SD1: Terfynau Datblygu

Amend Plan to include the site.

1 General Description
1.1 This LDP Representation relates to the potential inclusion of a new
site allocation for residential development in the Carmarthenshire
Revised Local Development Plan 2018 – 2033.
2 LDP Representation
2.1 The statement has been prepared by Ceri Davies BA Hons, Dip UP,
MRTPI, (Director of Ceri Davies Planning Ltd). The statement is
based on information provided by the client and other consultants.
All stated dimensions and distances are approximates and based on
the best information available at the time. Please refer to the
submission plans for detailed information.
2.2 The LDP Representation details include:
• 2
nd Deposit Revised LDP Representation Form
• Location & Site Plans
• Planning Statement
3 Client Details
3.1 The client is Mrs Molly John of Parc Gilfach, Llangynog, Carmarthen,
SA33 5DH.
4 The Site
4.1 The site consists of a rectangular shaped parcel of land which
currently forms part of a field enclosure. The parcel of land fronts
onto the C2081 and is located to the west of the settlement of
Llangynog.
4.2 The site lies on the northern flank of the C2081 and is located
between a number of road frontage dwellings at this stretch of
highway.
4
4.3 The site fronts directly onto the adjacent highway and is located in
close proximity to a predominantly residential area at the northwestern end of the settlement. The site lies approximately 300
metres west of the village settlement.
4.4 The proximity of the site to nearby dwellings along with its proximity
to the existing built form associated with the village of Llangynog is
illustrated on the map extract below (Figure i).
Figure i – Location Map of Llangynog
4.5 Whilst the site currently occupies an open countryside location, it
lies between a number of sporadic dwellings and within a
reasonable walking distance of the settlement development limits
associated with Llangynog. The actual proximity of the site to the
remainder of the village, which is predominantly residential in
nature, is clearly shown on the aerial photograph below (Figure ii).
5
Figure ii – Aerial Photograph
4.6 The site is essentially a greenfield site, nevertheless, given the
residential dwellings immediately east, along the C2081, it clearly
represents a site in close proximity to the edge of the village. Access
into the field enclosure is currently gained via existing field
entrances which come directly off the adjacent public highway.
5 The Development
5.1 The aim of the development advanced as part of this LDP
representation would be to provide a single residential plot,
fronting directly onto the adjacent highway.
5.2 Both the Location plan and Site plan below (Figures iii/iv) illustrate
the configuration of the site and extent of the site boundaries in
relation to the immediate environs and surrounding area.
Fig iii
The Site
6
5.3 The site plan extract below (Figure iv) illustrates the positioning of
the plot in relation to the adjacent built form. The scale of the plot
takes into full account the configuration of the site as well as the
approximate plot sizes of nearby residential properties.
Figure iv – Site Plan
6 Policy Context
6.1 A review of the planning policy context associated with the site and
the proposed development (at national and local level) is provided
within this section of the Statement.
National Planning Policy
6.2 Well-Being of Future Generations (Wales) Act (2015)
6.2.1 The Act places a duty upon public bodies to produce well-being
objectives that contribute to achieving a set of overarching wellbeing goals:
• A Prosperous Wales;
• A Resilient Wales;
• A Healthier Wales;
• A More Equal Wales;
• A Wales of Cohesive Communities;
• A Wales of Vibrant Culture and Thriving Welsh Language; and
• A Globally Responsible Wales.
7
6.2.2 Each public body is then required to take reasonable steps to meet
their objectives in the context of the principle of sustainable
development and whilst following a set of five ways of working.
6.2.3 The 'Resilient Wales' and 'Healthier Wales' goals are the key goals
that open space and greenspace, as part of the planning process will
contribute towards delivering.
6.3 Planning Policy Wales : Edition 11 (February 2021)
6.3.1 Planning Policy Wales (PPW) forms the overarching national
planning policy document for Wales and sets out the land use
planning policies of the Welsh Government. It is supplemented by a
suite of Technical Advice Notes (TANs), Welsh Government
Circulars, and policy clarification letters which together with PPW
provide the national planning policy framework for Wales. The main
objective of PPW is to promote place-making and sustainable forms
of development.
6.3.2 The primary objective of PPW is to ensure that the planning system
contributes towards the delivery of sustainable development and
improves the social, economic, environmental and cultural wellbeing of Wales, as required by the Planning (Wales) Act 2015,
the Well-being of Future Generations (Wales) Act 2015 and other
key legislation. PPW and National Development Framework (NDF)
set out how the planning system at a national. Regional and local
level can assist in delivering these requirements through strategic
Development Plans(SDPs) and Local development Plans (LDPs).
6.3.3 There are a number of key planning principles indicated within
Planning Policy Wales (PPW) to achieve the right development in
the right place.
6.3.4 Paragraph 1.18 emphasises that the legislation secures a
presumption in favour of sustainable development in accordance
with the development plan, unless material considerations indicate
otherwise. The principles of sustainable development are defined in
the Well-being of Future Generations Act.
6.3.5 Paragraph 1.22 of PPW states that up-to-date development plans
are the basis of the planning system and that these set the context
for rational and consistent decision making, where they have been
prepared in accordance with up to date national planning policies.
8
6.3.6 These key planning principles are set out with a view to achieve a
number of national sustainable placemaking outcomes, as
explained in paragraphs 2.15-2.20 and outlined in Figure 4. The
national sustainable placemaking outcomes are:
People and Places: Achieving Well-being Through Placemaking
• Growing our economy in a sustainable manner
• Making best use of resources
• Maximising environmental protection and limiting environmental
impact
• Creating and sustaining communities
• Facilitating accessible and healthy environments
6.3.7 Paragraph 2.17 states “In responding to the key principles for the
planning system, the creation of sustainable places and in
recognition of the need to contribute to the well-being of future
generations in Wales through placemaking, development plans and
development proposals must seek to deliver development that
address the national sustainable placemaking outcomes”.
6.3.8 Sustainable development forms a key consideration central to all
policies contained within Planning Policy Wales (PPW). Paragraph
1.2 states: “The primary objective of PPW is to ensure that the
planning system contributes towards the delivery of sustainable
development and improves the social, economic, environmental
and cultural well-being of Wales, as required by the Planning
(Wales) Act 2015, the Wellbeing of Future Generations (Wales) Act
2015 and other key legislation.”
6.3.9 Paragraph 2.27 sets out how to assess the sustainable benefits of
development: “Planning authorities should ensure that social,
economic, environmental and cultural benefits are considered in
the decision-making process and assessed in accordance with the
five ways of working to ensure a balanced assessment is carried out
to implement the Well-being of Future Generations Act and the
Sustainable Development Principle. There may be occasions when
one benefit of a development proposal or site allocation outweighs
others, and in such cases robust evidence should be presented to
support these decisions, whilst seeking to maximise contributions
against all the well-being goals.”
6.3.10 Paragraph 2.17 states that “in responding to the key principles for
the planning system, the creation of sustainable places and in
9
recognition of the need to contribute to the well-being of future
generations in Wales through placemaking, development plans and
development proposals must seek to deliver developments that
address the national sustainable placemaking outcomes.”
6.4 Future Wales: The National Plan 2040
6.4.1 Future Wales – The National Plan 2040 is Wales’ national
development framework which sets out the direction for
development in Wales to 2040. It is a development plan that sets
out a strategy for addressing key national priorities including
sustaining and developing a vibrant economy, achieving
decarbonisation and climate-resilience, developing strong
ecosystems and improving the health and wellbeing of our
communities.
6.4.2 The spatial strategy is a guiding framework which sets out the key
national policies that will guide and encourage development which
supports sustainable growth in both urban and rural areas across
Wales.
Policy 1 – Where Wales will grow
6.4.3 Policy 1 is the overarching policy which sets out where sustainable
growth will take place in Wales. Three National Growth Areas have
been established where there will 14 be growth in employment and
housing opportunities and investment in infrastructure. The
National Growth Areas are:
• Cardiff, Newport and the Valleys;
• Swansea Bat and Llanelli; and
• Wrexham and Deeside.
6.3.4 These National Growth Areas are complemented by Regional
Growth Areas, which will grow, develop and offer a variety of public
and commercial services at regional scale. There are Regional
Growth Areas in three regions:
• The South West;
• Mid Wales; and
• The North.
6.3.5 In addition to the above growth areas, there are a mix of smaller
towns and villages and large areas of countryside. The policy states
10
that ‘development in towns and villages in rural areas will support
local aspirations and need, complementing rather than competing
with efforts to grow our cities and towns.’
Local Planning Policy
6.4 The proximity of the site to the defined settlement development
limits for Llangynog in the current Local Development Plan 2006-
2021 (LDP) is illustrated in the map extract below, Figure (v).
Figure v – Proposals Map (LDP 2006-2021)

