SD1: Terfynau Datblygu

No change to the Plan

I am in support of your proposed boundary change in principle; however, in accordance with your sustainability policy; it would be advantageous to extend the boundary in a westerly direction by 25 metres to alleviate constrictions to the existing owners. See proposal map RCH-10 -attached.

Include land within limits

I am in support of your proposed boundary change in principle; however, in accordance with your sustainability policy; it would be advantageous to extend the boundary in a westerly direction by 25 metres to alleviate constrictions to the existing owners. See proposal map RCH-10 -attached.

Include site within the Plan

This submission is made in response to the latest consultation of the deposit revised
development plan of Carmarthenshire County Council.

This representation is made seeking
the inclusion of this site within the LDP. Details of the site are as follows;

- Address – Land adjacent to Gwastad, Penboyr, Felindre, Llandysul, Sir Gar, SA44 5FJ.
- Site area - 0.125ha.
- The proposal is for 2 residential dwellings.

The sites site plan is attached. Red line indicated the proposed site for the 2 dwellings. Blue
line is land within ownership.
Also find attached the integrated sustainability appraisal.
The application site is currently unutilised and is located in the centre of the small rural
settlement of Penboyr. The applicant has been approached by numerous local young people
asking to purchase a plot on site to build their own home.

The proposed site would
represent a logical infill within this rural village and would be within the proposed LDP
strategy. The applicant outlines that there are approximately 20 residential dwellings within
the settlement of Penboyr, and therefore the 2 proposed would represent a modest 10%
growth.

If you require any additional information relating to this planning application, please do not
hesitate to get in touch.

Exclude the site from the development limits.

Site ref: SR/019/001
Candidate site ref: CA 0464
Site location: Capel Iwan

This site is proposing to change its status to residential.

This proposed change of status would be detrimental to the village of Capel Iwan.
The site is outside the Development Plan boundary.
There are no amenities in the village to accommodate a potential increase in population. Therefore, more traffic would be expected.
The existing roads are narrow single track with numerous blind corners- long standing hedges may be removed.
There are already existing plots in the village with building permission that have lain dormant for some years.
Any development on this plot would reduce the absorption of rainfall causing more water run-off overloading the already stretched sewerage system and potential for flooding.
The reduction in grasslands is known to reduce the absorption of carbon dioxide from the atmosphere - a factor which is becoming an increasing concern .
An increase in building development would alter the village environment - it being a quiet rural area which already has seen a significant increase in traffic as shopping habits have changed.

Include site within the Plan

We are instructed by Mr. T. Jones to a make a formal representation to the “soundness” of
the Deposit Draft of the Carmarthenshire Local Development Plan.
Our client made a formal Candidate Site Submission in August 2018, which was referenced
SR/117/005 seeking the inclusion of the land within the defined development limits of
Nantgaredig as part of the Replacement Local Development Plan. The Candidate Site is set
off the eastern flank of Station Road, upon the road frontage, with the farmhouse and farm
outbuildings of Ty Newydd located to its rear. A further detached property, “Clychaur Nant”
lies immediately to its southern perimeter, with the Nantgaredig Primary School occupying a
wide roadside frontage off the opposite, western flank of the road.
Our client’s Candidate Site related to the need to have settlement limits reformed about this
small parcel of land which essentially is in two roadside parts. The northern part lies in a
separate field parcel adjoining a bungalow known as “Portfield” and is noted that this part of
the Candidate Site has been included within the Second Deposit draft settlement limits.
The 2014 adopted settlement limits of the LDP included for a plot of land off the southern
part of the southern side of the farm driveway to Ty Newydd, and set between that drive at
Clychaur Nant, is it noted that it continues to be included with Second Deposit draft limits.
However, the central portion of the Ty Newydd road frontage, being some two-thirds of the
Candidate Site has been excluded.
The site lies within walking distance to the range of community facilities and local services
the settlement has to offer, such as a Primary School, public house and Medical Surgery, as
well as well serviced bus stops that provide access to those services and facilities in the
wider growth area of Carmarthen, which is only some 10 minutes’ drive via the A40 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, but it should be
noted the assessment was undertaken in manner that largely considered each
Candidate Site as if it were being proposed for 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 failed the
assessment by default. Our client made a submission at Candidate Site stage; however, we
have noted that the Council did not entertain an amendment of the settlement limits, and the
following reason for their exclusion was given:
“The site is unable to deliver 5 units due to topographical constraints, however the
development limits will be drawn to include a small part of the site.”
We are at a loss to understand such a statement as our client’s Candidate Site submission
did not seek an allocated site of 5 or more dwellings. Instead, Mr Jones merely sought
an amendment to the settlement limits to accommodate 3-4 dwellings, and for the limits to
correspond and “mirror” the established development off the opposite, western flank
of Station Road, be that the primary school and neighbouring individual houses.
We however consider that the exclusion of this part of Nantgaredig to be an erroneous
decision by the Authority, 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”, in that the Plan “is not appropriate”, as
defined by the Planning Inspectorate’s LDP Examinations Procedural Guidance.
Specifically, we consider the approach of assessment taken by the Authority to such a
proposal 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 Deposit LDP. We consider therefore that the land edged red in
Figure 1 below, should be included within the defined development limits for Nantgaredig
under the provision of Policy SD1 of the Carmarthenshire Local Development Plan.
Figure 1 – Extract from Second Deposit Draft with Representation Site
highlighted 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
Part of Candidate
Site included within
draft limits
Part of site
excluded from
draft settlement
limits
Response to Council’s Reasons for Non-Allocation of Site
Consistency with Other Policies of the Deposit LDP
The Authority has provided no specific indication or guidance on how it has determined and
defined development limits within the Deposit LDP. It has therefore been difficult to ascertain
why some sites have been successfully included and others 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
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 first criteria listed above and so should in turn have been included within the defined
development limits of Nantgaredig. The land in question if developed is set within a roadside
frontage of established number of dwellings and would appear as an infill plot immediately
alongside the remainder of the settlement. There are no “topographic issues” preventing its
inclusion, as shown from the graphic images at Figures 2 and 3 below. It is a relatively level
enclosure, mirroring that off the southern side of the farm driveway.
The land does slope and ascend from its road frontage, but the increase / difference in
profile is not dramatic that would prevent sympathetically designed houses from being
implemented at this location. The ground could be excavated to reveal terraced plateaus for
new dwelling footprints with foreground parking at a lower level, and rear gardens terraced
above. Such a form of development over gently sloping land is not uncommon in
Carmarthen, and there are numerous example of such developments gaining planning
permission upon far steeper hillsides, some of which are provided in example cross sections
below, at Figures 4 and 5. In any event, the retention of the majority of the tree cover along
the road frontage would “visually absorb” and mask off the impact of such split-level
development, to a degree that passers-by upon Station Road would not be adversely
affected and the village character would be preserved.
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.
Figure 2 – view of Candidate Site off northern side of Ty Newydd farm drive
with no “topographical issues” displayed
Figure 3 – view taken along farm access driveway and orientated towards
Candidate Site
Figure 4 – typical cross section of how gently sloping sites can be successfully
designed to incorporate topographic changes in levels in Drefach – granted
planning permission within the last 18 months by the Council
Figure 5 – example of a far more precipitous slope being proposed for new
housing development in Burry Port, with wholesale excavation required to form
a level footprint. Nevertheless, the Council granted planning permission within
the last 18 months
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 Nantgaredig, the Authority has
been found to be inconsistent. In this case, the Council consider that land adjoining
Allocated Site SuV17/h1 should be included within the settlement limit, as shown in Figure 6
below, being is an extract of the Deposit LDP Proposals Map
Figure 7 highlights the inclusion of “white land” at the southern extremity of Station Road
where the limits have been extended to include undeveloped land at the western flank of the
highway. Nearby Capel Dewi has also had its settlement limits extended to include land at its
extremity, but in that case without that addition being logically capable of being described as
“infilling” or “rounding-off.” Figure 8 illustrates that nearby circumstance.
Figure 6 – Undeveloped land at Station Road within defined limits
marked with arrow
Figure 7 – Undeveloped land at Station Road in Nantgaredig within defined
limits marked with red arrow
Figure 8 – land included at eastern extremity of Capel Dewi
As can be seen, three separate undeveloped parcels of land have been included within
defined development limits at Nantgaredig and Capel Dewi. They constitute either the
promotion of infilling or extend the existing form of the settlement as such that they
respectively form part of the settlement. Or in the Capel Dewi neither, which is even more
baffling and illogical to comprehend?
It should be noted that we do not object to this form of identified land parcels to those
development limits, as it secures a varied form of available housing development
opportunities for a community. However, their inclusion is a direct contrast and inconsistency
to the Authority’s decision to exclude this part of Ty Newydd from the development
limits. Combined with our client’s land representing a logical “infilling” of the respective area
of the settlement, the exclusion of it would represent a clear inconsistency in approach taken
by the Authority, resulting in the Plan as it stands being unsound.
In conclusion, this Representation to the Deposit Draft of the Revised LDP has sought to
examine the Council’s reasons for non-inclusion of the Candidate Site at Nantgaredig within
specified defined development limits. It has successfully addressed the reason put forward
by the Authority 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.

Change the development limits in Llanboidy

I object to forward planning SD1 because of a small area which excludes the entrance and an existing building, which has not been included in the LDP 2018-2033
See RCH 11

Allocate candidate site reference SR/019/008.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/019/008, seeking the inclusion of their land within the development limits of Capel Iwan
as part of the Replacement Local Development Plan.
The Candidate Site comprises part of a field enclosure, being irregular in shape but shares a
common boundary on two sides with detached dwellinghouses which fronts the main road
running north to south through the village centre. The land benefits from an undeveloped
gap set between existing bungalows and the farm buildings of Cruglwyd set just to the north
of the field. Its extents are illustrated by the site edged in red at Figure 1 below.
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 Capel Iwan as contained within the Deposit Draft.
We note that the submission successfully passed through all three Assessment Stages,
being Stage 1 (site compatible against the location of future growth presented in the
Preferred Strategy), Stage 2A (Initial Detailed Site Assessment), Stage 2b (Further Detailed
Site Assessment) and Stage 3 (Sustainability Appraisal and Habitat Regulation Assessment)
of the Council’s site assessment. It therefore crucially was adjudged acceptable in all
technical aspects of formal assessment, but was only rejected at the final selection stage,
with reasons for reported as follows:
“There is sufficient and more suitable land available for residential development within the
settlement to accommodate its housing need.”
Figure 1 – Google Earth image of Candidate Site at Capel Iwan
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 Capel Iwan, 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 Capel Iwan, as reproduced below in
Figure 2.
Figure 2 – Extent of Representation Site in Second Deposit Draft Plan in centre
of Capel Iwan, and 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
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits
1.0 Overall Housing Supply at Capel Iwan and Cluster 4 within Deposit Draft
1.1 The Council consider that the only reason for the Candidate Site south of Cruglwyd
farmyard as not being included within the draft Plan as a Residential Allocation is that
they believe that there are sufficient residential sites allocated elsewhere in the
settlement. On this basis, it must be accepted that the form of the Candidate Site set
as an infill opportunity between established properties which front the minor road
running north from the village towards Newcastle Emlyn, together with the proposals
to provide individual vehicular accesses onto that C class road is deemed
acceptable, and in accord with the spatial form and character of the settlement.
1.2 The proposals under this Representation merely seek the addition of 3 residential
units to the overall housing supply of Capel Iwan, which is regarded as a Tier 3
Sustainable Village, identified within the Teifi Valley Cluster within the draft LDP.
Figure 3 below provides an extract of the indicative site layout plan for this
Representation site. The proposals can provide for 3 bed detached bungalows, each
served off their own accesses with traditional rear garden space.
Figure 3 – Proposed Indicative Site Layout Plan for Representation Site
1.3 The Teifi Valley Cluster (Cluster 4) aims to provide an additional 218 residential units
over the Plan period to 2033, with Capel Iwan (Settlement SuV38) providing only one
allocated site at “Maes-y-Bryn” expected to provide only 6 units to that overall Cluster
total (reproduced at Figure 4 below). We would submit in the first instance that the
realignment of settlement limits to provide an additional 3 units will not lead to an
over-supply of dwellinghouses within the Cluster, nor the defined Capel Iwan
settlement supply.
Figure 4 – Extract from Policy HOM1 for Capel Iwan
1.4 We have examined and researched sites which have been brought forward as
Residential Allocations with the Deposit Draft. In Capel Iwan great emphasis within
the Draft Plan has been placed upon the continued allocation of the above proposed
housing site, which is still left allocated from the 2008-21 Local Development Plan.
The above table indicates that the Council expect that site to be delivered to the
market between LDP years 6-10, being 2023 to 2028. Therefore, given that it already
benefits from being allocated in the current adopted LDP, the landowner or
prospective purchase can seek planning permission in the knowledge of its
acceptance in principle. Indeed, when questioned by the Council as part of their
formal review of Allocated Sites from the 2014 adopted Plan they reported that “The
site was submitted as a candidate site and as such, the agent has provided evidence
showing its viability.”
1.5 However, we note that no application for planning permission has ever been
submitted on the site, despite it appearing in an adopted LDP for nine years. The
site made up part of the residential allocation SC7/h2 as reproduced at Figure 5
below.
Figure 5 - Extract of Current LDP Proposal Map for Capel Iwan
and Maes y Bryn Allocation
1.6 The site was also included with the Carmarthenshire Unitary Development Plan,
adopted in 2006, and accordingly it has laid undeveloped and not subject of any
planning application for a combined total of 17 years. We will lodge separate formal
representations seeking omission of this site, as it clearly is undeliverable, and
the landowner has no intent of bringing it forward for development.
2.0 Newcastle Emlyn
2.1 We have also examined Draft Allocations within the nearby town of Newcastle
Emlyn, which is regarded as a Tier 2 Local Service Centre in the new LDP. Figure 6
below provides a snapshot of the three allocations in the town.
Figure 6 – Newcastle Emlyn HOM1 Allocations
2.2 “Trem-Y-Ddol” allocated as SeC12/h1 for 17 dwellings. The site was allocated in the
adopted 2014 Local Development Plan, and also Carmarthenshire Unitary
Development Plan in 2006. Full Planning Permission was sought under application
W/18258 for the development of “17 Dwellings, Site Layout and Access Road” in
2008. The application lay undetermined until 2022 – a period of 15 years – until it
was finally refused due to the Applicants’ failure to commit to making a contribution
towards Affordable Housing.
2.3 It is clear that to leave a planning application continue for so long without a decision
is testament to a lack of desire and commitment by the landowner to implement a
development upon the site, and accordingly it is plainly undeliverable as a future LDP
allocation.
2.4 Finally, “Dolcoed” is allocated as Site SeC12/h3, apparently capable of providing 20
new homes, in two phases over the 10 years remaining of this new Replacement
LDP. However, upon closer examination, it is revealed that there have been no
planning applications made relating to the site subject of this allocation to date.
This is despite the site being allocated in the Carmarthenshire Local Development
Plan (2014) as allocation (T2/4/h1). After a period of 10 years, not a single dwelling
has been proposed at this edge of town site, and yet the Council persist in awarding
this inability to deliver by continuing the allocation in the new Replacement LDP.
2.5 We therefore highlight that a combined total of 37 dwellings upon two sites within 3
kilometres of our client’s site at Capel Iwan have remained stagnant and their
continued allocation in a new LDP for a further 10 years is undeniably questionable.
The Council should be seeking more deliverable small sites such as that promoted
by our client at Cruglwyd Farm, which should be included in settlement limits in
replacement of one if not all the above three sites.
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 3 dwellinghouses will
not appear at odds to the prevailing spatial pattern of development in Capel Iwan. The
proposals will provide a short frontage of bungalows 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 Capel Iwan realigned to include the
Representation Site, in a realigned settlement limits in the Proposals Map of the adopted
Local Development Plan.

