I have no intention of applying for further development.
I ask that this small area is included within the Local
Development ‘black-line’ limit for Cynheidre. There is an existing physical feature in the form of two dwellings recently completed across the road from the land I refer to. The whole of the proposed land is well within a road subject to a thirty miles per hour speed limit.

These recently completed detached dwellings on the opposite side of the road do not yet show on the current maps. Furthermore, my proposed ‘black line’ ends opposite the allowed planning limit near the two new dwellings which does not extend the village beyond the existing boundary.

Mains drainage is present immediately alongside my proposed land as is mains electricity. Mains water is available directly on the opposite side of the road.

Please find a map of the area concerned with the approximate area marked in red.

I fully accept and support the Homes in Rural Villages HOM3.

No change to the Plan

We are instructed by Ms L and Mr A Edwards to make a formal representation with regards
to the above land and the Deposit Draft of the Carmarthenshire Local Development Plan.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/090/002, seeking the inclusion of their land within the development limits of Llanarthne
as part of the Replacement Local Development Plan. The Candidate Site comprised of part
of a single enclosure, with its northern boundary fronting onto the adjoining public highway,
from which access to it was gained. Its eastern and western boundaries are then well
defined by existing development, whilst it’s remaining southern boundary then leads on to
the remainder of the agricultural enclosure it forms part of. The land therefore clearly
represented a logical infill opportunity within the settlement and its extents are illustrated by
the red line below.

Plan A

Following its due consideration, the Council then included the land in question within the
Development Limits for the settlement of Llanarthne in its Deposit LDP, published in January
2020. However, for reasons outlined by the Council in their current submissions, a revised
second edition Deposit LDP was then prepared.

As part of the current consultation process into the 2nd Deposit LDP, the Council have again
published a “Site Assessment Table” (2023), which provides details of the Council’s analysis
of each received Candidate Site submission. We note that our Clients land was considered
as part of this process and as a result the Authority concluded as follows:

“The site cannot accommodate 5 or more dwellings. It will be included within development
limits due to its position in relation to the existing built form, and will contribute to small sites.”

As a result of the above, Plan B represents an extract of the Deposit LDP Proposals Map for
Llanarthne, clearly now identifying our Clients land as lying within the defined development
limits:

Plan B

We therefore welcome the decision of the Authority to concur with the representation
previously made in relation to our Clients land and fully support their decision to include the
land within the development limits.

Include the site within the development limits of Llandybie

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 SD1 are of particular interest to our Client. As a result, we
offer the following for the Authority’s consideration, and Inspector’s in due course.

Our Client made a formal Candidate Site Submission in August 2018, which was referenced
SR/082/006, seeking the inclusion of the land within the defined development limits of
Llandybie as part of the Replacement Local Development Plan. The Candidate Site centred
mainly on a small agricultural paddock that fronted onto Kings Road, edged red on Plan A.

Plan A

Further agricultural enclosures are positioned to the east, but residential development is
located directly to the land’s south and on the opposite side of Kings Road to the west. The
Site is also within walking distance to the range of community facilities and local services the
settlement has to offer, as well as well serviced bus stops that provide access to those
services and facilities in the wider growth area.

As part of the preparation of the 1st Deposit LDP, the Council then considered the
submissions made and provided a summary of its assessment in its ‘Site Assessment Table’
(January 2020), which read as follows:

““Inclusion of the site would result in extending a ribbon pattern of development contrary to
general planning principles.”

As a result, the proposed 1st Deposit LDP made no changes to the development limits in the
environs of the Candidate Site to those forming part of the current adopted LDP, as
illustrated by the Proposals Map extract below.

Plan B

As part of the current consultation process into the 2nd Deposit LDP, the Council have again
published a “Site Assessment Table” (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 Council concluded as follows:

“The site cannot accommodate 5 or more dwellings. Inclusion of the site would result
extending a ribbon pattern of development contrary to general planning principles.

As can be seen, the process of assessment of our Client’s land by the Council has remained
unchanged, as has its exclusion from the development limits. We however consider the
exclusion of the site to be an erroneous decision by the Council, as well as being an
inconsistent approach taken by it in the assessment of such sites. We therefore consider
that the LDP is “unsound” and should be changed, as it fails to meet the tests for
“soundness”.