6.5 The proximity of the site to the defined settlement development
limits for Llangynog in the 2
nd Deposit Revised Carmarthenshire
Local Development Plan (LDP) is illustrated in the map extract
below, Figure (vi).
6.6 It is evident from the revised proposals map that the settlement
development limits have been altered and reconfigured to include
additional land at the edges of the settlement.
11
Figure vi – Proposals Map (Revised LDP 2018-2033)
12
7 Detailed Consideration
7.1 It is asserted that the site is deemed compatible with Strategic Policy
SP3 of the revised LDP which seeks to ensure the provision of
growth and development is directed to sustainable locations in
accordance with the spatial framework.
7.2 Given its siting in close proximity to the settlement of Llangynog,
which is classed as a Tier 3 Sustainable Village, and, its proximity to
nearby villages such as Bancyfelin and Llanybri, ISA Objective 1
(Sustainable Development) is satisfied in this instance.
7.3 As illustrated on the aforementioned site plan, the site can
potentially accommodate a single residential dwelling which would
be sited between a number of road frontage dwellings along this
part of the highway.
7.4 Whilst the site is not considered to be directly related to the
identified settlement of Llangynog, there are a number of dwellings
beyond the site to the north/west. As already highlighted, the site
represents a very sustainable location given its close proximity to
Llangynog. In addition, it is only 3 miles from the service centre of
St Clears and less than 5 miles from the market town of Carmarthen
ancffosfelen, which is classed as a Principal Centre in Strategic Policy
SP3 of the LDP.
7.5 Natural Resources Wales Development Advice Maps indicate that
the site does not lie within a Zone C1 or C2 flood area as defined by
the development advice maps referred to in Technical Advice Note
15, Development and Flood Risk (TAN 15), as illustrated in the DAM
extract below (Figure vii).
7.6 TAN15 states that new development should be directed away from
Zone C and towards zone A, otherwise to zone B, where river or
coastal flooding will be less of an issue. The site is not considered to
be at risk of flooding during at least the 1 in 1000 year event.
7.7 The development advice maps supplemented by sediment data,
held by the British Geological Survey (BGS), of historical flooding.
The maps adopt a precautionary principle and are based on the best
known information available at the time. It is noted that the NRW
flood maps show the site as being flood free during the Q100 event
and Q1000 event.
13
Figure vii – DAM Map (NRW)
7.8 The Flood Map for Planning Wales also indicates that the site is not
at risk from localised or surface water flooding; this is illustrated on
the FMfP extract below (Figure viii). The Flood Risk Map below
demonstrates that apart from a small section of the site frontage,
the site falls outside of Flood Zone 2 and Flood Zone 3, as such falls
within and an area deemed at low flood risk from rivers. The site will
not be affected during the 1 in 1000 fluvial (Q1000 event or 0.1%
event) and would also be flood free during the 1 in 100 (Q100) flood
event.
Figure viii – FMfP
7.9 The site does not fall within a C1 or C2 flood risk zone as delineated
by TAN15 DAM flood maps. Neither does it fall within a Flood Zone
2 or Flood Zone 3 as delineated by FMfP (Flood Map for Planning
The Site
The Site
14
Wales). As such, ISA Objective 4 (Climatic Factors) and ISA Objective
5 (Water) are both satisfied in this instance.
7.10 The site is not located within or immediately any of the following
designated sites:
• Sites of Special Scientific Interest (SSSI)
• Special Areas of Conservation (SAC)
• Special Protection Areas (SPA)
• National Nature Reserves (NNR)
• Local Nature Reserves (LNR)
• Common Land or registered village green
As such, ISA Objective 2 (Biodiversity) is satisfied in this instance.
7.11 The site is not located within or immediately adjacent to any
Scheduled Monuments. As such, ISA Objective 8 (Cultural Heritage
and Historic Environment) is satisfied in this instance.
7.12 The proposed development is deemed appropriate at this location
in that it would not impact on any core planning principles. The
proposed development would be sited between a number of
dispersed residential dwellings along this stretch of highway. As
such, it would not be extending beyond existing dwellings to the
west and it would not represent an inappropriate intrusion into the
open countryside. On that basis, it would not be seen as an
unacceptable extension of the built form into the rural landscape.
7.13 As already emphasised, given that the development would not
extend beyond existing dwellings along this highway, the proposal
would not lead to unacceptable ribbon development; it would not
be deemed tandem development. It would not lead to unacceptable
coalescence of settlements and given its siting immediately
adjacent to an existing residential property, it cannot be described
as unacceptable sporadic development or an unacceptable
extension to the settlement. In addition it would not result in the
loss of areas of public open space or formal recreational land. Given
the aforementioned, it is asserted that the development would not
be contrary to general planning principles.
7.14 The development would sit comfortably at this location without
having any detrimental impact whatsoever on the character or
setting of the settlement. Furthermore, the development would not
have any detrimental impact on any features of the settlement such
15
as landscapes, townscapes or buildings of importance as a result of
its scale, density and prominence. As such, ISA Objective 8 (Cultural
Heritage and Historic Environment) along with ISA Objective 9
(Landscape) are both satisfied in this instance.
7.15 The proposal would not involve the re-use of suitable previously
developed land, hence it is acknowledged that the land is a
greenfield site, as such, ISA Objective 7 (Soil) is not satisfied in this
instance.
7.16 The site has a road frontage boundary that fronts onto the C20818.
As such, the site is readily accessible from the existing public
highway. The site has an existing and established entrance with
adequate visibility splays, which allows direct access into the site
from the adjacent highway.
7.17 The C2081 is a relatively quiet road which serves primarily as access
from the A40 to the village of Llangynog. The map below (Figure ix)
illustrates the number of crashes in the immediate vicinity of the
site.
Figure ix (Source:Crashmap.co.uk)
7.18 Data obtained from Crashmap.co.uk confirms that in the last 20
years, there have been no slight, serious or fatal crash incidents
along this part of the C2081 classified road, this would suggest that
there are no highway issues relating to the site or the public road(s)
which serve the site.
7.19 The site lies in very close proximity to National Cycle Network Route
4, which is approximately 150 metres away. This proximity of the
16
site to this cycle route is illustrated on the Sustrans National Cycle
Network Map extract below (Figure x).
Figure x (Source:Sustrans)
7.20 The site is readily accessible to local bus services with the nearest
bus stop less than a 5 minute walk away. There’s a regular bus
service which links the village to the commercial centres of
Carmarthen and St Clears.
7.21 It is considered the site has suitable access to public transport as
well as identified active travel routes, as such, satisfies the following
ISA Objectives; ISA 3 (Air Quality), ISA 4 (Climatic Factors), ISA 6
(Material Assets), ISA 12 (Health & Well-being), ISA 13 (Education
s& Skills), ISA 15 (Social Fabric).
7.22 Given its location, the site lies immediately adjacent to an accessible
green space. In addition, the site is very accessible to an identified
recreation play area in the village of Llangynog. As such, it is
considered the site satisfies ISA Objective 12 (Health & Well-being)
and ISA Objective 15 (Social Fabric) .
7.23 The site is within a reasonable driving distance of a number of retail
and employment provisions; and services and facilities, that can be
found in Bancyfelin and Llangain. Other provisions / services /
facilities within a reasonable driving distance (approx. 10 minutes)
can be found in the service centre of St Clears and of course the
17
Principal Centre of Carmarthen, which has a wide range of
employment/retail provisions, services and facilities. Whilst the site
occupies a rural location, it represents a very sustainable location
given its close proximity to the service centre.
7.24 It is considered the site is within a reasonable distance of a number
of employment and retail provisions as well as other local services
and facilities, given its proximity to St Clears and Carmarthen. As
such, the site satisfies the following ISA Objectives; ISA 6 (Material
Assets), ISA 10 (Population), ISA 14 (Economy), ISA 15 (Social Fabric).
7.25 The site represents a sustainable location in terms of its proximity
to Bancyfelin Primary School. The site is also within a reasonable
distance of Ysgol Gyfyn Bro Myrddin and QE High secondary schools.
As such, ISA Objective 13 (Education & Skills) is satisfied in this
instance.
7.26 The site is not located within or adjacent to a mineral buffer zone,
as such, ISA Objective 6 (Material Assets) is satisfied in this instance.
The site is not located within a Mineral Safeguarding Area, as such,
ISA Objective 6 (Material Assets) is satisfied in this instance. The site
is not located within or immediately adjacent to an a Air Quality
Management Area (AQMA), as such, ISA Objective 3 (Air Quality) is
satisfied in this instance.
7.27 The site does not contain high carbon e.g. peatlands, as such, ISA
Objective 7 (Soil) is satisfied in this instance. The site does not
contain high quality agricultural land (grades 1,2 or 3A, as identified
within the Agricultural Land Classification Maps). As such, ISA
Objective 7 (Soil) is satisfied in this instance.
7.28 The site is not located within or immediately adjacent to any
Regionally Important Geological or Geomorphological Sites. As
such, ISA Objective 9 (Landscape) is satisfied in this instance.
7.29 The site is located within close proximity to a viable water
connection and is also located within close proximity to other viable
infrastructure requirements such as electricity and main sewer.
7.30 The site is not located within or adjacent to a phosphate sensitive
SAC catchment. A such, As such, the site satisfies the following ISA
Objectives; ISA 2 (Biodiversity), ISA 5 (Water) & ISA 7 (Soil).
18
7.31 The site by virtue of its scale and location, would not have the
potential to have a detrimental impact on the Welsh Language. As
such, ISA Objective 11 (Welsh Language) is satisfied in this instance.
7.32 The traffic movements associated with the development proposal
will be marginal and the development could be accommodated on
the highway network and will not have a detrimental impact on the
free flow of traffic due to the existing volumes of traffic using the
local highway network. There are no access or transport constraints
to prevent the development of the site for residential purposes.
7.33 It is asserted that owing to the nature of the development proposal
being advanced i.e. single dwelling, the development has due regard
to the existing built form and also character and appearance of the
surrounding area. Careful consideration has been given to the
proposed layout to ensure the relationship between the proposed
dwelling and existing development in close proximity is acceptable.
It is considered that a modestly sized residential dwelling would
conform with the character and appearance of the immediate area
in terms of siting and land use.
7.34 It is not disputed that the siting of a residential dwelling at this
location would introduce built form at an otherwise undeveloped
site. However, the dwelling would not represent a prominent or
conspicuous form of development. While the proposed
development would inevitably change the character of the site
itself, the proposed changes would not be to the extent that would
result in an unacceptable impact on the surrounding landscape.
7.35 The development would not be readily visible from the wider area;
and would represent a logical extension to the existing built form
along this highway. Given the aforementioned, it is considered that
any resulting development would not be inappropriate or
disproportionate in scale. It is on this basis that it is considered that
the proposal would represent a sensitive form of development,
commensurate with the existing built form, hence would not
adversely affect the spatial character of the village or surrounding
area.
7.36 The development would not have a significant impact on the
amenity of adjacent land uses, properties, residents or the
community. The impact on the amenity of nearby residents has
been fully considered and duly discounted, particularly given the
separation distance between the site and the nearest residential
properties.
19
7.37 Overall, the proposed development would satisfy PPW’s objective
of achieving sustainable development both by ensuring that the
local community has access to sufficient housing and affordable
options whilst also working to facilitate a modal shift to more
sustainable methods of transport and reducing car borne journeys.
8 Summary and Conclusion
8.1 This Planning Statement has been completed on behalf of Molly
John and provides planning support for the inclusion of additional
land in the revised Local Development Plan to accommodate
potential residential development at land adjacent to Eithinduon,
Llangynog.
8.2 It has been established that the principle of residential development
is compliant with both national and local policy and represents an
acceptable form of ‘infill’ development at this location. The
development would assist with the housing land supply situation in
the county.
8.3 While residential development at this location would inevitably
change the character of the site itself, the proposed changes would
not result in an unacceptable impact on the surrounding landscape
nor would they have an adverse impact on the existing neighbouring
development, highway network or local infrastructure.
8.4 In conclusion, it has been demonstrated that there are significant
material considerations weighing in favour of the inclusion of this
site for residential development in the upcoming revised local plan.