Remove the site from the development limits.

SR/019/002
CA0465
Capel Iwan

This site is proposing to change its status to residential. This would be detrimental to Capel Iwan. This site is outside the development boundary listed for Capel Iwan - June 2011 SC7.

This proposed change of status would be detrimental to the village of Capel Iwan.
The site is outside the development plan boundary.
There are no amenities in the village to accommodate a potential increase in population therefore more traffic would be expected.
The existing roads are narrow single track with numerous blind corners - long standing hedges may be removed.
There are already existing building plots in the village with building permission that have land dormant for some years.
Any development on this plot would reduce the absorption of rainfall causing more water run-off overloading the already stretched sewage system and potential for flooding.
The reduction in grassfields is known to reduce the absorption of carbon dioxide from the atmosphere - A factor which is becoming an increasing concern.
An increase in building development would alter the village environment - It being a quiet rural area which already has seen a significant increase in traffic as shopping habits have changed.

Exclude the site from the development limits.

SR/019/007
CA 0774
Capel Iwan

This site is proposing to change its status to residential. This would be detrimental to Capel Iwan. This site is outside the development boundary listed for Capel Iwan - June 2011 SC7.

This proposed change of status would be detrimental to the village of Capel Iwan.
The site is outside the development plan boundary.
There are no amenities in the village to accommodate a potential increase in population therefore more traffic would be expected.
The existing roads are narrow single track with numerous blind corners - long standing hedges may be removed.
There are already existing building plots in the village with building permission that have land dormant for some years.
Any development on this plot would reduce the absorption of rainfall causing more water run-off overloading the already stretched sewage system and potential for flooding.
The reduction in grassfields is known to reduce the absorption of carbon dioxide from the atmosphere - A factor which is becoming an increasing concern.
An increase in building development would alter the village environment - It being a quiet rural area which already has seen a significant increase in traffic as shopping habits have changed.

No change to the Plan

This representation supports the inclusion of this site off Heol Morlais within
the development limits for Trimsaran.
Its inclusion within the development limits will not lead to any additional
environmental pressure, but instead will foster sustainable growth and allow
for a wider choice of housing type within the Trimsaran Tier 2 Service
Centre. The potential development of this land would be in keeping and in
character with the settlement and will ensure a deliverable source of future
housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature
conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood
risk, hydrological, ecological, archaeological or land ownership related
constraints and its delivery is assured.
The inclusion of this land within development limits for Trimsaran is fully
supported.

Exclude the land from the development limits.

We would ask that the proposed amendment in this 2nd Deposit Revised Carms LDP (attachment 1) should not be implemented and the plan should remain as in the original plan shown as AS/159/01 (attachment 2).
We will not restate all the reasons given in the first round of objections as they will no doubt be raised by others, but would know the legal aspect, whereby the land in question, which is shown in the attached conveyance, was given by the NCB for recreation or amenity purposes to the people of Tycroes for the perpetuity period ending 2068 (attachment 3).

Include land within limits.

Grid Reference SN 29579 37492
2.5 acre site
Adjacent to Maes y Cerrig, Capel Iwan, N.C.Emlyn,
Carmarthenshire. SA38 9LT

As you failed to include our original submission of 7th Feb 2019, this is a fresh submission to consider as advised by the planning office at the drop in session on February 12th 2020.

A History so far.....
On 11th February 2020 I received an email telling us that the assessment for our site could be
found on the Carmarthenshire County Council forward planning web page, via a link included on
the email which also advised of “Drop in Sessions”being held in relation to the LDP Consultation.
My sister spent 3 hours looking on the link but could not find any mention of the assessment
outcome.
She then attended the consultation “Drop in Session” held in Carmarthen Library on February 12
and spoke to Bethan Lovering, the Forward Planning Officer, explaining to her that she had been
unable to find the assessment.
The officer then looked for it herself and was unable to find said document, therefore, although we
had made the submission it had been overlooked by the planning department. The officer advised
that we had been late with our original submission as it should have been in by the summer of
2018. We had by chance seen a notice in the Carmarthen Journal in late January 2019 stating the
closing date for submissions was February 9th 2019.
We submitted the original submission on February 7th 2019 and awaited further news.
This came on February 11th 2020.
At the “Drop in Session” my sister was advised that we should re-submit the site before March 27th
of that year as the closing date had been extended, which we did.
We have since attended the latest ’Drop-in sessions’ in February 2023 and have now decided to
just submit just 2.5 acres of the field for consideration for inclusion in the plan.
Our reasons for asking again that consideration be given to our land for inclusion in the LDP
remain the same as previously stated in earlier submissions on the following grounds:-
1) Having looked up the definition for the term “Hamlet” - a Hamlet is very small with a handful
of houses and usually does not have any shops or services. We feel that any building in our field
would comprise part of the hamlet - there are 7 adjacent properties in close proximity (shown on
the new site map provided) and should be considered as infill. Utilities are close by i.e. Electric and
Water.
2) The site is within easy reach of all the amenities available in Newcastle Emlyn, being only 2 miles
fro the town.
3) The site is within easy commuting to work distances of Carmarthen, Cardigan, Newcastle Emlyn,
Llandysul and Aberaeron and would be a lovely rural community to live in to raise a family.
The local school bus runs past the bottom of the lane.

Include land within limits

We are instructed by Mr. A. Green to a make a formal representation to the “soundness” of
the Second Deposit Draft of the Carmarthenshire Local Development Plan.

Our client owns a small level paddock which immediately set to the rear of established
residential properties in Peniel. They are seeking inclusion of their land for future residential
development within the defined settlement limits of Peniel within the Replacement Local
Development Plan.

The Site is irregular in shape but shares a common boundary on two sides with detached
dwellinghouses which front an unclassified road on the eastern side of the village, close to
the Primary School. The land benefits from an undeveloped gap set between existing
houses which can allow for a shared access driveway road to be formed and continued into
the centre of the paddock.

We have noted that Peniel is categorised within the draft settlement limits as a Tier 3 Rural
Village and referenced SuV10. Two residential allocations have been drafted in the Plan,
namely “South of Pentre” – Site SuV10/h1, capable of providing 10 units, and
“Aberdeuddwr” – Site SuV10/h2, with a capacity for 38 units.

Land south of Pentre has been under construction for three last two years, with many units
completed and occupied.
It is noted that apart from the undeveloped field enclosure at Aberddeudwr, there are no
opportunities in Peniel for small scale “rounding-off” developments, which could provide for
local, self-build plots, whilst not adversely affecting housing land supply in the settlement or wider Cluster. This formal Representation relates solely to the non-inclusion of this land within the draft settlement limits.
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 Peniel, 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 Peniel, as reproduced below in Figure 1.

Figure 1 – Extract from Second Draft of Proposals Map with site edged in red

This formal representation letter supplements the following documents which comprise a complete submission to the Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Location and Indicative Site Layout plans
Response to Council’s Setting of Peniel Draft Settlement Limits

1.0 Integration of Site with Character and Setting of Locality

1.1 The Representation Site consists of a generally rectangular-shaped paddock which is well-defined in that its western and southern perimeters form the common rear boundaries of established residential properties.
Those properties benefit from uniform rear garden space, and a parallel line of boundary with the site, comprising mainly of high perimeter fencing. The northern and eastern perimeters consist of uniform lines of mature trees and hedgerow respectively. The boundaries form a strong, defensible boundary to surrounding agricultural pasture, which takes on a far more open and undefined form than the modest and compact Representation Site.

Figure 2 below illustrates the boundaries of the site in red, whilst Figure 3 provides a Google Earth reproduction of the aerial view of the site where the above features are graphically evident.

Figure 2 – Location plan of site with boundaries edged in red

Figure 3 – Google Earth image of site with boundaries and proximity to housing evident
Representation Site

1.2 The village is significant in scale, containing several dozen dwellinghouses, primary school and village hall. It also possesses good public bus service connections to Carmarthen and Lampeter via the A485 road. In other words, it is highly sustainable as a place to live and work, with Carmarthen only 5 minutes’ drive by road..

1.3 The Representation Site indicative site layout plan is reproduced below as Figure 4.
It illustrates for a cul-de-sac form of development with a total of 4 detached dwellinghouses set fronting an internal shared driveway, which can access the site through the undeveloped frontage between “Trysor” and “Llain Deg”. The proposed form of layout and development is complementary in form to adjacent established form of residential layout at “Bro Dauddwr” and “Bro Hyfryd”, located to the immediate west of the site.

1.4 The site also presents an opportunity to form a pavement link across the frontage of Trysor, which is within the ownership of the client’s family. The existing leylandii hedgerow can be translocated back to allow for an adequate visibility splay and in doing form a pavement about that frontage to allow existing and propsed residents to walk and cross to the existing pavement off the opposite flank of the highway.

1.5 We submit that the proposals put forward in the Representation Site encompasses the entire rear boundaries of existing properties and thus complemented that entire adjoining development in depth and form.

Figure 4 – Indicative site layout plan of proposed Representation Site

2.0 Overall Housing Supply at Peniel with Deposit Draft

2.1 The proposals under this Representation merely seek the addition of a further 4
residential units to the overall housing supply of Peniel, to add to the 48 units already
allocated within the draft Plan. Peniel is defined as sustainable settlement, and lends
to the principal service centre centring upon the Carmarthen Cluster as defined within
the draft LDP. The Carmarthen Cluster aims to provide an additional 1690
residential units over the Plan period to 2033, and thus the addition of a small unallocated
site at Peniel of only 4 dwellings, in addition to the current draft of 47 units
in the settlement will not lead to an over-supply of dwellinghouses within the
settlement nor Cluster.

Proposed Housing Allocations at Peniel

2.2 Peniel is quite unique in terms of its positioning and setting being part of the Carmarthen Cluster. It is placed at the northern side of the defined area, being one of a number of settlements spread sporadically along the A485 Carmarthen to Lampeter road, and A484 road to Cynwyl Elfed. Peniel together with Rhydargaeau and Llanpumsaint and Bronwydd serve a rural hinterland. However, Peniel is however, unlike the other settlements, as it is afforded with a Primary School and consequently, there are few other defined settlements in this part of the County which contain such specific sustainable attributes.

Two sites have been allocated in Peniel, with one of which carried over from the 2014 adopted LDP, that being “land south of Pentre”. That site of 10 units is under construction, and will be complete in the next 6 months.
The other site at Aberddeudwr is a new allocation, referenced as Site SuV10/h2, and according to the Housing Schedule within the draft LDP Statement capable of providing 38 units. That allocation however appears to break from the built form of the village, by extending to a new open field, north of the settlement.

2.3 We submit that the proposals to site only 4 dwellings within the Representation Site will form a rounding-off of the eastern part of the settlement. 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.
2.4 It is logical therefore that the same assessment criteria should be utilised in assessing whether or not a Representation 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 be included within the defined development limits of Peniel.

In conclusion, our clients have illustrated that their indicative proposals to construct a total of 4 dwellinghouses will not appear at odds to the prevailing spatial pattern of development in Peniel. The locality has numerous examples of modern cul-de-sac development being
completed at backland / edge of settlement locations, which in turn, advocates that the form of development proposed at land to the rear of Trysor 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 Peniel realigned to include the whole Representation Site, as a Residential Allocation in the Proposals Map of the adopted Local Development Plan.

Development limits to be drawn around Four Roads and the site in question to be included within the development limits.

This representation objects to the removal of development limits for Four
Roads. Appropriate development within Four Roads would not lead to
additional environmental pressure, but instead will foster sustainable growth
and allow for a wider choice of housing type within this Tier 4 Rural Village. Its
development would be in keeping and in character with the settlement and will
ensure a readily deliverable source of future housing for this sustainable
community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature
conservation interests.
Furthermore, the representation site is not impeded by any access, ground
condition, flood risk, hydrological, ecological, archaeological or land ownership
related constraints and its short term delivery is assured.
A full description of the site's development potential and merits has previously
been provided in the candidate site submission, to which reference should be
made.
It is considered that this site is both sustainable and readily deliverable and
offers a valuable development option within the village.
The inclusion of this land within reinstated development limits would be fully
supported.

Include site within Plan

LAND PART OF SARNAU,
GLANDY CROSS, CARMARTHENSHIRE


1.0 INTRODUCTION
1.1 Mr & Mrs S. Davies (the Land Owner) have instructed Evans Banks Planning Limited
to prepare and submit an Alternative Site Supporting Statement for the inclusion
within defined settlement limits of land part of Sarnau, Glandy Cross,
Carmarthenshire for the purposes of residential development in the forthcoming
Replacement Carmarthenshire Local Development Plan.
1.2 This Statement has been prepared in line with the Authority’s published documents
entitled Revised Carmarthenshire Local Development Plan: Guidance Note and
Revised Carmarthenshire Local Development Plan: Candidate Site Assessment
Methodology. The contents of this Statement therefore address the set criteria,
determining the issues and each qualifying point raised within these documents.
Consideration has also been given to ensuring that this formal submission complies
with the guidance and requirements of Planning Policy Wales (Edition 11), in relation
to the preparation of development plans and the allocation of land for residential
purposes as part of that preparation process.
1.3 The contents of this Statement therefore provide a comprehensive case for the
inclusion of the land for residential development purposes within the defined
settlement limits of Glandy Cross, and it should also be read in conjunction with the
accompanying supporting information and indicative site layout plan.

2.0 SITE CONTEXT
2.1 THE SITE
2.1.1 The Alternative Site relates to a parcel of undeveloped agricultural pasture which is
set off the northern flank of a farm access track, off the A478 Road within the village
of Glandy Cross. The entire field parcel is rectangular in shape and extends to a
gross area of 3.4 acres (1.78 hectares). It has a continuous boundary around its
perimeter consisting of hedgerows and mature trees, with the western perimeter
flanking the A478 road.
2.1.2 The Alternative Site is modest, being only approximately 0.36 hectares (0.88 acres)
in overall size, and has a frontage to the surfaced access lane, extending for a length
of 90 metres to a two-storey established property known as Sarnau. That dwelling
benefits from a domesticated garden to its western, front curtilage and also an
irregular shaped enclosure off the southern, opposite side of the access track.
Grazing fields extend to the north and east, with a large pond to be found to the
immediate east of the property. The southern perimeter of the access track and
Sarnau property lies off the rear gardens of bungalow properties set about a cul-sesac known as “Bro Deirian.” Some 10 individual properties encircle a hammerhead
road layout, with traditional rear garden space backing onto the Alternative Site.
2.1.3 The western flank of the A478 Road comprises of more established, older residential
properties set fronting that highway, and with a modest field enclosure set allocated
for further residential development within a triangular-shaped enclosure to its
immediate north, which will have the effect of extending the village northwards. The
Alternative Site should therefore be considered as a logical addition to Glandy Cross
settlement, being directly opposite that allocated field, and which will mirrors that
proposed development, but located to the east of the A478 extending north to an
equivalent distance.