Specifically, we consider the approach of assessment taken by the Council has been
inconsistent in terms of (a) other policy approaches taken by the Deposit LDP and (b) in
relation to other examples that were successfully included within defined development limits
of the 2nd Deposit LDP. We consider therefore that the whole of the land edged red in Plan
A, should be included within the defined development limits for Llandybie under the provision
of Policy SD1 of the Carmarthenshire Local Development Plan.

This formal representation letter supplements the following documents which comprise a
complete submission to the 2nd Deposit LDP Consultation stage:

- Completed 2nd Deposit LDP Representation Form
- Copy of Candidate Site Supporting Letter (August 2018)
- Copy of Candidate Site Location and Layout Plan (August 2018)

Response to Council’s Reasons for Non-Allocation of Site
Consistency with Other Policies of the Deposit LDP
The Council has provided no specific indication or guidance on how it has determined and
defined development limits within the 2nd Deposit LDP. It has therefore been difficult to
ascertain why some sites have been successfully included and others haven’t, which is
discussed further below. 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 a candidate site would make an acceptable addition to existing development
limits (A separate representation with regards to Policy SD1 has been made on this basis).
Taking our Client’s land into consideration, together with the actual ‘on-the-ground’ physical
attributes of adjoining and nearby land and its use, it is clear that it would adhere to the
second criteria listed above and so should in turn have been included within the defined
development limits of Llandybie. Its exclusion would be inconsistent with the provisions of
Policy HOM3 and indeed decisions taken by the Council with regard to other sites within the
Plan area. As a result and on this basis alone, the Plan as it currently stands is unsound.

Consistency with Other Development Limits
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 Llandybie and other
settlements, the Council has been found to be inconsistent.

The plans below are an extract of the 2nd Deposit LDP Proposals Maps for two areas
(indicated by the red star) in the settlement of Llandybie, Glanamman and Llanwrda.

Plan C
(Llandybie)

Plan D
(Llanwrda)

Plan E
(Glanamman)

In the case of the Llandybie example, two separate parcels of undeveloped land have been
included within the defined development limits, that extend the existing form of the
settlement in a southern ‘ribbon-like’ manner, and the Garnant example follows a similar
pattern. The Llanwrda example is then an element of an existing larger agricultural
enclosure, with two of its boundaries therefore currently undefined and so extending the
existing settlement’s limits beyond existing boundaries.
It should be noted that we do not object to the form of alteration to the development limits as
referred to above, as it secures a varied form of available housing development opportunities
for a community. However, their inclusion is in direct contrast and inconsistency to the
Council’s decision to exclude our Client’s land and the aforementioned existing properties
from the development limits. Combined with our Client’s land representing a logical
rounding-off of the respective area of the settlement (particularly when the on-the-ground
position is given full consideration), the exclusion of it would represent a clear inconsistency
in approach taken by the Council, resulting in the Plan as it stands being unsound.

In conclusion, this Representation to the 2nd Deposit Draft of the Revised LDP has sought to
examine the Council’s reasons for non-inclusion of a Candidate Site within the defined
development limits. It has successfully addressed the reason put forward by the Council for
its exclusion and highlighted that its continued exclusion would represent a dangerous
inconsistency.

We therefore respectfully request that this Representation be given careful examination, and
consequently the land in question be included within the defined development limits as part
of the Carmarthenshire Local Development Plan to ensure that the document passes all the
relevant tests of soundness.

Amend Plan to include the site

Gwernego Home Limited (“the company”) was incorporated to and subsequently undertook
residential developments principally in the village of Llandybie.

These sites were substantially completed and the company has been dormant for over thirty
years. it has been left holding the two parcels of land at Tanylan and Caeffynnon shown
respectively on the plans attached to the applications now made for the inclusion of parts of
those sites in the current version of the Local Development Plan.

The sites have no current use. it is highly unlikely that the company will ever trade again.
The applications are made on the following basis:

1. The company proposes that three or four prOperties should be constructed off what
is the existinghammerhead at Tanylan.

2. The company proposes that a single preperty should be constructed at Caeffynnon.

3. in each case the development suggested would amount to infill literally between the
existing properties.

4. The remaining land at both sites could become useful amenity land attached to the
new or any of the existing properties.

5. The proposal would effectively ’finish of? the developments and put the residual
land to good use.

6. The company wishes to work cooperatively with the local authority and is open to its
informed guidance as to how this land can be put to best use for the benefit of all
concerned.