Include the site within the development limits.

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

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

Include the above site within the development limits for Saron in the Revised LDP.

In the Revised LDP Site Assessment Table, the candidate site (SR/149/003) that I
submitted was assessed as follows:
Stage 1 - Is it compatible against the location of future growth presented in the
Preferred Strategy? YES
Stage 2a – Initial Detailed Site Assessment ? NO
Stage 2b – Further Detailed Site Assessment? NO

The comments were - The site cannot accommodate 5 or more dwellings. It will not be included within the development limits as it has been identified as being at high risk of flooding within the SFCA.

COMMENT 1 - the character of the stream, and the land each side, has not been assessed.
I understand that CCC has flood regulations to adhere to, but there is no risk of
flooding here. It may be possible – I do not know - that, a long way back upstream, the stream (Nant Arw) runs between shallow banks or that, way downstream, once it has run beneath the road-bridge across Saron Road and continued off towards Tycroes the situation might be different. That does not mean, though,that there is a risk of flooding here.
I believe that the application should be assessed, at least, by someone coming out to actually get an accurate picture.
As Nant Arw comes alongside this site, there is an approx. 20’ wide bay, with 8’-10’ banks.On my side, there is a 10’ wide x 25’ long area beside the stream, covered in very low vegetation. This has never even been covered in water - let alone risen a further 8’-10’ to the top of the bank.
Nant Arw continues in an S-shape through the next section of the site, flanked by 7’-10’ banks and with a 10’-15’ bay area - again covered in very low vegetation. It has never even risen onto the grassy bay - let alone to the top of the 7’-10’ banks.
It continues along around another bend - with 8’-15’ banks and forming a massive 15’-18’ wide bay area.

It then comes along between myself and a neighbour’s back garden (62 Saron Rd – the road bends sharply, therefore his garden backs onto Nant Arw). Again, there is a huge 15’-20’ bay area covered in vegetation and the stream has never even risen onto the lowest level of this - let alone risen a further 8’-10’ to the garden.

Finally, it comes around to run behind 64 Saron Rd and drops away very steeply between the high banks to a very low point, where it runs beneath the road bridge. This steeply-falling character means that it takes away water extremely quickly, so that it never has a chance to rise more than about 2’ along the length of the boundary to the candidate site - quite apart from the fact that it is so easily contained by large bay areas and very high banks.

COMMENT 2 – there is planning and building precedent
There used to be a stone cottage on this piece of land (the candidate site). The cottage no longer exists. My elderly neighbour who lived at 64 Saron Road, before he died, described how there used to even be a rough roadway accessing this site, coming off the main road, by the bridge, past where there is now a garage and down along the rear of 64 into the site at 68. He described how the coal-cart used to deliver down there.
It seems illogical that a site that previously had a dwelling on it has now been deemed not possible to have a dwelling on it.
In addition, it seems wrong that the development boundary now cuts across my little back garden, cutting off the large back garden.

Comment 3 - number of dwellings
I did not, at any point, propose there could be room for 5+ dwellings.

I had been informed that the site could, in theory, add 2-4 dwellings to the housing stock in Saron.
However, I would be looking to provide just one bungalow in what would be a lovely, quiet situation, only enhancing the area – just as there used to be one cottage on the site. (Initially, this would be for myself, as I find it increasingly hard to use the stairs in the house, 68 Saron Rd, due to a stroke and other illnesses. There is a tarmac drive right to the site, providing access. I have lived in no. 68 for 26 years and am greatly attached to the village, with family and friends not too far away, and would be very sorry to have to give up the house and move away.
As there is precedent for a dwelling on the site, it seems logical that there could be one there, again, if the development boundary had not been re-drawn to cut across the middle of my garden, thus excluding the site – for no apparent reason – and without a site inspection.