2.1.4 The parcel of land is identified in red by Plan A, which illustrates its wider position
within the settlement of Glandy Cross and shows the existing consolidated form of
modest estate and frontage development to the A478 Road. Plan B provides a
detailed Ordnance Survey map extract with the site perimeters identified.
Plan A – wider setting of Glandy Cross with site highlighted
Plan B – detailed OS Plan of Alternative Site

2.1.5 Photographs of the Alternative Site are reproduced below, showing its current March
2023 condition and form. The Alternative Site is relatively level, and its long frontage
to the A road is equipped with an agricultural field access set just to the north of a
wide public bus top with its associated lay-by. A wide grassed verge lies off the back
edge of pavement, with a linear hedgerow to the site frontage. The Site itself is
relatively level, without any discernible differences in ground or contour levels.
Photo 1 – view of level field from adjacent A478 highway
Photo 2 – view of wide access track from A478 road
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies
6
Photo 3 – view to left (south) from existing access onto A478 road illustrating
excellent visibility
Photo 4 – view to right (north) from existing access onto A478 road illustrating
excellent visibility

2.2 SETTLEMENT SUSTAINABILITY AND SITE SETTING WITHIN THE CURRENT ADOPTED
LOCAL DEVELOPMENT PLAN & SECOND DEPOSIT DRAFT (FEBRUARY 2023)
2.2.1 Under the provisions of the current adopted Carmarthenshire Local Development
Plan, the proposed land adjoins the Settlement Limit of Glandy Cross. The site is
shown edged in red at Plan C below, with the Second Deposit Draft Plan extract
shown as Plan D.
Plan C – 2014 Adopted LDP plan for Glandy Cross

Plan D – Second Deposit Draft of Glandy Cross
2.2.2 The Alternative Site adjoins and is well related to the existing defined Development
Limits of Glandy Cross. At present the development limits are drawn tightly about the
existing settlement form at Bro Deirian. The Alternative Site seeks to mirror the
development proposed on the opposite side of the A478.
2.2.3 The Alternative Site’s position and proposed use represents a natural and logical
location for the settlement’s expansion ensuring that development is produced evenly
throughout. Indeed, the property known as Sarnau together with the southern
triangular-shaped enclosure were included within the settlement limits of the
Carmarthenshire Unitary Development Plan. Outline planning permission was
granted in 2006 for a new dwellinghouse within this southern enclosure.
2.2.4 Glandy Cross is a popular location particularly to new homeowners due to its
accessibility to the nearby settlements of Clunderwen, Llandissilio and town of
Narberth and Crymych, and its links via the A478 Penblewin to Cardigan Road.

2.2.5 In terms of the Sarnau Site, it is located within easy driving distance of all community
facilities and local services present provided within Glandy Cross and Efailwen
settlements. Access to further facilities in the town of Narberth to the south and
Crymych to the north can be gained by regular bus services where stops are located
near the village crossroads upon the A478 road.
2.2.6 Transition from Adopted Local Development Plan (2006-21) – Allocation Status
In terms of planned growth, the proposed Alternative Site is located within the
identified SC4 Settlement Cluster within the current LDP, adopted in December
2014. Glandy Cross and Efailwen are regarded by the Council as sustainable
settlement communities several kilometres north of Clunderwen and Narberth within
Pembrokeshire. Within these areas, those settlements are regarded as
accommodating a range of services providing a modest degree of sustainability to the
local community.
2.2.7 A number of the housing allocations within the LDP have yet to be delivered after 8
years since the Plan’s adoption. Glandy Cross appears to now been assessed as a
separate settlement from Efailwen for the purposes of developing the Second Draft of
the Replacement LDP. The new Inset Map identifies two residential allocations.
Plan C above provided an extract from the 2014 Proposals Map for Glandy Cross. It
indicates two residential allocation sites in Glandy Cross, being SC4/h1 at “Maesglas”
and SC4/h2 at “Cross Roads”. The Council have chosen to retain those sites within
the Replacement LDP. Maesglas is now allocated as SuV55/h1 for a total of 9 units,
whilst “Cross Roads” is no longer allocated but continues to lie INSIDE new draft
settlement limits. Plan D below provides an extract of the 2014 adopted LDP extract
for Glandy Cross.
In considering, the formulation of a new Plan, the Council have examined four
Candidate Sites put forward in August 2018. In 2023, the Council provides an
Assessment Report evaluating those Candidate Sites, and in the case of Maesglas
indicates that it should continue as an allocation based upon “Outline Application
pending on this site. Site to remain as an allocation with reference SUV55/h1.” That

application is referenced W/38320 which was granted in May 2021. However, only
outline planning permission was granted, and in the subsequent two years, no
submissions for Approval of Reserved Matters have been made. It therefore remains
questionable as to whether the development of that site will be brought forward.
In terms of SC4/h2 at Cross Roads, the Council’s online application records reveal
that no applications for planning permission have been submitted in the 8 years since
adoption, and therefore it must be questioned why the land remains within settlement
limits?
2.2.8 The net result is that despite the Settlement Community continuing to have good
provision of community facilities, local services and public transport connections to
Crymych and Narberth, its ability to grow and capitalised on these sustainable
attributes has been prevented through a lack of delivery of existing allocations. More
deliverable residential opportunities are required. The deliverability of the remainder
of the longstanding allocations are clearly in doubt, so, in order to re-address this
deficit in provision and capitalise on the sustainability of the Sustainable Community,
more deliverable residential allocations are required.
2.2.9 Second Deposit Draft LDP (February 2023)
The Council published a Deposit Draft in February 2023, which is now subject of
public consultation. Within the Second Deposit Draft, the following sites are allocated
for housing provision within Glandy Cross.
Table 1 – 2023 Second Deposit Draft Allocations

2.2.10 It is noted that the level of allocation in Glandy Cross has remained consistent. The
Maesglas site is evident, as is a new allocation at “land north of Cross PH.” That site
is allocated as SuV55/h2 for 6 units. It is noteworthy given its position lying directly
opposite Sarnau off the opposite, western flank of the A478 road.
We consider that it is clear that there is a need for an additional minor site within the
proposed Replacement LDP. Sarnau is located across the main road from SuV55/h2
and possesses the same physical and locational characteristics as that site. In the
case of Sarnau it benefits from being located off an established vehicular access lane
off the A478 road and has an established residential dwelling located within the
Alternative Site.
2.3 Settlement Facilities
2.3.1 The Alternative Site lies upon the A478 Penblewin to Cardigan main highway, only
some 5 miles south of Crymych. Public bus stops are located immediately adjoining
the Glandy Cross crossroads, only two minutes’ walk from the Alternative Site. Main
public bus services call at these stops, particularly the 430 service (Cardigan to
Narberth) which calls at Crymych to the north and Clunderwen and Llandissilo to the
south.
2.3.2 The Sarnau Site is a short 5 minutes’ drive from Clunderwen railway station which
has services to Cardiff and Swansea to the east and Haverfordwest and Milford
Haven to the east.
2.3.3 It lies within a one-minute walk from the Glandy Cross petrol filling station and
general store whilst Ysgol Beca Primary School is a two-minute drive away at
Efailwen.
2.3.4 Narberth town centre is located a short 15 minutes’ drive away with its associated
comparison shops, high street banks, public houses/cafes, offices, industrial estate,
library, and leisure/recreation facilities.

3.0 THE PROPOSAL
3.0.1 This Statement is accompanied by an indicative layout for a potential residential
scheme that could be development on the site. It should be emphasised that the
accompanying layout is for illustrative purposes only, and that other design solutions
for the site could be reached. Notwithstanding this, the accompanying layout drawing
has taken into account all potential assets and constraints of the site and
demonstrates that it can deliver 4 units in a deliverable and sustainable manner.
3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Alternative Site be allocated in the forthcoming replacement
LDP for the purposes of a combined total of 4 residential units. As detailed above, the
accompanying illustrative layout demonstrates that the site can accommodate this
number in a deliverable and sustainable manner. Plan E illustrates the indicative site
layout for the Alternative Site, as edged in red, extending off the A478 highway,
proposing a mirrored and balanced development to that to the west of the highway
and Bro Deirian to the immediate south.
Plan E – Site Layout

3.1.2 As illustrated above, the site is capable of accommodating detached bungalows to
replicate and being reflective to the existing form of the development to the south at
Bro Deirian.
3.1.3 With regards to access, it is proposed that the Alternative Site would be served by an
improvements and widening of the existing access track adjoining the A478 highway.
Vehicle speeds are consistent with the 40mph speed limit, and thus visibility splays of
2.4m x 59m can easily be achieved where the accesses adjoin the A478 road.
3.1.4 The Alternative Site proposals can fully retain all existing boundary treatments being
established tree perimeter and hedgerows about the existing house.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Development of the Alternative Site for residential units would be served by mains
water, public sewer and electricity connections.
3.2.2 A new estate road is proposed within the development. This will be equipped with
roadside gullies and drainage which aid discharge run-off from the carriageway. The
proposed accesses to the site could connect to the existing highways drainage.
3.2.3 The Alternative Site comprises of former agricultural pasture and domestic curtilage.
There are no areas of significant marshy grassland or water-logging evident, and
therefore at first inspection, it appears that the site benefits from good ground
percolation of rainwater.
3.2.4 Soakaways would be the most sustainable means of disposing of surface water from
individual properties. If required, attenuation measures can be deployed on site to
control surface water run-off during extreme storm events, which could also allow for
additional capacity, making allowances for climate change. Such features can be soft
engineered in the form of attenuations basins and / or swales, thus adhering to the
principle of Sustainable Urban Drainage Systems (SUDS).

4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 The Alternative Site has been assessed against data held on the “Data Map Wales”
website which details statutory and non-statutory National and Local sites of
ecological importance. Plan F below provides an extract of those records applied to
the Glandy Cross locality. The red star denotes the position of the Alternative Site.
Plan F – Extract from Data Map Wales detailing any known ecological interests
4.1.2 The records reveal that the Alternative Site does not include or adjoin any national or
local nature conservation designation. The Eastern Cleddau SSSI lies several
kilometres west of the village.
Any biodiversity assets that may be present or adjoining the Sarnau Site have been
given full consideration with regards to exploring its potential for residential
development. This has included the proposed retention and management of existing
boundary trees. It is envisaged that the entirety of mature tree lines could be retained
and managed further for uninterrupted biodiversity gain.

4.1.3 It is considered that any statutory and non-statutory designations are significantly
distant from the site, which will ensure that its development would have no
detrimental impact upon them.
4.2 HISTORICAL ASSETS
4.2.1 The Alternative Site has been assessed for any proximity to known and designated
Historic Assets, using the “Cof Cymru – National Historic Assets of Wales” from
CADW’s website. An extract from Cof Cymru Assets map for Glandy Cross is
reproduced below as Plan G. The red star denotes the position of the Sarnau Site.
Plan G – Extract from Cof Cymru Historic Assets website
4.2.2 The extract reveals a multitude of Scheduled Ancient Monuments in the locality;
however, none are to be found within the Alternative Site field enclosure and are
located south-west and north-east of the village.

4.3 ENVIRONMENTAL CONSTRAINTS
Potential for Risk from Flooding
4.3.1 The Alternative Site has been assessed against the Flood Map for Planning,
prepared by Natural Resources Wales, and as referred to within the Welsh
Government’s revised / draft “Technical Advice Note 15: Development and Flood
Risk”. An extract from the Flood Map for Planning is reproduced below as Plan H,
with the site denoted by a red star.
Plan H – Extract from NRW’s Flood Map for Planning
4.3.2 The above plan extract revels that no part of the Alternative Site lies within the
designated flood zones, and thus the potential development of the site is not at risk
from either fluvial or tidal flooding.
4.3.3 An examination has also been made of NRW records relating to potential surface
water flooding, as shown by purple tone in the above plan. The red star again
denotes the positioning of the Alternative Site and reveals there to be no potential for
pooling of surface water upon the site.

Past and Present Potential for Ground Contamination and Coal Mining Activity
4.3.4 The Candidate Site comprises a modest former agricultural field. Due to its greenfield
nature and agricultural use, the field as no history of known past ground
contamination related constraints.
4.3.5 The records of The Coal Authority have been examined and reveal no history of coal
mining in this part of the County.
5.0 VIABILITY
5.0.1 As part of the preparation of any development plan, it is vital to ensure that
allocations within it are both viable and deliverable. To not make efforts to explore
both aspects inherently poses risks that the Plan may be unsound and so in turn fails
to meet its own targets or objectives.
5.0.2 Although detailed viability appraisals are difficult to prepare at this stage of the Plan’s
preparation due to the absence of, for example, such things as full engineering
details, it is possible to undertake
5.1 VIABILITY APPRAISAL
5.1.1 The following provides an indication of the viability of delivering the proposed 4 units
on the Alternative Site in question. It is based very much on its greenfield status and
uses values and costings previously accepted by the Local Authority through its
determination of planning applications and other works. The following appraisal is
therefore based on the assumptions set out below in order to provide a residual land
value for the scheme.
Costs
• Dwelling construction costs are based on an absolute minimum of £1300 per
metre given that bespoke four bed detached bungalows (160 sq.m.), with a medium grade of internal finishing, and formation of accesses to the highway
are likely to be the preferred house type.
• Estate road carriageway costs are placed at £1200 per linear metre
• Connections for all utilities include water, foul water and electric.
• Developer’s Profit based on minimum RICS guidelines (18%)
• Professional Fees include planning application fee, associated professional
fees, estate agency fees (1%) and LABC Warranty fee.
Sales Values
• Sale Prices based on LPAs “Affordable Housing” Supplementary Planning
Guidance, market research and Welsh Government “Acceptable Cost
Guidance” figures where relevant.
5.1.2 Using the above, the following represents a strategic viability appraisal for the
proposed 4 units, based on an affordable housing level being a financial contribution
of £75.00 per square metre of internal floorspace.
Costs Cost Per Unit/Metre
No.
Units/Metres Total
Four Bed Bungalows 208,000 4 832,000
Road Construction 1200 100 120,000
Utility Connections 5000 4 20,000
Professional Fees - - 40,000
Sprinklers 3500 4 14,000
Affordable Housing 75 640 48,000
Contribution
Total 1,074,000
Sales
Four Bed (Open M’kt) 400,000 4 1,600,000
Developers Profit Total 288,000
Residual Land Value 238,000
Table 2
5.1.3 Based on the above figures, it is considered that in-principle, the development of the
site would be financially viable. The residual land value of £238,000 for a site consisting of four development plots (£59,000 per plot) is consistent with evidence
gathered over recent years by the District Valuer in examining residential site
transactions within Carmarthenshire. The DV discovered land values on completed
and on-going sites to be averaging £245,000 per net residential acre of land, based
on 2020 values.
5.2 DELIVERABILITY
5.2.1 In terms of deliverability, it should be firstly noted, as illustrated above, that the site is
financially and physically viable, with no environmental, geo-physical or technical
constraints prohibiting immediate development. Furthermore, there are no ownership
or third-party interests preventing the site’s delivery.
5.2.2 In terms of a delivery timescale, with a developer secured, it is envisaged that the site
could be capable of being completed within 2 years from the adoption of the
replacement Local Development Plan. Glandy Cross remains an attractive part of the
cluster of villages about the Cardigan to Penblewin Road, benefitting from its semirural location, but easy access to Crymych and Narberth by road and the nearby
schools, shops, services and community facilities.
5.2.3 The presence of modern, detached houses and bungalows adjoining and located
immediately alongside at Bro Deirian is testament to this market need and the desire
for home buyers to seek out such forms of modest residential development.