**************

I would be grateful if CCC would, at least, arrange to view and assess the site in
order to make a sound decision and I believe this is a fair request.

Dim byd yn cael ei ddatgan.
___
Nothing stated.

Rhagair
• Mae MAP yn ymwybodol iawn bod angen datblygu er mwyn cadw pentrefi'n 'fyw' yn ogystal â diwallu'r angen yn lleol am gartrefi fforddiadwy a chartrefi o safon i'w rhentu.
Ond mae MAP yn pryderu hefyd am yr ardrawiadau a ddaw yn sgil rhai datblygiadau ac yn dadlau y dylai unrhyw ddatblygiad ym Mhorth-y-rhyd fod yn gydnaws â chymeriad y pentref ac wedi'i godi ar safle sy'n addas.
• Yn hytrach na thrafod cais yn ynysig mae MAP wastad yn ystyried oblygiadau'r pictiwr cyflawn yn enwedig ar adegau pan fo sawl datblygiad yn y pair yr un pryd.
• Mae MAP yn llwyr ymwybodol o'r dasg heriol sydd gan swyddogion Blaen-gynllunio i'w wneud i glustnodi safleoedd ar gyfer cyrraedd targedau.
• Sylweddolwn bod brîff wedi'i roi i Adrannau Blaen-gynllunio ddosbarthu cwota i bob pentref ac nid oes gennym wrthwynebiad i'r argymhelliad hwn o gwbwl. Mae'n ddisgwyliad hollol resymegol a theg fyddai'n arwain at ddosbarthu tai dros ardal eang yn hytrach na rhoi sêl bendith i ddatblygiad mawr fyddai fel ploryn mewn pentref. Popeth yn dda os oes tir addas i'w ddatblygu ar gael. Yn anffodus, mae pentref Porth-y-rhyd yn wahanol i'r rhelyw o bentrefi eraill yn y fro. Mae'n bentref ar lawr dyffryn, y rhan helaethaf ohono o fewn Parthau Llifogydd B ac C2 a phrif bibell yn tramwyo trwyddo. Am y rhesymau uchod a'r ffaith na chaniateir datblygiadau o fewn pellter penodol i'r bibell, tasg heriol yw clustnodi safle addas ym mhentref Porth-y-rhyd.
Dyma'r argymhellion ar gyfer Porth-y-rhyd :
1. Newid y ffin o flaen Tŷ Cynheidre i ddarparu safle ar gyfer ei ddatblygu.
2. Safle SuV20/h1 Tir sy'n ffinio â Fferm Llwyn Henri
3. Wernfraith Mae'r safle wedi'i ddad-ddyrannu o'r CDLl Diwygiedig 2018 – 2033 ond yn dal yn safle wedi'i ddyrannu yn y cynllun mabwysiedig CDLl 2018 sy'n dal mewn grym nes y'i disodlir gan y fersiwn hwn.
Mae'n debygol iawn y bydd cais yn cael ei gyflwyno ar gyfer 42 o dai. Os caiff ei ddatblygu yna bydd yn cael ei gategoreiddio fel Hap-safle.
Teimlir mai dyma'r amser gorau i dynnu sylw at faterion o bwys a phryder i drigolion Porth-y-rhyd. Mae'r adroddiad yn crynhoi'r holl ddadleuon, sylwadau a barn a leisiwyd ganddynt.
Gwerthfawrogir y cyfle i fod yn rhan o'r broses ymgynghori y tro hwn eto.

SYLWADAU'R TRIGOLION
1. NEWID FFIN Y PENTREF
Sylwyd bod newid ffin i gynnwys tir o flaen Tŷ Cynheidre yn cael ei argymell yn y fersiwn diwygiedig hwn.
Rydym ar ddeall nad oes manylion am yr hyn a fwriedir parthed datblygu'r cae ar yr adeg hon yn y broses. Nid oes manylion am y math o ddatblygiad, y nifer o dai na'r math o dai fyddai'n cael eu hadeiladu ar y tir. Efallai mai adeilad arall a fwriedir? Adeilad amaethyddol?
Tynnwyd sylw at y bibell sy'n croesi'r cae. Mae'r bibell yn fwy o faint na'r arferol felly holwyd a oes angen clustogfa o unrhyw fath i ddiogelu'r bibell? Os felly, beth yw mesuriadau'r glustogfa?
A yw'r ffaith bod pibell ddŵr yn croesi'r cae yn mynd i gael unrhyw effaith ar Hyfywedd ac Ymarferoldeb y safle?
Gan nad oes rhagor o wybodaeth ar gael ar hyn o bryd mae'n anodd ymateb yn deg i'r newid hwn. Yr unig opsiwn sydd gan MAP felly ar yr adeg hon yn y broses Ymgynghoriad yw GWRTHWYNEBU.

2. Safle SuV20/h1 Rhan o SR/139/002 a CA0894 * Heb ddod ar draws y cyfeirnod hwn o'r blaen.
Nodir yn y ddogfen drafft nad oes Hanes Cynllunio Perthnasol i'r safle arfaethedig hwn ond credwn ei bod yn holl bwysig edrych yn ôl ar hanes y safle hwn.
2012 -
Cynigiwyd y cae hwn a adwaenwyd fel ALT/159/006/N yn un o saith safle amgen ar gyfer CDLl 2006 - 2018. Roedd y safle yn 0.75 hectar gyda photensial i ddarparu 15 o dai.
Dyma ddyfarniad Ymgynghorydd Cynllunio Annibynnol bryd hynny:
In summary the site is linked but does not completely adjoin an existing cluster of development to the north of the core of the settlement. However, its development would represent the extension of this cluster further into the undeveloped adjoining open countryside. With no key services located at the cluster in question, this is not considered to be the most sustainable location for further development nor would it be in character with the general existing pattern of development of the village. In addition, the level of flood risk (which could be greater than perceived by the DAM) also seriously questions its deliverability.
Gw: Adroddiad am y Safleoedd Amgen yn Llanddarog a Phorth-y-rhyd. Mai 2012.(JCR)
Alternative Site Review Report for Llanddarog and Porth-y-rhyd May 2012.(JCR)

Cyflwynodd MAP ddadleuon ar nifer o'r pwyntiau cynllunio: dwysedd, newid cymeriad y pentref, ardrawiad negyddol ar dai a thrigolion cyfagos, problemau mynedfa a diogelwch, straen ar y gwasanaethau, cynnydd mewn cymudo, colli tir amaethyddol, colli cae draeniad naturiol a allai arwain at broblemau dwys dŵr glaw. Prif bryder MAP oedd y parthau llifogydd C2 a B a'r ffaith bod y brif beipen yn 'anghyfforddus o agos' at y safle.
Mae MAP yn dal i aros am ateb i gwestiwn a holwyd bryd hynny:
Faint o le sydd angen ei gadw'n glir i greu clustogfa ar gyfer gwarchod y bibell?
Cyflwynwyd tystiolaeth amrywiol yn cynnwys Deiseb a arwyddwyd gan dros 300 o bobl.
Cynhaliwyd Profion Methodoleg Asesu'r Safle, Asesiad Cynaliadwyedd, Asesiad Amgylcheddol Strategol a rhestrwyd nifer o resymau Cynllunio cadarn dros wrthod y safle a pheidio â'i gynnwys o fewn y Ffin Datblygu. Yn dilyn Gwrandawiad (HS19) gydag Arolygydd Annibynnol gwrthodwyd y safle:-
The site has been through the Site Assessment Methodology and the consideration of the site has been included within the Assessment of Site paper. It is considered that the site failed Phase 2b of that methodology for the following reasons:
• Development of the site would have a detrimental impact on the character and setting of the settlement or its features (including views and glimpses both into and out of the settlement.)
• In order for this development to take place, it would mean a considerable amount of new vehicular traffic on the minor road which leads to the site. Similar the Council's response during the UDP examination the carriageway would need to be widened to facilitate the development of the land for housing. As a result the land is both unnecessary and unsuitable for allocation.
Yn 2012 roedd y Cae Uchaf yn cael ei gynnig fel safle amgen ar wahân ALT/159/007/N.
Safle 1.2 hectar oedd hwn gyda photensial i ddarparu 24 o dai.
Gwrthodwyd y cae hwn hefyd oherwydd problemau parthed y mynediad ac fel y dywedodd yr Ymgynghorydd Cynllunio:
'In summary, its development would extend the aforesaid cluster in a manner that would alter the current pattern of development and be of a scale that would represent an unsympathetic encroachment into the open countryside. In addition, clear access constraints question its deliverability.'
Argymhellodd yr Adran Blaen-gynllunio wrthod y safle ar sail nifer o ddadleuon cynllunio a dyna oedd dyfarniad yr Arolygydd Annibynnol yn y Gwrandawiad. (Ebrill 2014)
Yn ddiweddarach, cadarnhaodd y Cyngor iddynt wrthod cynnwys y safle yn y CDLl 'yn seiliedig ar broses cadarn a rhesymegol'.
2018 - SR/159/002
Yn 2018 cyfunwyd y cae gwaelod (ALT 159/006/N sef SuV20/h1) a'r cae uchaf (ALT/159/007/N) i greu un safle – y cae gwaelod yn 0.7 h. a'r cae uchaf yn 1.1h. Roedd y cynllun ar gyfer 32 o dai. Argymhellwyd creu mynedfa newydd ar waelod yr hen heol - ymgais i ddatrys y problemau dwys mynediad a fu'n rhannol gyfrifol am iddo gael ei wrthod yn 2014. Golygai fwy na dyblu niferoedd y tai.
Gweler: Adroddiad i Gefnogi'r Safle Dyddiedig Gorffennaf 2018 (JCR)
Bu gwrthwynebiad chwyrn i'r cynllun a rhyddhad pan gafodd ei wrthod.

2020
Yn 2020 penderfynodd yr Adran Blaen-gynllunio ar y canlynol:
• Gwrthod cynnwys y cae uchaf i'r gogledd-ddwyrain fel rhan o'r safle.
• Hepgor ardal de-orllewinol y cae gwaelod sy'n ffinio â'r B4310.
• Argymell codi 6 o dai yn unig ar y cae.
* Ni fydd y nifer tai yn bendant nes y cyflwynir cais cynllunio manwl.
Roedd hepgor y cae uchaf yn gyfangwbl a'r ffaith na fyddai adeiladu ar dir o fewn y parthau llifogydd yn newyddion i'w groesawu. Rhaid cydnabod hefyd bod 6 o dai yn fwy synhwyrol fel datblygiad i bentref o faint Porth-y-rhyd.
Rhaid pwysleisio NAD yw MAP yn gwrthwynebu datblygu ond mae'n gwrthwynebu adeiladu ar safleoedd anaddas all arwain at ardrawiadau negyddol yn enwedig o ran problemau dŵr glaw a'r system garthffosiaeth.
Er yr addasiadau teimlai'r trigolion bod raid gwrthwynebu y tro hwn eto oblegid mai dyma'r union gae a ddyfarnwyd yn safle anaddas ar gyfer ei ddatblygu yn 2014 a bod y rhesymau dilys dros ei wrthod bryd hynny yn dal dŵr o hyd!

2023 - SuV20/h1
Ar hyn o bryd nid oes manylion pellach ar gael parthed cynllun y safle, y fynedfa arfaethedig, y math o gartrefi y bwriedir eu darparu nac ychwaith y nifer o dai. Yr unig beth a wneir yw cadarnhau bod lle i godi 5+ o dai. Gall hynny olygu 6? / 10? / 14?
Ymddengys bod yr Ymgeisydd wedi cyflwyno tystiolaeth parthed Hyfywedd ac Ymarferoldeb y safle (Gw. Pwynt 28 Hyfywedd ac Ymarferoldeb) ond nad yw'r wybodaeth honno ar gael i'r cyhoedd.
Mae teimlad cryf yn y pentref mai dyma'r union gae a wrthodwyd am resymau cynllunio cadarn yn y gorffennol. Mynegwyd pryder hefyd am yr amwysedd a'r ansicrwydd parthed nifer tai.
Cytunwyd felly i gyflwyno dadleuon a thystiolaeth cyn y dyddiad cau gan hyderu y cawn gyfle eto i ymateb yn llawnach i'r cynllun unwaith y bydd gwybodaeth bellach parthed SuV20/h1 ar gael i'r cyhoedd.
Cytunwyd bod MAP yn datgan GWRTHWYNEBIAD i gynnwys safle SuV20/h1 yn y CDLl Diwygiedig 2018 – 2033 ar sail y dadleuon canlynol..


1. Tresmasu i dir agored
Byddai datblygiad ar y safle hwn yn tresmasu i dir agored. Dyna un o'r rhesymau pam y'i gwrthodwyd yn 2014. Ni fyddai'n estyniad naturiol.

'Its development would represent the extension of this cluster further into the undeveloped adjoining open countryside'.
Dyfyniad o adroddiad Ymgynghorydd Cynllunio yn 2014
2. Colli tir amaethyddol
Yn yr adran sy'n ystyried Ystyriaethau Amgylcheddol noda bwynt rhif 21 nad yw'r safle'n cynnwys tir amaethyddol o ansawdd uchel (gradd 1,2,3a) ond prydera'r trigolion lleol am ddiflaniad cae arall ellid ei ddefnyddio i'r dyfodol fel cae amaethyddol. Mae cymaint o sôn yn dilyn Brexit am bwysigrwydd ffermio a chynhyrchu bwyd yn lleol.
Onid oes angen dwys ystyried pa ddewis sydd orau. Ai defnyddio'r cae ar gyfer adeiladu tai arno a choncritio tir draeniad pwysig neu'i ddiogelu ar gyfer ei amaethu am flynyddoedd i ddod a dal gafael mewn cae pwysig o ran ei rôl yn draenio dŵr glaw?

3. Colli ardal werdd
Mae cymaint o sôn am bwysigrwydd yr amgylchedd ac ardaloedd gwyrdd o ran lles ac iechyd trigolion ac mae Deddf Llesiant Cenedlaethau'r Dyfodol (Cymru) 2015 yn hyrwyddo gwarchod ein hamgylchedd hardd er lles trigolion.
Mae Cwm Gwendraeth yn hen ardal ddiwydiannol ac mae digon o safleoedd brown o fewn tafliad carreg i'r safle hwn. Pam na ellir datblygu'r rheiny cyn troi golygon at dir gwyrdd?
Beth am yr holl siopau ac adeiladau gwag yn ein trefi – Rhydaman, Llanelli a Chaerfyrddin?
Does bosib bod digon o safleoedd addas wedi'u dotio led led y Sir – safleoedd y gellid eu datblygu'n ddidrafferth a di-wrthwynebiad er mwyn darparu cartrefi yn gyflym i gwrdd â'r galw yn lleol.
Arwyddodd drigolion y pentref Ddeiseb yng Ngwanwyn 2019 yn gofyn yn garedig am i chwi wneud hynny.
4. Ardrawiad andwyol ar gartrefi sy'n ffinio
Dau fyngalo yn unig sydd yn ffinio â'r cae hwn. Mae'r tai eraill cyfagos yn dilyn patrwm llinellol o boptu'r hen heol. Nid colli golygfa, preifatrwydd neu olau yn unig all ddigwydd i drigolion y byngalos ond gall eu tai – eu heiddo a'u buddsoddiad - ddibrisio dros nos unwaith yr adeiledir tai yn union o'u blaenau.
Mae Polisi GP1 y CDLl yn pwysleisio pwysigrwydd ystyried a yw datblygiad yn gweddu i'r hyn sydd o'i gwmpas 'o ran graddfa ac uchder …. ac na ddylai gael effaith andwyol o ran ardrawiad gweledol, golau, preifatrwydd.'
'the importance that developments are compatible with their surroundings in terms of scale, height, massing, and general topography of locality.... must not adversely affect local amenity in terms of
visual impact, loss of light and privacy, disturbance and traffic movement....'
Mae’r safle hwn ar lechwedd gyda lefel y tir yn codi'n sylweddol o'r ffordd (B4310) islaw.
Oni fydd hyn yn achosi problemau? Tybed pa fath o dai a ganiateir ? Ai byngalos neu dai?
A fydd toi y tai newydd yn tyrru uwchben y cartrefi cyfagos?
Sylwer ar sylwadau'r Adran Gynllunio pan wrthodwyd y safle yn 2014.
• Development of the site would have a detrimental impact on the character and setting of the settlement or its features (including views and glimpses both into and out of the settlement.)
Beth sydd wedi newid?