6.0 NATIONAL PLANNING POLICY CONSIDERATIONS
6.1 In the preparation of any development plan, consideration must be given to national
planning policy and guidance. At present, this takes the form of Planning Policy
Wales and a series of Technical Advice Notes (TAN) that deal with a variety of topic
areas.
6.2 With regards to residential development, or housing, the overarching requirements
and principal guidance set by national policy can be found at Paragraph 9.2.3, which
reads as follows:
“Local planning authorities must ensure that sufficient land is genuinely available
or will become available to provide a 5-year supply of land for housing judged
against the general objectives and the scale and location of development provided for
in the development plan. This means that sites must be free, or readily freed, from
planning, physical and ownership constraints, and economically feasible for
development, so as to create and support sustainable communities where people
want to live. There must be sufficient sites suitable for the full range of housing types.”
6.3 At present, Carmarthenshire County Council’s housing supply figure is below the
required 5-year level therefore, it is imperative that this is addressed as quickly as
possible to avoid further deterioration of communities and the facilities and services
they have to offer.
6.4 Dealing specifically with the Alternative Site subject of this Report, it is evident that its
inclusion within the Replacement LDP would adhere to the requirements of PPW, in
that it is free from any planning, physical, or ownership constraint. In addition, as
shown in Section 5 of this statement, the site is also economically viable in
deliverability terms.

7.0 CONCLUSION
7.1 The Alternative Site is modest in overall size, with an established dwellinghouse
located within a modest side curtilage and southern enclosure, backing onto Bro
Deirian. That property and southern enclosure was set within the 2006 Unitary
Development Plan and benefitted from outline planning permission to site a
new dwellinghouse in this enclosure. At that time, the Council saw no reason
to consider this site as one not otherwise conforming to the spatial and
consolidated form of the village.
7.2 The Site lies within close proximity and walking distance to the existing community
and local services of Glandy Cross and Efailwen which will ensure it makes a positive
contribution to both national and local sustainable development objectives.
7.3 From a wider sense, the Site will also benefit from well served excellent public
transport links to the nearby settlements, specifically the town of Crymych and
Narberth, together with other locations within and adjoining the County. In tandem to
this, the development of the Site will in turn ensure a deliverable source of future
housing for the Sustainable Community in which it lies, which has seen both allocated
sites fully developed leading to an under supply since the adoption of the current
LDP. The development of the Site will help to redress this imbalance and it is strongly
suggested that the Authority recognises the suitability and deliverability of modest
sites if it is to continue to realise the contribution villages such as Glandy Cross make
to the housing land supply.
7.4 With the Alternative Site having no access, ground condition, flood risk, hydrological,
ecological, archaeological or land ownership constraints, its delivery if included within
settlement limits is assured. Combined therefore with its locational characteristics, the
Site in question represents a sustainable alternative for future housing development.
7.5 In view of the above and the information provided within this Statement, it is
respectfully requested that the Alternative Site in question be included within limits for
a modest residential development.

Amend Plan to include the site

We are instructed by Mr H. & Mrs N.M. Evans to a make a formal representation to the
“soundness” of the Deposit Draft of the Carmarthenshire Local Development Plan.

Our client made a formal Candidate Site Submission in August 2018, which was referenced
SR/145/011, seeking the inclusion of the land within the defined development limits of
Rhydargaeau as part of the Replacement Local Development Plan. The Candidate Site
centred mainly on part an agricultural paddock that fronted onto the A485 Carmarthen to
Lampeter Road, within the northern cluster of development that forms the settlement.
Further agricultural enclosures are positioned to the south-east, but residential development
is located directly to the land’s north and on the opposite side of the main 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 of Carmarthen, which is only some 10
minutes by 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
settlement limits of Rhydargaeau, as contained within the Second Deposit Draft.

We note that the submission successfully passed through Stage 1 (site compatible against
the location of future growth presented in the Preferred Strategy) and Stage 2A (Initial
Detailed Site Assessment) of the Council’s site assessment.

However, it was rejected at Stage 2B (further detailed site assessment), with reasons for non-inclusion reported as follows:

“Development of the site would have a detrimental impact on the character and setting of the settlement. Furthermore, there is sufficient and more suitable land available for development within the village to accommodate its housing need.”

Our clients consider that the LDP is “unsound” and should be changed, as it fails to meet the tests for “soundness,” in that the Plan “is not appropriate,” as defined by the Planning Inspectorate’s LDP Examinations Procedural Guidance.

Specifically, our clients consider that the Second Draft settlement limits for Rhydargaeau, 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 Rhydargaeau, as reproduced below in Figure 1.

Figure 1 - Extract from Proposals Map with Representation site edged in red

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

- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits

1.0 Impact upon Character and Setting of the Settlement

1.1 The Council consider that the inclusion of the site within defined settlement limits
would “have a detrimental effect on the character and setting of the settlement.” In
response, it is abundantly clear from the submitted indicative site layout plan, as
reproduced at Figure 1 below, that the proposals constitute “rounding off”. The
proposals will seek to develop an established and delineated paddock, the
boundaries of which are marked upon the Ordnance Survey Map and will bring
development about the eastern flank of the A485 road in comparison to that
established off the opposite, western flank. We question how that can be described
as “detrimental” when the western flank is already in existence?

Figure 2 – Indicative Site Layout Plan of Representation Site

1.2 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

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 Rhydargaeau.

The land in question if developed with a small number of dwellings would appear as a “mirroring” of established development off the opposite side of the main road. 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.
2.0 Consistency with Other Settlement Limits

2.1 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 Rhydargaeau, the Authority has been found to be inconsistent.
Figure 3 below is an extract of the Deposit LDP Proposals Maps for an area at the south of Rhydargaeau.

Figure 3 – examples of undeveloped land at settlement edge marked with red arrows

2.2 As can be seen, two separate parcels of undeveloped land have been included within the defined Rhydargaeau development limits, which extend the existing form of the settlement in a southern ‘ribbon-like’ manner. It should be noted that we do not object to this form of alteration to the development limits, as it secures a varied form of available housing development opportunities for a community. However, its inclusion
is a direct contrast and inconsistency to the Authority’s decision to exclude our client’s land 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 Authority, resulting in the Plan as it stands being unsound.
2.3 The practice of illogical addition of undeveloped land at nearby village fringes has continued at Peniel, where land at Aberddaudwr has been added, as shown below at Figure 4. This inclusion of this parcel of land exhibits a complete departure of extending the settlement limits off the eastern flank of the A road, without any definitive barrier such a hedgerow or tree line to mark as a physical barrier to the settlement.

Figure 4 – illogical extension of settlement limits at Peniel
2.4 The expansion of settlement limits to mirror development off an opposite road flank is not confined to Peniel. Figure 5 below shows a recent addition to settlement limits at Bronwydd, where land off the western side of the B4333 Llanpumsaint Road has been added in this Second Draft of the LDP. This is another example of the inconsistent approach taken by the Authority in examining modest representations within villages north of Carmarthen.

Figure 5 – expansio of settlement limits at Bronwydd in mirroring development off an opposite road flank

In conclusion, this Representation to the 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 Authority 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 Plan

We are instructed by Mrs M. Jones 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/021/014, seeking inclusion of their land for future residential development within the
defined settlement limits of Carmarthen within the Replacement Local Development Plan.
The Candidate Site comprises the field frontage and modest range of former agricultural
outbuildings set off the western flank of Trevaughan Road, directly opposite the Is-y-Bryn, at
the northern-most part of Trevaughan.

We have noted that part of the Candidate Site is included within the draft settlement limits,
that being a field frontage set off the northern gable of the dwelling known as Brodawel to
the southern side of a small grouping of former agricultural outbuildings.
However, the compacted range of outbuildings has not been included within the
Second Draft settlement limits. This formal Representation to the Second Draft relates solely
to part of the unsuccessful part of the Candidate Site to include those physical buildings.

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 all the site was not selected for inclusion within the
settlement limits of Trevaughan, near Carmarthen, as contained within the Second Deposit
Draft.

We note that the submission successfully passed through Stage 1 (site compatible against the location of future growth presented in the Preferred Strategy) but failed to proceed through Stage 2A (Initial Detailed Site Assessment) of the Council’s site assessment, with reasons for non-inclusion reported as follows:

“The site cannot accommodate 5 or more dwellings. Part of the site will be included within development limits and will contribute to the small sites supply component.”

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 Second Draft settlement limits for Carmarthen, 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 Carmarthen, as reproduced below in Figure 1.

Figure 1 – Extract from Proposals Map with Representation site edged in red

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

- Completed Deposit LDP Representation Form
- Location plan indicating proposed realignment of settlement limits at Trevaughan

Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits

1.0 Inclusion of Physical Outbuildings as part of Trevaughan Road street frontage

1.1 The Council have realigned the settlement limit from the current adopted (2014) Proposals Map of the Local Development Plan, to include part of the field frontage adjoining Brodawel in the Second Draft of the Replacement LDP. However, they have stopped short of including the existing modest range of outbuildings that are to be found off the northern side of the newly included field frontage.

1.2 The very compacted yard lies just before an acute bend in the C class Trevaughan Road but is very much positioned to be part of the filed frontage. The outbuildings are set back by some 10 metres from the near edge of highway carriageway and equipped with its own vehicular access and concrete surfaced apron. The outbuildings in question are graphically shown by the Google Earth image reproduced below as Figure 2, and Streetview image at Figure 3, taken in April 2022.

Figure 2 – Extract from Google Earth (April 2021) illustrating the existing outbuildings
Compacted Outbuildings

Figure 3 – Existing outbuildings as viewd from public highway upon Streetview (April 2022)

1.3 As can be seen from the above photograph from the public highway, the existing outbuildings from part of the roadside setting at this approach into the settlement of Trevaughan. The dwelling known as Brodawel can be seen as a close backdrop, with neighbouring dwellings to be found forming a comntinuous frontage of developmet off the opposite eastern flank of the main road.

1.4 The inclusion of the existing outbuildings in new settlement limits will not involve any encroachment into open countryside but merely allow the limits to include an established compaction of modest outbuildings and thus to provide a formal and definitive edge to the settlement.
In conclusion, this Representation to the Deposit Draft of the Revised LDP has sought to include existing outbuildings into the Second Draft settlement limits of the Local Development Plan. Such a very modest realignment will not compromise the Plan’s aims at safeguarding the adjoining countryside for its own sake, nor pose any detriment to the visual setting and character of this semi-rural locality.

We respectfully request that this Representation be given careful examination, and consequently the defined settlement limits of this part of Carmarthen realigned to include the Representation Site in the Proposals Map of the adopted Local Development Plan.

Include site in plan

We are instructed by Mr. C. Davies to a make a formal representation to the “soundness” of
the Second Deposit Draft of the Carmarthenshire Local Development Plan.

Our client owns a small holding set at the south-western approaches to the town of
Llanybydder. The agricultural holding falls to a roadside boundary with the A485 Carmarthen
to Lampeter road, and is marked by the presence of a pair of semi-detached houses,
together with compacted farmyard set alongside with its own independent vehicular access
onto the A road. They are seeking inclusion of a very modest parcel of farmyard for future
residential development within the defined settlement limits of Llanybydder within the
Replacement Local Development Plan.
This formal Representation relates solely to the non-inclusion of ALL of this established
farmyard within the draft settlement limits.

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 Llanybydder, 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 Llanybydder, as reproduced below in
Figure 1.

Figure 1 – Extract from Second Draft of Proposals Map with site edged in red

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

- Completed Deposit LDP Representation Form
- Location and Indicative Site Layout plans

Response to Council’s Setting of Llanybydder Draft Settlement Limits
1.0 Integration of Site with Character and Setting of Locality

1.1 The Representation Site consists of a generally level farmyard, equipped with a range of agricultural outbuildings, ranging from portal framed sheds to brick-built workshop outbuilding and open-sided metal sheeted shelters. The Second Draft of the Replacement LDP has repeated the settlement limits currently adopted in 2014 and imposed a settlement limits carving straight through this farmyard, so the consequence is that half the outbuildings lie inside the settlement limits, whilst the western half do not. There appears to be no logic or rationale reasoning for the segregation of the farmyard in this manner, and the Representation merely seeks all the farm outbuildings to be included within defined settlement limits.

Figure 2 below illustrates the boundaries of the site in red of the Representation site, whilst Figure 3 provides a Google Earth reproduction of the aerial view of the site where the above features are graphically evident.

Figure 2 – Location plan of site with boundaries edged in red

Figure 3 – Google Earth image of site with whole farmyard in evidence, compacted about the site vehicular access

Representation Site

1.2 The Representation Site is shown in the following photographs where the distinction between which outbuildings are contained within settlement limits and those which lie outside is not readily apparent.

Photo 1 – extent of farm outbuildings at Blaenpwlyf

Photo 2 – outbuildings contained actually within settlement limits

1.3 An indicative site layout plan is reproduced below as Figure 4, where it is considered that the farm outbuildings could be replaced with a senstively designed detached dwellinghouse to mirror that proposed under Planning Application PL/02326. That application proposes the removal of rather unsightly outbuildings and construction of one-three bed detached house with the existing farm entrance improved to provide enhanced visibility standards for all users. That application proposal involves the eastern part of the farmyard contained within settlement limits, but ideally, our client wishes to remove all the farm buildings and construct a second identical dwelling directly over the footprint of those redundant western outbuildings as shown below.
Figure 4 – indicative site layout plan of proposed repalcement of farm buildings with single dwelling

1.4 The site is shown above as extending to built farmyard only, and not encroaching into the adjoining open pasture. Accordingly, the redevelopment of the farmyard would not encroach into the surrounding countryside, and not otherwise potentially detracting from its openness and rural character.
It also resembles “rounding-off” given the presence of Grove Farm directly opposite, off the southern flank of the A485, where a significant proportion of the side curtilage of that property is located within limits.