5. Colli tir draeniad pwysig
Ni colli tir glas yn unig fyddai canlyniad datblygu'r cae hwn. Byddai concritio'r cae yn golygu colli cae draeniad naturiol pwysig arall a fyddai yn ei dro yn arwain at ddwysáu'r problemau dŵr glaw sy'n bodoli'n barod yn y rhan hon o'r pentref.
Ar hyn o bryd mae'r holl ddŵr glaw yn llifo o'r llethrau cyfagos i ddraenio yn y cae hwn.
Yn aml gwelir pyllau ar y cae a phan fydd yn ddyfrlawn llifa'r dŵr ar draws y B4310.
Hoffai MAP dynnu sylw at y ffaith nad argymell peidio ag adeiladu ar Barthau Llifogydd yn unig a wneir erbyn hyn ond i beidio ag adeiladu ar dir sy'n ffinio â Pharthau Llifogydd hefyd.
Mae'r neges yn glir. Dyma'r caeau pwysig o ran draeniad.

6. Parthau Llifogydd
Yn y Gwrandawiad (HS19) Ebrill 2014 gofynnodd yr Arolygydd Annibynnol i'r Awdurdod Cynllunio Lleol gadarnhau a oedd y cae hwn o fewn Parth Llifogydd B ac C2 fel yr honnai MAP ai peidio.
LPA to confirm whether alternative site ALT/159/006/N 'Land east of Llwyn Henry Farm' is within a TAN 15 DAM Flood Zone.
The map in Appendix 3 indicates the TAN 15 DAM Flood Zone maps for ALT/159/006/N
The southern and western sections of the site lie within Zone B, with a part of the site within Zone C2'
Does dim wedi newid. Mae rhan isaf y cae yn dal o fewn Parthu Llifogydd C2 a B.

7. Y Bibell Ddŵr
Gofid arall i'r trigolion yw bod y safle arfaethedig hwn yn 'anghyfforddus o agos' at y bibell sy'n cludo dŵr o Orsaf Bwmpio Nantgaredig i Felindre.
Cytunai'r Ymgynghorydd Cynllunio yn 2014 : 'the pipeline skirts the site'.
Rhaid cadw llain o dir yn glir o boptu'r bibell i greu clustogfa neu Goridor Diogelwch.
A oes unrhyw ran o safle SuV20/h1 yn tarfu ar y Coridor Diogelwch hwn?



8. Mynedfa:
Ceisiwyd datrys problemau'r fynedfa i'r safle drwy argymell creu agoriad newydd yn agos at y gyffordd ar waelod y lôn. Byddai hyn yn arbed i yrwyr y safle ddefnyddio'r lôn gul, un trac, 10 -12 troedfedd o led mewn mannau.
Nid yw'r lleoliad hwn yn addas o gwbwl ar gyfer mynedfa. Mae'r B4310 yn ffordd brysur yn enwedig yn ystod yr oriau brig ac nid yw'r gwelediad i'r ddau gyfeiriad yn dda o gwbwl. Ffordd gul droellog yw'r B4310 o Glenfryn draw at sgwar y pentref. Oherwydd nad oes gan y teras o dai ar y chwith garej na lle i barcio'r ceir does dim dewis ganddynt ond parcio ar y ffordd.
Rhaid ystyried hefyd yr holl drafnidiaeth ychwanegol fydd yn teithio heibio'r safle arfaethedig hwn pan fydd SWTRA yn cau cyffordd Foelgastell i'r ddau gyfeiriad a chyffordd Llanddarog i gyfeiriad Crosshands. Golyga hyn y bydd holl gymudwyr pentrefi Llanddarog, Llangyndeyrn, Cwm Mawr, Mynydd Cerrig, Foelgastell a Drefach yn defnyddio'r B4310 heibio'r safle hwn ddwywaith y dydd.
Dyma ddyfyniad o lythyr SWTRA :
'the closure of, or modifications to existing junctions will clearly result in traffic having to divert along minor roads and the implications of this needs to be fully taken into account.'
Bob tro y mae digwyddiad ar y ffordd ddeuol A40 rhwng Crosshands a Chaerfyrddin dargyfeirir y cerbydau drwy bentref Porth-y-rhyd. Digwydd hyn yn bur gyson.
Teimla'r trigolion nad yw'r ffaith bod modd cael mynedfa arall i'r cae yn datrys yr holl broblemau dwys eraill.

9. Problemau llifogydd a dŵr glaw.
Un o brif ofidiau'r trigolion yw'r problemau dŵr glaw a ddaw yn sgil datblygu safleoedd anaddas.
Mae hanesion am lifogydd yn y pentref yn dyddio'n ôl flynyddoedd lawer. Adroddodd un o'r trigolion, a oedd yn ei nawdegau ar y pryd, ei hatgofion am lifogydd pan oedd hi'n blentyn. Disgrifiodd yr holl ddŵr yn llifo fel afon o'r llethrau ac i mewn i'r tai.
Yn fuan wedi i'r gwaith ar ddatblygiad Clôs y Wennol ddechrau ffurfiodd llyn mawr o amgylch dau o fyngalos tai'r henoed – Cwm Cati – wedi glaw trwm. Wrth bwmpio'r dŵr dywedodd swyddog y Frigad Dân ei bod yn 'gwbl amlwg nad oes unman i'r dŵr fynd iddo.' Nid dyna'r unig dro. Galwodd yr henoed sawl gwaith dros y blynyddoedd am gymorth cymdogion i fopio, glanhau a diogelu eu heiddo.
Bob tro yn dilyn glaw trwm gwelir 'llynnoedd' yn ymddangos ar gaeau yn y pentref – y cae hwn a chae Wernfraith.
Adeiladwyd ar Barth Llifogydd ac ar gae draeniad allweddol bwysig yng nghanol y pentref. Concritiwyd y cae hwn oedd arfer delio â'r holl ddŵr a lifai o'r llechweddau gan ei atal rhag achosi problemau ar y sgwar ac i dai cyfagos dros y ffordd.
Rhyddhad yn wir oedd gweld bod yr Adran Blaen- gynllunio wedi gwrthod safle amgen arall yng nghalon y pentref yn 2019 – safle sydd ar barth llifogydd ac a fyddai wedi creu problemau dwys i'r cartrefi cyfagos.
Edrychwch ar y lluniau o'r llifogydd yn 2009 a'r casgliad o ffotograffau sydd yn yr atodiad.
Mae problemau dŵr glaw yn ardal y safle hwn ger Llwyn Henri. Llifa'r holl ddŵr glaw o'r bryn ac o ddatblygiad yr hen heol fach i'r cae gwaelod hwn sydd â rhan ohono o fewn parth llifogydd C2 a B. Mae'r cae yn aml yn ddyfrlawn a phwll yn ffurfio ar y gwaelod bob tro y cawn law trwm.
Gweler y ffotograff a dynnwyd ar Ebrill 11eg 2023 wedi pedair awr o law trwm.
Mae angen dwys ystyried i ble fydd yr holl ddŵr glaw yn llifo pe concritir y cae hwn?
Ychydig draw o'r safle hwn mae ardal arall gyda phroblemau dŵr glaw oherwydd i'r ceuffosydd a'r gwteri gael eu blocio pan godwyd y tai newydd.
Blerwch, diffyg cynllunio a diffyg monitro achosodd yr hunllef hwn i'r trigolion sy'n byw ger y datblygiad anorffenedig.
Mae gennym ffeil o ohebiaeth sy'n croniclo dros 20 mlynedd o ddiflastod trigolion.
Yng ngeiriau un o'r trigolion yn ddiweddar “er bod datblygwr yn honni y gall ddatrys problem dŵr glaw ar y safle nid dyna'r realiti a gadewir trigolion i ddelio â chanlyniadau ardrawiad negyddol y datblygiad ar eu liwt eu hunain! '