2.0 Conclusion

2.1 In conclusion, our client has illustrated that their indicative proposals to construct a single, additional dwellinghouse will not appear at odds to the prevailing spatial pattern of development in Llanybydder. The locality has numerous examples of minor additions to the extremities of defined settlement limits, where opportunities to replace old outbuildings with new sensitive development can be achieved. This example 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 Llanybydder be realigned to include the whole Representation Site, as a Residential Allocation in the Proposals Map of the adopted Local Development Plan.

Amend policy within the Plan

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

Include the site within the development limits at Bryngwili Road, Cross Hands.

1 Introduction
1.1 This Candidate Site submission document for the Second Deposit Revised Local Development Plan for
Carmarthenshire has been prepared in order to accompany the submitted form completed in respect
of land at Bryngwili Road, Cross Hands, Carmarthenshire. It is submitted on behalf of Suzie Jones and
Bryn Jones.
1.2 A 5.2 hectare site was previously submitted for the First Deposit Revised LDP in 2018 (Ref: SR/031/008)
but was not allocated for residential development as it was considered that there was sufficient suitable
land available elsewhere in Cross Hands to meet its housing needs. This resubmission of the site at
Bryngwili Road, Cross Hands only concerns a much-reduced area of land at the most western portion of
the land that was originally submitted, amounting to approximately 1.5 hectares.
1.3 The site is located to the north of Bryngwili Road, approximately equidistant from Cross Hands and
Tumble. The land can be entered via an existing gated access along Bryngwili Road.
1.4 This submission will demonstrate that the site should be allocated for residential development which is
sympathetic to its surroundings in terms of scale and form, and addresses the opportunities and
constraints of the site. Furthermore, Appendix 2 reveals that the site received planning permission in
1990 for residential development thus confirming that in the past the Local Planning Authority have
considered it suitable for residential development.
1.5 The deposit LDP states that there are a number of housing allocations within Cross Hands/Tumble area.
On further examination it is evident that 3 of which have already been built out. Occupants are moving
into the dwellings along Ffordd y Neuadd and Clos yr Eithin (PrC3/h11), the residential development at
land adjoining A48 and Heol y Parc (PrC3/h12) has been completed, whereas development at the land at
Heol Cae Pownd (PrC3/h13) has been partially completed. The remaining allocation at the land adjacent
to Maesyrhaf only concerns an allocation of 5 dwellings. Furthermore, it should also be noted that the
Central Garage allocation in nearby Tumble (PrC3/h29) has also now been completed and occupied. As a
result of this, it is considered that additional candidate sites need to be put forward. The land owners
have stated that they are keen for the site to be developed in the short term, with a contractor in place to
start building, along with an estate agent that has clients ready to purchase.
1.6 In terms of the content of this Supporting Statement, Section 2 provides a brief description of the site;
Section 3 discusses the overall planning policy context; Section 4 assesses the site in the context of criteria
identified in Planning Policy Wales. Section 5 provides a summary and conclusions.

2 Site Description
2.1 This section sets out the site’s general location and provides a brief description of the candidate site and
its immediate surroundings.
2.2 The site is located equidistant between Cross Hands and Tumble, on land just north of Bryngwili Road. It
is situated roughly 12.5 miles south east of the county town of Carmarthen and circa 9 miles to the northeast of Llanelli. Bryngwili Road lies along the A476, which runs from Llanelli to near Llandeilo via
Carmarthen. It is a single carriageway road which is approximately 27km long. Within the deposit LDP,
Cross Hands and Ammanford form a Tier 1 principal settlement, where the vast majority of the growth will
be focused during the plan period.
2.3 The irregular shaped parcel of land comprises circa 1.5 hectares in area, with its most southern point lying
within the development limits of Cross Hands. Bryngwili Road is mainly residential in character, with a
mixture of dwelling types. Retail and services can be found to the east in Cross Hands. To the west lies the
village of Tumble, which provides a number of key services such as schools, a doctor’s surgery and a place
of worship. While to the north and south of the site, the land is in agricultural use. In terms of community
facilities, Cefneithin RFC is situated along Carmarthen Road, approximately 900m to the north of the site.
Llechyfedach Primary School and Ysgol Gyfun Maes y Gwendraeth are within walking distance of the site.
2.4 The site is currently in agricultural use, with a boundary of hedgerows and some mature trees. As
previously mentioned, planning permission was gained by the current land owner in 1990 for residential
development at the site.
2.5 The nearest bus stops are situated along Bryngwili Road, at the southern end of the site, which offer
services heading to several destinations in Carmarthenshire including Ammanford, Carmarthen and
Llanelli. The northbound side is services by the 129 and 166, whereas the southbound side is serviced by
the 128, 129 and 166. These stops are serviced on a regular basis, with a service calling once every
hour/two hours between the hours of 6am and 7pm on weekdays. In terms of train provision, two
stations are a similar distance away from the site, those being Ammanford and Pantyffynnon. Both stations are roughly 5.5 miles from the site, and they are both located on the Heart of Wales line which runs
from Swansea to Shrewsbury. Five trains a day travel northbound calling at both stations, and another
five head southbound from Monday to Friday. On Saturdays, four services head in both directions,
whereas this number is halved on Sundays. All trains calling at both stations are operated by
Transport for Wales, and proposed enhancements have been made to the line as part of the Swansea Bay
and West Wales Metro. Lying to the north of the site is National Cycle Route 47 which is 195 kilometres
in length, running from Newport to Fishguard and forms part of the Celtic Trail West.

3 Planning Policy Framework
Overview
3.1 The policy basis for this submission derives from the content and scope of national planning guidance. It
is submitted that the residential land use proposed would be in accordance with national advice and
guidance, its associated Technical Advice Notes (TANs), together with the Development Plan for the local
area.
3.2 The Well-Being of Future Generations (Wales) Act 2015
The Well-Being of Future Generations Act requires public bodies in Wales to think about the long-term
impact of their decisions, to work better with people, communities and each other, and to prevent
persistent problems such as poverty, health inequalities and climate change. To make sure we are all
working towards the same purpose, the Act puts in place seven well-being goals. The Act makes it clear
the listed public bodies must work to achieve all of the goals, not just one or two.
The seven well-being goals include:
1. A prosperous Wales
2. A resilient Wales
3. A healthier Wales
4. A more equal Wales
5. A Wales of cohesive communities
6. A Wales of vibrant culture and Welsh Language
7. A globally responsible Wales
Future Wales – The National Plan 2040
3.3 Published on the 28th February 2021, Future Wales comprises the first development plan of its kind within
Wales. It is a development plan with a strategy for addressing key national priorities through the planning
system, including sustaining and developing a vibrant economy, achieving decarbonisation and climateresilience, developing strong ecosystems and improving the health and well-being of our communities.
The National Plan notes that the planning system must respond to these changes and contribute to a
sustainable recovery, shaping places around a vision for healthy and resilient places. The strategy blends
the existing settlement patterns and the distribution of jobs and homes with a vision of managing change
and future trends for the benefit of everyone in Wales. Planning Policy Wales is the primary source of detail
on how the planning system will support reconstruction efforts.
3.4 Future Wales is the highest tier of development plan and is focused on solutions to issues and challenges
at a national scale. Due to its strategic nature, it does not allocate development to all parts of Wales, nor
does it include policies on all land uses. It is a framework which will be built on by Strategic Development
Plans at regional level and Local Development Plans at local authority level. As set out on Page 52 of
Future Wales, the 11 Outcomes are collectively a statement of where the Welsh Government aspire
Wales to be in 20 years` time as follows:
A Wales where people live:
1. …and work in connected, inclusive and healthy places
2. …in vibrant rural places with access to homes, jobs and services
3. …in distinctive regions that tackle health and socio-economic inequality through sustainable growth
4. …in places with a thriving Welsh Language
5. …and work in towns and cities which are a focus and springboard for sustainable growth
6. …in places where prosperity, innovation and culture are promoted
7. …in places where travel is sustainable
8. …in places with world-class digital infrastructure
9….in places that sustainably manage their natural resources and reduce pollution
10. …in places with biodiverse, resilient and connected ecosystems
11. …in places which are decarbonised and climate-resilient
3.5 Page 60 notes that “In all parts of Wales the strategy supports sustainable growth. Any place without jobs,
homes, community spaces and wildlife has no prospect of having a thriving and cohesive community, Welsh
language or economy. There is such a thing as too much development or the wrong type of development,
whereas sustainable development should foster a stable or growing population to ensure a healthy natural
environment and economic and social stability”.
Planning Policy Wales
3.6 National planning policy is contained within the eleventh edition of Planning Policy Wales (PPW),
published by the Welsh Government in February 2021. It is the principal document for planning
considerations in Wales. PPW provides land use planning policy and should be taken into account when
preparing planning applications. It is supplemented by a series of Technical Advice Notes (TANs), Welsh
Government Circulars, and policy clarification letters, which together with PPW provide the national
planning policy framework for Wales. The planning system is central to achieving sustainable
development in Wales. It provides the legislative and policy framework to manage the use and
development of land in the public interest which is consistent with key sustainability principles.
3.7 Sustainable Development is defined at Page 7 of PPW as follows: “the process of improving the economic,
social, environmental and cultural well-being of Wales by taking action, in accordance with the sustainable
development principle, aimed at achieving the well-being goals”. Paragraph 1.18 sets out that “legislation
secures a presumption in favour of sustainable development in accordance with the development plan
unless material considerations indicate otherwise to ensure that social, economic, cultural and
environmental issues are balanced and integrated”. Paragraph 1.18 of PPW relates to sustainability which
emphasises that the planning system should provide for a presumption in favour of sustainable
development to ensure that social, economic and environmental issues are balanced and integrated (Para
4.2.2). In Paragraph 2.3 it goes on to state that “The planning system should create sustainable places
which are attractive, sociable, accessible, active, secure, welcoming, healthy and friendly. Development
proposals should create the conditions to bring people together, making them want to live, work and play
in areas with a sense of place and well-being, creating prosperity for all.”
3.8 The Well-being of Future Generations (Wales) Act 2015 is brought up in PPW, which places a duty on
public bodies (including Welsh Ministers) to carry out sustainable development. In carrying out this duty,
actions which public bodies must take include:
• setting and publishing objectives (“well-being objectives”) that are designed to maximise its
contribution to achieving each of the well-being goals; and
• taking all reasonable steps (in exercising its functions) to meet those objectives.
3.9 The Act puts in place seven well-being goals to help ensure that public bodies are all working towards
the same vision of a sustainable Wales. These include the need for cohesive communities which are
attractive, viable, safe and well-connected.
3.10 In addition, sustainable development should be achieved through the design which is described in
Paragraph 3.3: “Good design is fundamental to creating sustainable places where people want to live, work
and socialise. Design is not just about the architecture of a building but the relationship between all
elements of the natural and built environment and between people and places. To achieve sustainable
development, design must go beyond aesthetics and include the social, economic, environmental, cultural
aspects of the development, including how space is used, how buildings and the public realm support this
use, as well as its construction, operation, management, and its relationship with the surrounding area.”
3.11 In terms of housing, Paragraph 4.2.1 notes the following: “Planning authorities must understand
all aspects of the housing market in their areas, which will include the requirement, supply and delivery
of housing. This will allow planning authorities to develop evidence-based market and affordable
housing policies in their development plans and make informed development management decisions that
focus on the creation and enhancement of Sustainable Places. New housing development in both
urban and rural areas should incorporate a mix of market and affordable house types, tenures and sizes
to cater for the range of identified housing needs and contribute to the development of sustainable and
cohesive communities”. In relation to housing, PPW states that the planning system ought to:
“recognise a supply of land to assist the delivery of the housing needs to meet the varying requirements
of communities across all tenures; offer provision of a spread of well-designed, energy efficient, high
quality market and affordable dwellings that contribute towards the formation of sustainable settings;
and concentrate on delivery of the recognised housing requirement and associated land supply”.
3.12 In terms of the historic environment, Paragraph 6.1.5 notes that “The planning system must take into
account the Welsh Government’s objectives to protect, conserve, promote and enhance the historic
environment as a resource for the general well-being of present and future generations. The historic
environment is a finite, non-renewable and shared resource and a vital and integral part of the historical and
cultural identity of Wales. It contributes to economic vitality and culture, civic pride, local distinctiveness and
the quality of Welsh life. The historic environment can only be maintained as a resource for future generations
if the individual historic assets are protected and conserved.” This is a key aspect of wider sustainable
development responsibilities which should be taken into account in both the formulation of planning
policies and the exercise of development management functions. The conservation of the historic
environment also contributes to the Welsh Government’s seven well-being goals for a sustainable Wales
Carmarthenshire Local Development Plan
3.13 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires that planning application
decisions should be made in accordance with the development plan unless material considerations
indicate otherwise. The statutory development plan for this site is provided by Carmarthenshire Local
Development Plan (LDP) 2006 – 2021 which was adopted by the County Council in December 2014.

3.14 The site lies immediately outside the development limits of Cross Hands and Tumble, to the north of
Bryngwili Road. However the site is still designated under a number of different categories by the LDP
such as: High Specification Aggregate - Sandstone and Igneous Rocks MPP3, Secondary Resource
Zone MPP3, Caeau Mynydd Mawr SPG Area EQ7, Higher proportion of Welsh Speakers SP18 and the
Affordable Housing Viability Targets AH1 (10%).
3.15 The Carmarthenshire Local Development Plan Review will be required to make provision for future
housing needs with an extended Plan Period to 2033, including those of individual settlements in
accommodating necessary levels of growth to maintain communities and facilities.
3.16 The following section will seek to establish that national planning guidance is supportive of a limited form
of residential development taking place on the site. In these circumstances, therefore, it is submitted that
these aspects should be taken into account when assessing the merits of the site as a housing land
allocation through the LDP Review site selection process.
4 Appraisal
4.1 This section examines how the submission site accords with prevailing planning policy in terms of
identifying housing land allocations within development plans.
Availability of Previously Developed Land
4.2 The site is not brownfield land but is well-connected to the current settlement pattern of Tumble and
Cross Hands, and its development for residential purposes represents a logical extension of those limits
for residential development and inclusion within the settlement boundary, at this location. As previously
mentioned, there are several facilities and amenities within walking distance of the site, primary and
secondary schools, and a surgery.
4.3 In order to achieve a sufficient range and choice of housing land opportunities, there will be a need to
consider sites which represent viable urban extensions, especially those which could contribute to the
Council’s housing land supply until 2033.
Accessibility
4.4 The site sits directly north of Bryngwili Road, which can be accessed via a gate along the southern portion
of the land. Transport links are also good, with the A48 being easily accessible from the site. Bus stops are
also provided along Bryngwili Road, with the nearest within 20m of the access point, which enables travel
to and from Llanelli, Ammanford and Carmarthen bihourly. In terms of train provision, both Pantyffynnon
and Ammanford stations lie a quarter of an hour away and are situated along the Heart of Wales line. A
national cycle route lies in close proximity to the north, providing a route for cyclists and pedestrians to
use at their leisure.
Land Ownership
4.5 The land to which this Candidate Site Representation refers is within the joint-ownership of the Site
Promoter – Suzie Jones and Bryn Jones. Both landowners are fully committed to bringing forward the
development of the site. They have informed us that there is a contractor ready to build on site and an
estate agent has clients waiting to purchase. Bringing this site forward will help meet the housing need of
Cross Hands in the short term. Within the deposit plan, three of the four housing allocations for Cross
Hands have been built out, whereas the other allocation only concerns a small scale allocation.
Consequently, other sites within the settlement ought to be considered, and due to limited land within
settlement limits, the search ought to be extended to areas outside the development boundary whilst
taking into consideration the nature of the existing settlement pattern.
Capacity of Infrastructure
Utilities
4.6 The site lies adjacent to existing development at Bryngwili Road where utility services are readily available
or can be provided. In addition, as the detailed design of the proposed development progresses, the
provision of electric-charging on a plot-by-plot basis will be considered further.
Drainage
4.7 The site is located within ‘Zone A’ of National Resources Wales (NRW) Development Advice Map, which
means it is considered to be at little or no risk of fluvial or coastal/tidal flooding. Appropriate means of
surface water drainage, including SUDs will be considered. It is not anticipated that there are capacity
issues in the area regarding foul drainage.
Access
4.8 The site sits directly north of Bryngwili Road, and currently benefits from a gated access with good inter
visibility along the site frontage.
Impact on the Community/Welsh Language
4.9 The site is located within an area designated as being a higher proportion of Welsh Speakers (under
policy SP18). It is considered that a housing development at this site will accord with Policy SP18 by
assisting in ensuring sufficient and proportionate housing supply for Welsh Speakers, including
affordable housing provision comprising greater than or equal to 10% of the site, which is fully policycompliant with policy AH1 of Carmarthenshire’s LDP – providing young, local Welsh Speakers the
opportunity to stay in the area. In terms of Welsh speakers, this will be helped by the fact that there are 5
Welsh medium primary schools in close proximity to the site, along with comprehensive school Ysgol
Maes y Gwendraeth,
Physical and Environmental Constraints
Ecology
4.10 It is considered that any existing trees and hedgerows on site could be incorporated into a residential
layout. Notwithstanding it may be necessary for further ecological and tree surveys to be undertaken to
determine any potential impacts on protected habitats/species.
Visual Impact
4.11 Given the surrounding residential development, the design of the dwellings would need to be in keeping
with the character of the area with the existing dwellings mainly consisting of more traditional two storey
dwellings with pitched roof design. It’s not anticipated that a residential development on this site would
give rise to any adverse visual impacts with good design and layout of the site.
Flood Risk
4.12 The site is not identified in the TAN 15 Development Advice Map as being at risk from flooding.
Site Contamination
4.13 In terms of ground conditions there are no known constraints that prevent the development of the site
for residential uses in trems of ground contamination.
Compatibility with Neighbouring Uses
4.14 Given the land use in the surrounding settlement is mainly that of a residential nature, it is considered
that the principle of residential development at this site would form a compatible use with the
neighbouring uses. To ensure residential amenity is protected, adequate separation distances and
compatible design of any future dwellings will need to be carefully considered. Currently, the site
benefits from strong boundary features including hedgerows, which could be incorporated into the
design of the site to provide a buffer between residential developments.
Coalescence of settlements
4.15 Development on the site would not result in the coalescence of settlements. Development of the site will
result in a marginal extension of Cross Hands` development limits, although the most southern part of
the site already within settlement limits in the deposit plan. Extending the boundary a little further north
will not impact the make up of the settlement.
The potential to reduce carbon emissions through co-location with other uses
4.16 The site is considered to be located in a sustainable location with a bus stop within 20m of the site access
along Bryngwili Road. Links to Ammanford, Llanelli and Carmarthen are provided bihourly, with a school
service number 109 also serving the secondary school along Heol y Parc in Cefneithin. Therefore it can be
seen that the location of the proposed development will encourage travel by means other than car, thus
reducing carbon emissions.
Relationship with Historic Environment
4.17 Approximately 175m to the west of the gated access to the site, a Grade 2 listed building can be found
that demarcates a milestone between Cross Hands and Tumble. It is not anticipated that any proposed
works at the site will affect the setting of this historic asset.
Delivery of Key Placemaking Objectives
4.18 Placemaking is at the heart of both ‘Future Wales’ and Planning Policy Wales (Edition 11, February 2021).
As set out at Section 3 of ‘Future Wales’: “Future Wales’ Outcomes are overarching ambitions based on the
national planning principles and national sustainable placemaking outcomes set out in Planning Policy
Wales”. Preliminary investigations have identified that the candidate site can provide homes in the right
place and create a sustainable, well-designed, and high-quality housing scheme, where people will want
to live, in accordance with national placemaking objectives.
5 Conclusion
5.1 This Candidate Site representation is made by Asbri Planning Limited on behalf of Suzie Jones and Bryn
Jones and requests that land to the north of Bryngwili Road, Cross Hands is brought forward as a
housing land allocation through the Carmarthenshire County Council Second Deposit Revised Local
Development Plan 2018 - 2033.
5.2 The allocation of the site will assist in ensuring the adequate delivery of housing in Cross Hands, with
most of the housing allocations within the deposit LDP having already been developed, therefore there is
an additional need for housing in the area. 4 of the housing allocations ought to be removed from the
deposit plan as they have already been built out, whereas the remaining one at the land adjacent to
Maesyrhaf only has an allocation for five dwellings across the plan period. The scale and nature of this
site would be attractive to house builders, which would facilitate delivery in the short to medium term.
The land owners have stated that they are keen for the site to be developed in the short term, with a
contractor in place to start building, along with an estate agent that has clients ready to purchase. The
southern end of the 1.5 hectare site lies within the development limits of the deposit plan, however this
submission requests that the boundary is extended further north as shown in Appendix 1 in order for the
site to accord with Policy SD1 (Development Limits).
5.3 The site could potentially deliver several dwellings of various types and sizes which could be phased as
appropriate and which would complement the existing form of the settlement. It will not give rise to any
significant adverse impacts upon the character of the area, local amenities, residential amenity and highway
safety whilst providing a significant contribution to the area’s housing land supply requirements.
Furthermore, it is positioned in a sustainable location where several amenities lie nearby, and there are
adequate public transport connections on offer.
5.4 This submission has assessed the site against prevailing planning policy in Wales. It is clear that the
proposals are compatible with the relevant criteria. It is acknowledged that proposals will need to be
refined on the basis of further comprehensive study information.
5.5 In light of the above, it is, therefore considered that Carmarthenshire County Council should, in its review
of the Local Development Plan, identify the land at Bryngwili Road, Cross Hands as a housing land use
allocation.

Include the site within the Revised LDP development limits at Aberlash Road, Ammanford.

We are instructed by Mr & Mrs M. Lloyd 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/004/019, seeking inclusion of their land for future residential development within the
defined settlement limits of Ammanford within the Replacement Local Development Plan.
The Candidate Site comprised two parts, being the frontage part of a grazing field off the
northern side of Aberlash Road, and the majority of an open field fronting the southern side
of Aberlash Road.

We have noted that the northern part of the Candidate Site is included within the draft
settlement limits. Our clients are very satisfied with this inclusion and wish to express their
support and gratitude to the Council. They intend to seek planning permission for detached
houses upon this area within the new limits immediately after LDP adoption.

However, the southern field has not been included within the Second Draft settlement
limits, despite formal representations made to you following publication of the First Draft of
the LDP in March 2020. This formal Representation to the Second Draft relates solely to the
unsuccessful part of the Candidate Site.
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
settlement limits of Ammanford, as contained within the Second Deposit Draft.
We note that the submission successfully passed through Stage 1 (site compatible against
the location of future growth presented in the Preferred Strategy) and Stage 2A (Initial
Detailed Site Assessment) of the Council’s site assessment.
However, it was rejected at Stage 2B (further detailed site assessment), with reasons for
non-inclusion reported as follows:
Development of the southern part of the site would be likely to impact upon trees subject to
Tree Preservation Orders and access to the site is likely to be gained through an area which
falls within the C2 floodzone as identified in the TAN15 Development Advice Maps.

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 Second Draft settlement limits for Ammanford, 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 Ammanford, as reproduced
below in Figure 1.

Figure 1 – Extract from Proposals Map with Representation 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
- Location and indicative site layout plan
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits

1.0 Impact upon trees subject to Tree Preservation Order

1.1 The Council consider that the inclusion of the site within defined settlement limits
would be likely to impact upon trees which are the subject of a Tree Preservation
Order. The TPO in question is “E48”, which is shown below, being an extract from the
Council’s on-line record of Tree Preservations Orders in Carmarthenshire.

Figure 2 – Extract of Tree Preservation Order record for Aberlash locality

1.2 The Order amounts solely to two individual mature specimens, one set on the road
frontage of the field, whilst the other lies near the eastern field perimeter with existing
dwellinghouses at Ffrwd -y-Felin. The specimens in question are graphically shown
by the Google Earth image reproduced below as Figure 3.

Figure 3 – Extract from Google Earth (April 2021) illustrating two protected
mature tree specimens

1.3 Both trees are well defined with equi-concentric crown spreads from respective
central trunks, and as such an indicative site layout plan can easily be adapted to
illustrate a form of residential development which can effectively preserve each
specimen and ensure their future health and well-being, allowing existing root
protection areas to be designated and thereafter maintained.

1.4 The original Candidate Site indicative site layout plan has been subsequently revised
to account for this issue, and is reproduced below as Figure 4. It illustrates for only
four detached dwellinghouses set fronting the southern flank of Aberlash Road, and
thus also complementary in form to adjacent established forms of residential
development along this highway and particularly the exisiting and proposed form of
frontage development off the opposite, northern flank of Aberlash Road.
TPO
specimens

Figure 4 – Indicative site layout plan of proposed Representation Site

2.0 Proximity to Zone C2 Flood Zone & Means of Emergency Access / Egress

2.1 The Council indicate that the Candidate Site fails to be included within defined
settlement limits as access to the site is likely to be gained through a “Flood Zone
flood zone as identified in the TAN15 Development Advice Maps.” The Council are
referring to the designated flood zone of the River Lash as reproduced below as Figure 5.
The extreme fluvial flood waters are predicted as flowing over the public
carriageway of Aberlash Road, where that highway underpasses the Heart of Wales
railway line. The new draft “Flood Map for Planning” which is due to supersede the
DAM map in 2023/24 also repeats the same extent of flood zone east of the site.

Figure 5 – DAM map illustrating extent of flood zone

Figure 6 – extent of Flood Map for Planning

2.2 In response, our clients would point to that contractors acting on behalf of Natural
Resources Wales have recently begun the implementation of flood alleviation works
to this section of the River Lash, as part of their capital expenditure programme for
the town of Ammanford. The Alleviation Works are considered by NRW to be “a
combination of measures is needed to reduce the risk of flooding. We believe that the
best option is to construct a series of flood defence embankments and walls in
several areas in the town to contain flood water in the River Loughor, and installation
of Property Flood Resilience (PFR) measures to houses on Aberlash Road.”

2.3 We therefore submit that flood prevention matters are being put into place by NRW to
effectively manage the effects of flood waters during such extreme events. We
submit that following the completion of these works, it will lead to a revision of the
Development Advice Map, and consequential redrawing of the flood zone
designation.
Notwithstanding this, existing and proposed residents at Aberlash also have the
option to egress the locality by travelling north to Waunfarlais Road and back to the
A483 AND along Waunhafog Road west towards the B4556 Llandybie to Penygroes
road. Neither of which are, nor would be, affected by flooding.

2.4 We submit that the land subject of this Representation remains within Zone A, and
as such is not subject to flood risk. In accordance with TAN 15 advice, new
residents could remain in their properties, as a place of safe refuge, and await those
extreme floodwaters to recede. ALL ABERLASH ROAD RESIDENTS WILL HAVE A
LOGICAL MEANS OF EVACUATION as required by TAN15 Guidance.
We submit that in any extreme event the depth of floodwaters at this point and are of
a depth so as to not to prevent emergency vehicles from accessing Aberlash Road
properties, which given the limited headroom of the railway bridge have to travel
along Waunfarlais Road to access Aberlash Road properties.

3.0 Overall Housing Supply at Ammanford with Deposit Draft

3.1 The proposals under this Representation merely seek the addition of four residential
units to the overall housing supply of Ammanford. Aberlash forms part of the principal
service centre centring upon the Ammanford Cluster as defined within the Second
draft LDP.

3.2 The new Draft Proposals Map reveals that the Council have allocated a total of 8
sites at Ammanford as shown below.

3.3 The above eight alocated sites proposed for Ammanford reveal a combined total of
292 units, howeve upon analysis it is clear Wind Street, Llys Dolgader, Gwynfryn and
Yr Hen Felin have already been constructed, totalling 49 dwellings.

3.4 Of the other four Ammanford allocations, it is immediately noteworthy that they are
predominately “roll-overs” from earlier Development Plans with those sites showing
no commitment whatsoever to commit to the implementation of a planning
application. We would comment on the two largest of those sites as follows:
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.

Figure 7 – wider view of Ammanford draft Proposals Map
3.5 Site Prc3/H36 - Betws Colliery – for 66 units

Outline planning permission was first granted for residential development on the
allocation as far back as 2005 (Application E/09584), with reserved matters being
granted in 2011 (Application E/24724). A Non-Material Amendment (Application
PL/04568) has been granted in September 2022 for the ‘Removal of chimneys and
raising the height of window sills’.
The site was allocated in the Carmarthenshire Local Development Plan (2014) as
part of a larger allocation (GA3/h9), and Allocation PDB27 of the Carmarthenshire
Unitary Development Plan (2006), which included the land south of Ffordd y Glowyr,
which has been developed.
However, the northern element continues to be allocated for 66 units in the Second
Draft LDP. This is despite having almost 20 years of support for the principle of
residential development at the historic allocation from the Council, with not a single
housing unit has been delivered to date.

In conclusion, this Representation to the Deposit Draft of the Revised LDP has sought to
examine the Council’s reasons for non-inclusion of a Candidate Site. It has successfully
addressed two technical issues, and revised the indicative site layout proposals to ensure
any future houses avoid incursion into the root protection zones of two mature protected
trees, and; will access the A483 Ammanford Road via Aberlash Road where the NRW have
embarked upon a series of flood prevention measures, with the aim to lessen the effects of
fluvial flooding upon the locality. The site itself nevertheless remains flood-free.

This Report has also painted an inconsistent rationale applied by the Council in continuing to
allocate historic allocations in the LDP, without the majority of those units having been
brought forward over the last 20 years. Their continued retention within the Plan renders the
Plan as undeliverable, contrary to Planning Policy Wales guidance. Those sites should be
omitted, and more modest alternatives included such as that promoted at Aberlash Farm.
Our clients have presented their indicative proposals to promote a frontage development of
only four additional dwellinghouses. The proposals will be compatible with existing and
proposed development along both flanks of Aberlash Road, and thus ensuring that future
development respects 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 Ammanford realigned to include the
Representation Site in the Proposals Map of the adopted Local Development Plan.