10. Y system garthffosiaeth
Bu cryn gyhoeddusrwydd yn ddiweddar am ollwng carthion heb eu trin i'r afonydd. Achosir y broblem oherwydd bod system dŵr glaw a'r system garthffosiaeth yn un system gyfunol.
Yn ôl ystadegau 2021 Dŵr Cymru digwyddodd hyn 77 gwaith yn yr Orsaf Bwmpio ym Mhontfaen. Nid yw'r ffigwr hwn yn cynnwys yr holl adegau y llifodd carthion yn 'ddamweiniol' ar gaeau a gerddi.
• Mae Pwmp Pontfaen sy'n pwmpio'r gwastraff i Orsaf Cwmisfael wedi dyddio ac er iddo gael ei uwchraddio flynyddoedd yn ôl nid yw'n ymdopi'n effeithiol. Nid yw hynny'n syndod gan na fwriadwyd i'r pwmp hwn ddelio â gwastraff cymaint yn fwy o dai yn ogystal â'r dŵr glaw ychwanegol sy'n llifo o gaeau a goncritiwyd.
• Adeiladwyd dros 40 o dai yn y pentref ers c 2000 - cynnydd o 43%.
• Adeiladwyd yr holl gartrefi ychwanegol ond ni fu unrhyw waith uwchraddio ar y system.
• Sut mae disgwyl i'r system ymdopi os bydd mwy o ddatblygu eto yn y pentref ac yn Llanddarog gan mai'r UN system sy'n gwasanaethu'r ddau bentref.
• Gwerthfawrogwn bod yr Adran Gynllunio yn ystyried pob cais yn unigol gan wneud hynny'n gwbwl deg a phroffesiynol ond mae'n hanfodol edrych ar y pictiwr llawn.
• Ar hyn o bryd mae cynllun i godi 42 o dai ar safle Wernfraith. Does dim amheuaeth y byddai caniatáu'r datblygiad hwn yn achosi ardrawiad trychinebus o ran y system garthffosiaeth a dŵr glaw yn y pentref.
• Clwstwr bach o dai a argymhellir ar y safle hwn a ger Tŷ Cynheidre (o bosib) OND mae'n bwysig rhifo'r tai i gyd i sylweddoli faint o straen ychwanegol fydd ar y system.
Porth-y-rhyd Wernfraith 42
SuV20/h1 6 6? 10? 14?
Cynheidre 5 ?
Llanddarog SuV19/h1 16 (0.903 hectar)
SuV19/h2 15 ( 0.863 hectar)

Hap safleoedd eraill - Amhosib dyfalu nifer!

Mae'r cyfanswm isaf posib yn 84 o dai ond gallai fod yn llawer uwch.
Dychmygwch y straen anferthol ar system ddiffygiol gyda'r holl dai ychwanegol.
Rhaid cofio bod Porth-y-rhyd wedi bod dan fygythiad yn 1963 pan oedd Corfforaeth Ddŵr Abertawe am foddi'r pentref. A oes perygl iddo gael ei foddi yn 2023!
Cysylltodd MAP â Dŵr Cymru a chadarnhawyd ganddynt bod angen uwchraddio systemau pentrefi cefn gwlad Cymru ac NA fydd cyllid i gyflawni'r gwaith yn y dyfodol agos o gwbwl.

Beth fydd y sefyllfa yn y cyfamser ?
Gwaethygu fydd y tywydd i'r dyfodol a byddwn ni, a'r cenedlaethau fydd yn ein dilyn yn gorfod delio gyda'r canlyniadau.
Bydd yn rhy hwyr i wyrdroi'r sefyllfa unwaith y bydd cae wedi diflannu dan goncrid.
Mae'r argymhellion gan yr arbenigwyr yn nodi'n glir ei bod yn annoeth adeiladu ar gaeau nesaf at barth llifogydd gan mai'r rhain yw'r caeau draenio holl bwysig.
Mae'r neges yn glir yn llythyr Julie James AS Y Gweinidog Newid Hinsawdd (Tachwedd 23ain 2021).

Given the immediate and serious challenges posed by the climate emergency, a ’business as usual’ approach ... is no longer a viable option. Taking meaningful action to address climate change will mean taking difficult and sometimes unpopular decisions. The planning system is at the forefront of responding to the climate emergency and ensuring the well-being of current and future generations.
The decisions local planning authorities make today will have a profound effect on how we adapt to climate change now and in the future. It is particularly important that we protect homes from flooding, when we know the devastating impact it can have on health and well-being.
Gwerthfawrogwn barodrwydd yr Ymgeisydd i addasu'r safle sawl gwaith.
Gwerthfawrogwn benderfyniadau'r Adran Blaen-gynllunio a'u hargymhellion diweddaraf.
OND
• er bod y cae uchaf wedi'i hepgor,
• er bod y safle wedi'i docio fel nad yw o fewn Parth Llifogydd
• ac er bod y nifer tai a argymhellir bellach yn fwy rhesymol (5+ ?)
mae'r pryder parthed problemau dŵr glaw a'r system garthffosiaeth yn gorbwyso hyn oll.

3. WERNFRAITH
Mae MAP wedi astudio'n fanwl gynlluniau'r datblygwyr POBOL Group a JONES (Henllan).
Bydd yr ardrawiad yn hunllefus.
Bwriedir GWRTHWYNEBU unwaith y cyflwyna'r datblygwyr gais cynllunio.
Yn y cyfamser ymatebodd trigolion y pentref i'r Ymgynghoriad Cyn Ymgeisio a drefnwyd gan yr Asiant Evans Banks. Cyflwynwyd 165 llythyr yn datgan GWRTHWYNEBIAD a nifer fawr o ebyst.
Bwriedir brwydro yn erbyn y datblygiad arfaethedig hwn.
• MAP is fully aware of the need for development to keep villages 'alive and viable' and create affordable homes and decent rental accomodation for local people. However, MAP is also committed to consider the impact of any proposed developments in Porth-y-rhyd and to ensure that any kind of development is in character with the village and is built on a site where there are no issues.
• Although MAP debates applications individually when they are submitted, it also looks at the broader picture and tries to determine the true impact all developments combined (if granted permission) would have on the village.
• MAP appreciates the challenge facing Forward Planning Officers to identify suitable sites for developments in order to reach targets set.
• MAP realises that Forward Planning has been given a brief to ensure that all villages are allocated a quota - a reasonable argument to be commended as it would avoid the danger of a massive 'carbuncle' of a development being forced on one village. In theory this is all well and good provided that there are suitable sites available. That unfortunately is not the case in Porth-y-rhyd – a village on the valley floor, within designated Flood Zones and with a pipeline traversing across it. It is, therefore, a far more challenging task.
These are the recommendations for Porth-y-rhyd:
• Change of boundary to include land near Tŷ Cynheidre for development.
• Site SuV20/h1 Land adjacent to Llwyn Henri
• Wernfraith Although this site has been de-allocated in the Revised LDP 2018 – 2033
it remains an allocated site in the current LDP 2006-2018. Our understanding is that when the Revised LDP will come into force Wernfraith will be classified as a Windfall Site.
Residents are of the opinion that this is the time to draw the attention of the Planning Authority to important issues and concerns. It was decided to compile a report on their behalf summarizing all concerns, comments and opinions expressed by the deadline of April 14th and hopefully have the opportunity to respond to specific details relating to SuV20/h1 and the change of boundary once information is available to the public.
MAP appreciates the opportunity to participate in this Consultation.
1. CHANGE OF BOUNDARY
It appears that a change of boundary is recommended to include a field below Tŷ Cynheidre.
We understand that no information is available at this stage in the process as to the kind of development intended, the number of dwellings or the type of homes. It is therefore difficult to respond to this change in boundary without having all the relevant details. Perhaps a different type of building will be proposed – a farm building?
MAP's attention was drawn to the fact that another pipeline crosses this field.
This pipeline is wider than the usual water supply pipes. Is there a need to ensure a buffer zone on either side of the pipeline? If so, what measurements would that entail?
Will the fact that a pipeline crosses this field affect the Viability and Deliverability?
As there is no information available at this stage in the process to enable MAP to respond in a fair and proffesional way there is only one option open to us which is to OPPOSE.