Include site within the Revised LDP.

1.0 I NTRODUCTION
1.1 Mr & Mrs S. Davies (the Land Owner) have instructed Evans Banks Planning Limited to prepare and submit an Alternative Site Supporting Statement for the inclusion within defined settlement limits of land part of Sarnau, Glandy Cross, Carmarthenshire for the purposes of residential development in the forthcoming Replacement Carmarthenshire Local Development Plan.
1.2 This Statement has been prepared in line with the Authority’s published documents entitled Revised Carmarthenshire Local Development Plan: Guidance Note and Revised Carmarthenshire Local Development Plan: Candidate Site Assessment Methodology. The contents of this Statement therefore address the set criteria, determining the issues and each qualifying point raised within these documents.
Consideration has also been given to ensuring that this formal submission complies with the guidance and requirements of Planning Policy Wales (Edition 11), in relation to the preparation of development plans and the allocation of land for residential purposes as part of that preparation process.
1.3 The contents of this Statement therefore provide a comprehensive case for the inclusion of the land for residential development purposes within the defined settlement limits of Glandy Cross, and it should also be read in conjunction with the accompanying supporting information and indicative site layout plan.
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies

2.0.0 SITE CONTEXT
2.1 THE SITE
2.1.1 The Alternative Site relates to a parcel of undeveloped agricultural pasture which is set off the northern flank of a farm access track, off the A478 Road within the village of Glandy Cross. The entire field parcel is rectangular in shape and extends to a gross area of 3.4 acres (1.78 hectares). It has a continuous boundary around its perimeter consisting of hedgerows and mature trees, with the western perimeter flanking the A478 road.
2.1.2 The Alternative Site is modest, being only approximately 0.36 hectares (0.88 acres) in overall size, and has a frontage to the surfaced access lane, extending for a length of 90 metres to a two-storey established property known as Sarnau. That dwelling benefits from a domesticated garden to its western, front curtilage and also an irregular shaped enclosure off the southern, opposite side of the access track. Grazing fields extend to the north and east, with a large pond to be found to the immediate east of the property. The southern perimeter of the access track and Sarnau property lies off the rear gardens of bungalow properties set about a cul-se-sac known as “Bro Deirian.” Some 10 individual properties encircle a hammerhead road layout, with traditional rear garden space backing onto the Alternative Site.
2.1.3 The western flank of the A478 Road comprises of more established, older residential properties set fronting that highway, and with a modest field enclosure set allocated for further residential development within a triangular-shaped enclosure to its immediate north, which will have the effect of extending the village northwards. The Alternative Site should therefore be considered as a logical addition to Glandy Cross settlement, being directly opposite that allocated field, and which will mirrors that proposed development, but located to the east of the A478 extending north to an equivalent distance.
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies
2.1.4 The parcel of land is identified in red by Plan A, which illustrates its wider position within the settlement of Glandy Cross and shows the existing consolidated form of modest estate and frontage development to the A478 Road. Plan B provides a detailed Ordnance Survey map extract with the site perimeters identified.
Plan A – wider setting of Glandy Cross with site highlighted
Plan B – detailed OS Plan of Alternative Site
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies
2.1.5 Photographs of the Alternative Site are reproduced below, showing its current March 2023 condition and form. The Alternative Site is relatively level, and its long frontage to the A road is equipped with an agricultural field access set just to the north of a wide public bus top with its associated lay-by. A wide grassed verge lies off the back edge of pavement, with a linear hedgerow to the site frontage. The Site itself is relatively level, without any discernible differences in ground or contour levels.
Photo 1 – view of level field from adjacent A478 highway
Photo 2 – view of wide access track from A478 road
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies
Photo 3 – view to left (south) from existing access onto A478 road illustrating excellent visibility
Photo 4 – view to right (north) from existing access onto A478 road illustrating excellent visibility
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies
2.2 SETTLEMENT SUSTAINABILITY AND SITE SETTING WITHIN THE CURRENT ADOPTED LOCAL DEVELOPMENT PLAN & SECOND DEPOSIT DRAFT (FEBRUARY 2023)
2.2.1 Under the provisions of the current adopted Carmarthenshire Local Development Plan, the proposed land adjoins the Settlement Limit of Glandy Cross. The site is shown edged in red at Plan C below, with the Second Deposit Draft Plan extract shown as Plan D.
Plan C – 2014 Adopted LDP plan for Glandy Cross
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies
Plan D – Second Deposit Draft of Glandy Cross
2.2.2 The Alternative Site adjoins and is well related to the existing defined Development Limits of Glandy Cross. At present the development limits are drawn tightly about the existing settlement form at Bro Deirian. The Alternative Site seeks to mirror the development proposed on the opposite side of the A478.
2.2.3 The Alternative Site’s position and proposed use represents a natural and logical location for the settlement’s expansion ensuring that development is produced evenly throughout. Indeed, the property known as Sarnau together with the southern triangular-shaped enclosure were included within the settlement limits of the Carmarthenshire Unitary Development Plan. Outline planning permission was granted in 2006 for a new dwellinghouse within this southern enclosure.
2.2.4 Glandy Cross is a popular location particularly to new homeowners due to its accessibility to the nearby settlements of Clunderwen, Llandissilio and town of Narberth and Crymych, and its links via the A478 Penblewin to Cardigan Road.
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies
2.2.5 In terms of the Sarnau Site, it is located within easy driving distance of all community facilities and local services present provided within Glandy Cross and Efailwen settlements. Access to further facilities in the town of Narberth to the south and Crymych to the north can be gained by regular bus services where stops are located near the village crossroads upon the A478 road.
2.2.6 Transition from Adopted Local Development Plan (2006-21) – Allocation Status
In terms of planned growth, the proposed Alternative Site is located within the identified SC4 Settlement Cluster within the current LDP, adopted in December 2014. Glandy Cross and Efailwen are regarded by the Council as sustainable settlement communities several kilometres north of Clunderwen and Narberth within Pembrokeshire. Within these areas, those settlements are regarded as accommodating a range of services providing a modest degree of sustainability to the local community.
2.2.7 A number of the housing allocations within the LDP have yet to be delivered after 8 years since the Plan’s adoption. Glandy Cross appears to now been assessed as a separate settlement from Efailwen for the purposes of developing the Second Draft of the Replacement LDP. The new Inset Map identifies two residential allocations.
Plan C above provided an extract from the 2014 Proposals Map for Glandy Cross. It indicates two residential allocation sites in Glandy Cross, being SC4/h1 at “Maesglas” and SC4/h2 at “Cross Roads”. The Council have chosen to retain those sites within the Replacement LDP. Maesglas is now allocated as SuV55/h1 for a total of 9 units, whilst “Cross Roads” is no longer allocated but continues to lie INSIDE new draft settlement limits. Plan D below provides an extract of the 2014 adopted LDP extract for Glandy Cross.
In considering, the formulation of a new Plan, the Council have examined four Candidate Sites put forward in August 2018. In 2023, the Council provides an Assessment Report evaluating those Candidate Sites, and in the case of Maesglas indicates that it should continue as an allocation based upon “Outline Application pending on this site. Site to remain as an allocation with reference SUV55/h1.” That
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies
application is referenced W/38320 which was granted in May 2021. However, only outline planning permission was granted, and in the subsequent two years, no submissions for Approval of Reserved Matters have been made. It therefore remains questionable as to whether the development of that site will be brought forward.
In terms of SC4/h2 at Cross Roads, the Council’s online application records reveal that no applications for planning permission have been submitted in the 8 years since adoption, and therefore it must be questioned why the land remains within settlement limits?
2.2.8 The net result is that despite the Settlement Community continuing to have good provision of community facilities, local services and public transport connections to Crymych and Narberth, its ability to grow and capitalised on these sustainable attributes has been prevented through a lack of delivery of existing allocations. More deliverable residential opportunities are required. The deliverability of the remainder of the longstanding allocations are clearly in doubt, so, in order to re-address this deficit in provision and capitalise on the sustainability of the Sustainable Community, more deliverable residential allocations are required.
2.2.9 Second Deposit Draft LDP (February 2023)
The Council published a Deposit Draft in February 2023, which is now subject of public consultation. Within the Second Deposit Draft, the following sites are allocated for housing provision within Glandy Cross.
Table 1 – 2023 Second Deposit Draft Allocations
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies
2.2.10 It is noted that the level of allocation in Glandy Cross has remained consistent. The Maesglas site is evident, as is a new allocation at “land north of Cross PH.” That site is allocated as SuV55/h2 for 6 units. It is noteworthy given its position lying directly opposite Sarnau off the opposite, western flank of the A478 road.
We consider that it is clear that there is a need for an additional minor site within the proposed Replacement LDP. Sarnau is located across the main road from SuV55/h2 and possesses the same physical and locational characteristics as that site. In the case of Sarnau it benefits from being located off an established vehicular access lane off the A478 road and has an established residential dwelling located within the Alternative Site.
2.3 Settlement Facilities
2.3.1 The Alternative Site lies upon the A478 Penblewin to Cardigan main highway, only some 5 miles south of Crymych. Public bus stops are located immediately adjoining the Glandy Cross crossroads, only two minutes’ walk from the Alternative Site. Main public bus services call at these stops, particularly the 430 service (Cardigan to Narberth) which calls at Crymych to the north and Clunderwen and Llandissilo to the south.
2.3.2 The Sarnau Site is a short 5 minutes’ drive from Clunderwen railway station which has services to Cardiff and Swansea to the east and Haverfordwest and Milford Haven to the east.
2.3.3 It lies within a one-minute walk from the Glandy Cross petrol filling station and general store whilst Ysgol Beca Primary School is a two-minute drive away at Efailwen.
2.3.4 Narberth town centre is located a short 15 minutes’ drive away with its associated comparison shops, high street banks, public houses/cafes, offices, industrial estate, library, and leisure/recreation facilities.
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies

3.0
3.0 TTHE HE PPROPROPOSOSALAL
3.0.1 This Statement is accompanied by an indicative layout for a potential residential scheme that could be development on the site. It should be emphasised that the accompanying layout is for illustrative purposes only, and that other design solutions for the site could be reached. Notwithstanding this, the accompanying layout drawing has taken into account all potential assets and constraints of the site and demonstrates that it can deliver 4 units in a deliverable and sustainable manner.
3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Alternative Site be allocated in the forthcoming replacement LDP for the purposes of a combined total of 4 residential units. As detailed above, the accompanying illustrative layout demonstrates that the site can accommodate this number in a deliverable and sustainable manner. Plan E illustrates the indicative site layout for the Alternative Site, as edged in red, extending off the A478 highway, proposing a mirrored and balanced development to that to the west of the highway and Bro Deirian to the immediate south.
Plan E – Site Layout
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies
3.1.2 As illustrated above, the site is capable of accommodating detached bungalows to replicate and being reflective to the existing form of the development to the south at Bro Deirian.
3.1.3 With regards to access, it is proposed that the Alternative Site would be served by an improvements and widening of the existing access track adjoining the A478 highway. Vehicle speeds are consistent with the 40mph speed limit, and thus visibility splays of 2.4m x 59m can easily be achieved where the accesses adjoin the A478 road.
3.1.4 The Alternative Site proposals can fully retain all existing boundary treatments being established tree perimeter and hedgerows about the existing house.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Development of the Alternative Site for residential units would be served by mains water, public sewer and electricity connections.
3.2.2 A new estate road is proposed within the development. This will be equipped with roadside gullies and drainage which aid discharge run-off from the carriageway. The proposed accesses to the site could connect to the existing highways drainage.
3.2.3 The Alternative Site comprises of former agricultural pasture and domestic curtilage. There are no areas of significant marshy grassland or water-logging evident, and therefore at first inspection, it appears that the site benefits from good ground percolation of rainwater.
3.2.4 Soakaways would be the most sustainable means of disposing of surface water from individual properties. If required, attenuation measures can be deployed on site to control surface water run-off during extreme storm events, which could also allow for additional capacity, making allowances for climate change. Such features can be soft engineered in the form of attenuations basins and / or swales, thus adhering to the principle of Sustainable Urban Drainage Systems (SUDS).
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies

4.0
4.0 EENVIRONMENTAL NVIRONMENTAL CCONSIDERATIONSONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 The Alternative Site has been assessed against data held on the “Data Map Wales” website which details statutory and non-statutory National and Local sites of ecological importance. Plan F below provides an extract of those records applied to the Glandy Cross locality. The red star denotes the position of the Alternative Site.
Plan F – Extract from Data Map Wales detailing any known ecological interests
4.1.2 The records reveal that the Alternative Site does not include or adjoin any national or local nature conservation designation. The Eastern Cleddau SSSI lies several kilometres west of the village.
Any biodiversity assets that may be present or adjoining the Sarnau Site have been given full consideration with regards to exploring its potential for residential development. This has included the proposed retention and management of existing boundary trees. It is envisaged that the entirety of mature tree lines could be retained and managed further for uninterrupted biodiversity gain.
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies
4.1.3 It is considered that any statutory and non-statutory designations are significantly distant from the site, which will ensure that its development would have no detrimental impact upon them.
4.2 HISTORICAL ASSETS
4.2.1 The Alternative Site has been assessed for any proximity to known and designated Historic Assets, using the “Cof Cymru – National Historic Assets of Wales” from CADW’s website. An extract from Cof Cymru Assets map for Glandy Cross is reproduced below as Plan G. The red star denotes the position of the Sarnau Site.
Plan G – Extract from Cof Cymru Historic Assets website
4.2.2 The extract reveals a multitude of Scheduled Ancient Monuments in the locality; however, none are to be found within the Alternative Site field enclosure and are located south-west and north-east of the village.
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies
4.3 ENVIRONMENTAL CONSTRAINTS
Potential for Risk from Flooding
4.3.1 The Alternative Site has been assessed against the Flood Map for Planning, prepared by Natural Resources Wales, and as referred to within the Welsh Government’s revised / draft “Technical Advice Note 15: Development and Flood Risk”. An extract from the Flood Map for Planning is reproduced below as Plan H, with the site denoted by a red star.
Plan H – Extract from NRW’s Flood Map for Planning
4.3.2 The above plan extract revels that no part of the Alternative Site lies within the designated flood zones, and thus the potential development of the site is not at risk from either fluvial or tidal flooding.
4.3.3 An examination has also been made of NRW records relating to potential surface water flooding, as shown by purple tone in the above plan. The red star again denotes the positioning of the Alternative Site and reveals there to be no potential for pooling of surface water upon the site.
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies
Past and Present Potential for Ground Contamination and Coal Mining Activity
4.3.4 The Candidate Site comprises a modest former agricultural field. Due to its greenfield nature and agricultural use, the field as no history of known past ground contamination related constraints.
4.3.5 The records of The Coal Authority have been examined and reveal no history of coal mining in this part of the County.
5.0 VIABILITY
5.0.1 As part of the preparation of any development plan, it is vital to ensure that allocations within it are both viable and deliverable. To not make efforts to explore both aspects inherently poses risks that the Plan may be unsound and so in turn fails to meet its own targets or objectives.
5.0.2 Although detailed viability appraisals are difficult to prepare at this stage of the Plan’s preparation due to the absence of, for example, such things as full engineering details, it is possible to undertake
5.1 VIABILITY APPRAISAL
5.1.1 The following provides an indication of the viability of delivering the proposed 4 units on the Alternative Site in question. It is based very much on its greenfield status and uses values and costings previously accepted by the Local Authority through its determination of planning applications and other works. The following appraisal is therefore based on the assumptions set out below in order to provide a residual land value for the scheme.
Costs
• Dwelling construction costs are based on an absolute minimum of £1300 per metre given that bespoke four bed detached bungalows (160 sq.m.), with a
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies
medium grade of internal finishing, and formation of accesses to the highway are likely to be the preferred house type.
• Estate road carriageway costs are placed at £1200 per linear metre
• Connections for all utilities include water, foul water and electric.
• Developer’s Profit based on minimum RICS guidelines (18%)
• Professional Fees include planning application fee, associated professional fees, estate agency fees (1%) and LABC Warranty fee.
Sales Values
• Sale Prices based on LPAs “Affordable Housing” Supplementary Planning Guidance, market research and Welsh Government “Acceptable Cost Guidance” figures where relevant.
5.1.2 Using the above, the following represents a strategic viability appraisal for the proposed 4 units, based on an affordable housing level being a financial contribution of £75.00 per square metre of internal floorspace.
Costs
Cost Per Unit/Metre
No. Units/Metres
Total
Four Bed Bungalows
208,000
4
832,000
Road Construction
1200
100
120,000
Utility Connections
5000
4
20,000
Professional Fees
-
-
40,000
Sprinklers
3500
4
14,000
Affordable Housing
75
640
48,000
Contribution
Total
1,074,000
Sales
Four Bed (Open M’kt)
400,000
4
1,600,000
Developers Profit
Total
288,000
Residual Land Value
238,000
Table 2
5.1.3 Based on the above figures, it is considered that in-principle, the development of the site would be financially viable. The residual land value of £238,000 for a site
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies
consisting of four development plots (£59,000 per plot) is consistent with evidence gathered over recent years by the District Valuer in examining residential site transactions within Carmarthenshire. The DV discovered land values on completed and on-going sites to be averaging £245,000 per net residential acre of land, based on 2020 values.
5.2 DELIVERABILITY
5.2.1 In terms of deliverability, it should be firstly noted, as illustrated above, that the site is financially and physically viable, with no environmental, geo-physical or technical constraints prohibiting immediate development. Furthermore, there are no ownership or third-party interests preventing the site’s delivery.
5.2.2 In terms of a delivery timescale, with a developer secured, it is envisaged that the site could be capable of being completed within 2 years from the adoption of the replacement Local Development Plan. Glandy Cross remains an attractive part of the cluster of villages about the Cardigan to Penblewin Road, benefitting from its semi-rural location, but easy access to Crymych and Narberth by road and the nearby schools, shops, services and community facilities.
5.2.3 The presence of modern, detached houses and bungalows adjoining and located immediately alongside at Bro Deirian is testament to this market need and the desire for home buyers to seek out such forms of modest residential development.
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies

6.0 NATIONAL PLANNING POLICY CONSIDERATIONS
6.1 In the preparation of any development plan, consideration must be given to national planning policy and guidance. At present, this takes the form of Planning Policy Wales and a series of Technical Advice Notes (TAN) that deal with a variety of topic areas.
6.2 With regards to residential development, or housing, the overarching requirements and principal guidance set by national policy can be found at Paragraph 9.2.3, which reads as follows:
“Local planning authorities must ensure that sufficient land is genuinely available or will become available to provide a 5-year supply of land for housing judged against the general objectives and the scale and location of development provided for in the development plan. This means that sites must be free, or readily freed, from planning, physical and ownership constraints, and economically feasible for development, so as to create and support sustainable communities where people want to live. There must be sufficient sites suitable for the full range of housing types.”
6.3 At present, Carmarthenshire County Council’s housing supply figure is below the required 5-year level therefore, it is imperative that this is addressed as quickly as possible to avoid further deterioration of communities and the facilities and services they have to offer.
6.4 Dealing specifically with the Alternative Site subject of this Report, it is evident that its inclusion within the Replacement LDP would adhere to the requirements of PPW, in that it is free from any planning, physical, or ownership constraint. In addition, as shown in Section 5 of this statement, the site is also economically viable in deliverability terms.
Alternative Site Supporting Statement March 2023
Land Part of Sarnau, Glandy Cross Mr & Mrs S. Davies

7.0 CONCLUSION
7.1 The Alternative Site is modest in overall size, with an established dwellinghouse located within a modest side curtilage and southern enclosure, backing onto Bro Deirian. That property and southern enclosure was set within the 2006 Unitary Development Plan and benefitted from outline planning permission to site a new dwellinghouse in this enclosure. At that time, the Council saw no reason to consider this site as one not otherwise conforming to the spatial and consolidated form of the village.
7.2 The Site lies within close proximity and walking distance to the existing community and local services of Glandy Cross and Efailwen which will ensure it makes a positive contribution to both national and local sustainable development objectives.
7.3 From a wider sense, the Site will also benefit from well served excellent public transport links to the nearby settlements, specifically the town of Crymych and Narberth, together with other locations within and adjoining the County. In tandem to this, the development of the Site will in turn ensure a deliverable source of future housing for the Sustainable Community in which it lies, which has seen both allocated sites fully developed leading to an under supply since the adoption of the current LDP. The development of the Site will help to redress this imbalance and it is strongly suggested that the Authority recognises the suitability and deliverability of modest sites if it is to continue to realise the contribution villages such as Glandy Cross make to the housing land supply.
7.4 With the Alternative Site having no access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership constraints, its delivery if included within settlement limits is assured. Combined therefore with its locational characteristics, the Site in question represents a sustainable alternative for future housing development.
7.5 In view of the above and the information provided within this Statement, it is respectfully requested that the Alternative Site in question be included within limits for a modest residential development.

That the development limit should be extended to include the remaining part of Land adjacent to Crofters Rest (ref. AS2/126/003), to encompass the full site as per the candidate site submission originally submitted in 2018 (ref: SR/126/001).

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.

Not to extend the boundary in the village of Llanllwch

I am not objecting to the wording of SD1 but the boundary limits as they relate to Llanllwch village.
The village boundary limits seem to have been extended, since the application for these two sites were submitted.
As previously stated in the 1st deposit of the LDP through to 2033, for the sites SR/098/001 + SR/098/002.
Poor access - both extended boundary areas lead onto a single track road.
High volume of traffic already plague this area. This will be increased with the agreed developments in Llangain and Travellers Rest/St David’s new road, as a lot of that traffic cut through Llanllwch.
Single track bridge, that has been damaged in the past and does lead to some vehicles, having to revers back towards a blind corner.
Additional traffic from any developments in the extended boundary area would only add to theses issues.
Any development would also add strain to the sewerage, water and electrical infrastructure.
Hazardous to walk in the village on times due to the lack of footpaths and vehicle congestion.
The area has a potential to flood.

No change to the Plan.

We fully support the allocation of the land in question for mixed use, together with the alteration of the development limits at this location to facilitate the comprehensive and effective development of the site.

Work on the preparation of a full planning application for the development of the whole of the site is ongoing and discussions with the local planning authority and all interested parties are now at an advanced stage. It should be also noted that a number of end-users have already been identified for various aspects of the site, clearly supporting the deliverability of the allocation.

No change to Plan

Based on the previously submitted infomation, I would strongly support the inclusion of site ref SR/077/002 within permitted development limit of Llanboidy for possible small scale development in line with the SD1 development limit policy.A possible small scale development on the proposed site is believed to be in keeping with the character of the village and would have minimal detrimental impact on the surrounding properties and highways, whilst having a small but positive effect on local amenities. The recent addition of a pavement (PL/02133) on land to the south east of the site, which was donated free of charge by the applicant has further enhanced the accessibility of the site. This area of thesite is deemed to be realistic in relation to the size of the village, and achievable in a fairly short time frame.

Include the site within the development limits in the Revised LDP.

A key factor in this Second Revised LDP is sustainability. This is being considered as central to the plan. The proposed site for two new dwellings at Pant Y Bryn would be powered entirely by the wind turbine already onsite. It is capable of meeting the demands of the existing properties and the proposed new properties. For the new properties it has the capacity to meet the whole of the energy demands, including driving a heat pump and to support a car charging point. This last also helps to overcome any transport issues, in that private transport could all be via electric vehicles.
A side effect of this is to reduce the burden on the national grid.

Water supply would be from the mains, as this is already in place, and waste would be dealt with on site via a biodigester and reed bed.

It could be argued that all new developments should aim for this level of sustainability.

No change to Plan.

We are instructed by Mr E Thomas to make a formal representation with regards to the
above land and the 2nd Deposit Draft of the Carmarthenshire Local Development Plan.

Our Client made a formal Candidate Site Submission in August 2018, seeking the inclusion
of their land (edged red on Plan A) within the development limits of Ammanford as part of the
Replacement Local Development Plan.

Plan A
The Candidate Site comprised of part of our Client’s existing residential curtilage, with its
northern, eastern and western boundaries clearly and strongly defined. The land therefore
clearly represented a logical rounding off of the existing developed form of the settlement at
this location.

Following its due consideration, the Council then included the land in question within the
Development Limits (see Plan B below) for the settlement of Ammanford in its Deposit LDP,
published in January 2020.

Plan B
Notwithstanding the above, for reasons outlined by the Council in their current submissions,
a revised second edition Deposit LDP was then prepared. As part of the preparation process
into the 2nd Deposit LDP, we understand the Council have again assessed all Candidate Site
submissions. As a result of this, Plan C represents an extract of the 2nd Deposit LDP
Proposals Map for Ammanford, clearly again identifying our Client’s land as falling within the
defined development limits:

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

No change to Plan

We are instructed by Mrs C. Davies 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/157/012, seeking the allocation of their land for residential development within the
settlement limits of Trimsaran as part of the Replacement Local Development Plan.

The Candidate Site comprises of an undeveloped paddock set off the southern flank of Heol
Morlais, as the B4308 runs through the centre of the village of Trimsaran. The proposals
seek inclusion of the frontage part of the enclosure to provide a small-scale development of
frontage houses to complement established properties off its eastern side flank, and the
access road to the former Miners Arms public house off its western side. It also lies directly
opposite further frontage houses off the northern 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 Trimsaran 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 cannot accommodate 5 or more dwellings, however, it will be included within the development limits.”

Plan A- Location Plan of Candidate Site

Plan B represents an extract of the Second Deposit LDP Proposals Map for Trimsaran, 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 Trimsaran

Our client therefore welcome and SUPPORT the decision of the Authority to 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.

Include the land within the development limits.

The promoter operates Beacon Stoves, Capel Iwan with his family and currently
lives at Parc Gwair with his parents. Beacon Stoves operates from the adjoining
property known as Ty Pren, a purpose built showroom and commercial space and
the adjoining storage building and yard. There is a desire for the family to continue
to work on site and live on site, but in sperate dwellings. Beacon Stoves is a
succesful family run business specialising in the sale and installation of log
burners. The business has expaned significantly in recent years going from a total
of 4 to 11 employees (including directors).
Capel Iwan is identified as a Tier 3 settlement (with a settlement boundary) and we
are currently assessing options for achieving the objective of developing a second
dwelling on site. The Deposit LDP2 suggests an overall reduction in the extent of
the settlement boundary at Parc Gwair and Ty Pren and therefore the land owners
feel it prudent to comment on the Deposit LDP2. The slight adjustment and
enlargement of the settlement boundary at the yard area to the south and west of
Ty Pren proposed as part of the deposit LDP2 is welcomed, however there are two
comments: (see also accompanying plan).
1. The Proposals map for Capel Iwan sees a reduction in land to the south of
Parc Gwair. This land could potentially facilitate the development of a
dwelling and it’s removal from the settlement boundary would potentially
prejudice this. It is requested that this land be reinstated.
2. In lieu of the removal of part of the land to the south of Parc Gwair, or in
addition to it, it is requested that the settlement boundary to the south of Ty
Pren is adjusted to include additional land to facilitate the construction of a
dwelling at this location. This addition would appear as a minor and logical
rounding off of the settlement boundary. Inclusion of this area of land,
identified as Option 1 on the accompanying plan, would be the priority for
the proposers. i.e if the LPA consider it prudent to allow only one of the
areas subject to this submission, the area south of Ty Pren (option 1 on the
accompanying plan) would be the priority.
The retention of the land south of Parc Gwair, and/or minor extension to the
settlement boundary to the south of Ty Pren would be minor logical rounding-off of
the development pattern that would fit in with the character of the village and
landscape in accordance with policy HM03: Homes in Rural Villages of the Deposit
LDP2. The areas would be unimposing given the immediate character of the area
and wider built form of Capel Iwan and a traditional hedgebank and planting could
be formed along the southern boundary of the proposed settlement boundary.
The site would be accessed via the existing accesses to the buildings and parking
area for Beacon Stoves, and electricity, water and mains foul connection points
are adjoining the site. There are no known capacity issues associated with these
services and there are no known highways, flooding or archaeological constraints
associated with the site. Issues relating to phosphate levels within the Riverine
Special Area of Conservation Catchments are acknowledged, but anticipating that
these issues are resolved in the short to medium term, the development of the site
would be viable and deliverable in the short to medium term. It is anticipated that
the development would make a financial contribution towards the provision of
affordable housing elsewhere, in line with the LDP policy.
It is anticipated that planning permission would be applied for immediately on
adoption of the LDP2 with the dwelling completed within 2-3 years thereafter,
subject to resolution of the phosphate issue. In contrast the closest allocation
within Capel Iwan (SuV38/h1) Maes Y Bryn for 6 dwellings has a long delivery
timescale of 6-10 years.
Inclusion of the land subject to these comments within the settlement boundary
would therefore provide the proposer with a dwelling in close proximity to their
family and place of work and contribute towards the delivery of housing in the area
whilst also respecting the 10% cap within the village set out in policy HOM3. For
the reasons set out above, the development would also contribute to the wellbeing
goals set out in the Well-being of Future Generations Wales Act 2015 and
the Future Wales: The National Plan 2040.
In light of the above, it is considered that the proposed adjustments to the
settlement boundary of Capel Iwan would be minor and logical, enhance the
deliverability of housing in an appropriate location and support the LDP’s
requirements for being deliverable and appropriate. Development of the site would
comply with all other policies of the deposit LDP2.
To summarise, the adjustments to the settlement boundary would facilitate the
delivery of a dwelling in a sustainable location that would strengthen the viability
and vitality of an existing family run business and therefore can be viewed as an
appropriate and acceptable adjustment to the deposit LDP2.
It is also considered that the adjustments would be compatible with the objectives
of the Sustainability Appraisal Framework.