2. Candidate Site SuV20/h1 Part of SR/139/002
CA0894*Have not seen this refernce before.
It is stated in the draft that there is no Relevant Planning History to this proposed site but the residents believe it is vitally important to look back on the planning history of this site.
2012
This field referred to as ALT/159/006/N was submitted at the Deposit LDP stage as one of seven alternative sites to be included in the Local Development Plan 2006 - 2018 (adopted in 2014). The site was 0.75 hectares with a proposed potential capacity for 15 units.
This was the conclusion reached at that time by an independent Planning Consultant:
In summary the site is linked but does not completely adjoin an existing cluster of development to the north of the core of the settlement. However, its development would represent the extension of this cluster further into the undeveloped adjoining open countryside. With no key services located at the cluster in question, this is not considered to be the most sustainable location for further development nor would it be in character with the general existing pattern of development of the village. In addition, the level of flood risk (which could be greater than perceived by the DAM) also seriously questions its deliverability.
See: Alternative Site Review Report for Llanddarog and Porth-y-rhyd May 2012.
The action group MAP acted on behalf of the residents presenting evidence on planning issues such as density, the change in character of the village, negative impact on neighbouring properties, problems with the then proposed entrance and increase in vehicles using the narrow winding old lane, strain on services, school had reached it's capacity, increase in commuting, loss of agricultural land, and loss of drainage field that would lead to more problems relating to surface water.
MAP's main concern was the fact that areas of the field were within flood zones B and C2 and that the main pipeline from Nantgaredig to Felindre skirted the site.
MAP still awaits an answer to a question asked in 2012:
What area needs to be kept clear of developments in order to create a buffer zone or corridor of protection?
Evidence was presented at the time including a Petition signed by over 300 residents (95% of the residents).
Site Assessment Methodology, Sustainability Appraisal / Strategic Environmental Assessment etc were carried out and following a robust and rational site selection process the boundary was drawn to exclude the site. At the Hearing it was confirmed by the LPA that alternative site ALT 159/006/N 'Land east of Llwyn Henry' is within a TAN 15 DAM Flood Zone as argued by MAP. Following the Hearing chaired by an Independent Planning Inspector the site was turned down.
The site has been through the Site Assessment Methodology and the consideration of the site has been included within the Assessment of Site paper. It is considered that the site failed Phase 2b of that methodology for the following reasons:
• Development of the site would have a detrimental impact on the character and setting of the settlement or its features (including views and glimpses both into and out of the settlement.)
• In order for this development to take place, it would mean a considerable amount of new vehicular traffic on the minor road which leads to the site. Similar the Council's response during the UDP examination the carriageway would need to be widened to facilitate the development of the land for housing. As a result the land is both unnecessary and unsuitable for allocation.

The upper field was also submitted for consideration as an alternative site in 2012 - ALT/159/007/N. The site size of 1.2 hectares had a potential capacity for 24+ units.
The Independent Planning Consultant stated: 'In summary, its development would extend the aforesaid cluster in a manner that would alter the current pattern of development and be of a scale that would represent an unsympathetic encroachment into the open countryside. In addition, clear access constraints question its deliverability.'
Forward Planning Dept. proposed the site be refused based on numerous planning issues and that was also the decision of the Independent planning Inspector at the Hearing. (April 2014)
The Council confirmed that the site had been refused based on a robust and rational process.
2018 – SR/159/002
A new proposal was submitted in 2018 – 2019 . The lower field (ALT/ 159/006/N now SuV20/h1 ) was combined with the upper field (ALT/159/007/N) to create one large site – the lower field of 0.7 hectares and the larger upper field of 1.1 h. The proposal was for 32 houses. Access would now be at the bottom of the lane, thus avoiding the use of existing narrow lane. It also meant that the number of dwellings would more than double.
See: Candidate Site Supporting Statement dated July 2018 (JCR)
There was overwhelming opposition to this proposal and relief when it was REFUSED.

2020
• The north-eastern upper field enclosure is no longer included. in the Revised Local Development Plan 2028 - 2033
• A portion of the lower south - western field that extends along the B4310 has also been excluded. Only part of the lower field is allocated for housing.
• Forward-Planning Dept. has identified 6 dwellings as being indicative for the site.
(Exact housing figures for the site will be determined when a detailed planning application is submitted).
The fact that the upper field has been excluded is welcomed as is the fact that there will be no building on the flood zone areas. A development of six dwellings also seems far more reasonable in a village the size of Porth-y-rhyd. We must stress that MAP is not opposed to developments but is concerned when developments are proposed on unsuitable sites where the impact will have a detrimental effect especially regarding surface water and sewerage problems.
However, as this is the exact same field that was categorically refused in 2014 following a Public Hearing and regarded as an unsuitable site for development, MAP objected.
2023 - SuV20/h1
It is impossible for MAP to respond as we would have wished to SuV20/h1 as no detailed information is available to date regarding the plan of the site, the proposed entrance, the type of houses or the exact number of dwellings. It is confirmed that the site can accommodate 5 or more dwellings. What exactly does this mean? 6 / 10 / or more?
The Applicant has provided 'sufficient evidence to show that the development is deliverable and financially viable' (See Point 28. Viability and Deliverability) and that was all the requirement at the current stage in the process. This document is not in the public domain.
It was agreed that MAP would compile a report summarizing the arguments and evidence of the residents and respond again to the detailed information available once that is in the public domain. .
1. Encroaching onto open land.
This proposed development would be encroaching onto open land. It is not a 'natural extension'.
That was one of the main arguments in 2014 that led to it's refusal.
'Its development would represent the extension of this cluster further into the undeveloped adjoining open countryside'.
Report of the Planning Consultant in 2014 (JCR)
2. Loss of agricultural land
In the section dealing with Environmental Consideration it is stated in Point 20 that the site does not contain high quality agricultural land (Grade 1, 2 or 3a.) but the local residents fear that yet another agricultural field will disappear under concrete – a field that would be of agricultural value to future generations. There has been so much discussion since Brexit of the importance of farming and producing food locally. Should we not pause to consider which is the best option? To build on this field and lose a drainage field in the process or to preserve it for agricultural use for years to come and retain an important natural surface water drainage field?
3. Green areas
There is so much talk today about the importance of green areas to support people's physical and mental well-being. Well-being of Future Gebnerations (Wales) Act 2015 .
Should we not be protecting our green areas?
The Gwendraeth Valley was an industrial area and there is an abundance of brown-field sites within a short distance from this site which could accommodate the council's targets for housing. Why not concentrate on all these available areas before setting sights on the green fields? Not only is it unsustainable but it's unacceptable that agricultural land is sacrificed.
What about all those empty buildings and shops in Rhydaman, Llanelli and Caerfyrddin?
Surely there are more suitable options for development across Carmarthenshire as a whole.
4. Impact on neighbouring properties
This proposed development would have an impact on the neighbouring properties.
Policy GP1 / LDP stresses the importance that a development is compatible to its surroundings:
'the importance that developments are compatible with their surroundings in terms of scale, height, massing, and general topography of locality.... must not adversely affect local amenity in terms of visual impact, loss of light and privacy, disturbance and traffic movement....'
This particular field is on a steep slope – the land rising suddenly from the level of the B4310 road below. What type of dwellings will be built there? Will they be bungalows or three storey houses? Will the roofs of the new properties tower over existing properties?
• Development of the site would have a detrimental impact on the character and setting of the settlement or its features (including views and glimpses both into and out of the settlement.)
Forward Planning statement in 2014.
Two bungalows are sited adjacent to the site. Those living there are presently able to enjoy the view of the open countryside. However, it would not only be a case of loss of vista, privacy and light. There is a possibility that the propoerties could devalue overnight once dwellings are built directly in front of them.
All other properties on the old lane are of a linear pattern.
5. Loss of drainage field
Not only will developing this field be a loss of agricultural land but also mean that yet another important drainage field will be lost. This would exacerbate existing serious problems with surface water in this part of the village.
All surface water flows from the developed area along the old lane and from surrounding area into this field. Very often large pools will appear on the field and once the field is saturated that surface water floods onto the B4310. Enclosed photos show this field after 4 hours of heavy rainfal on April 11th 2023.
The recommendation today is to refrain from developing not only sites within Flood Zones but land adjacent to Flood Zones.
The message is loud and clear. These fields are the important natural drainage areas and without them surface water problems will intensify.
We undrstand that a developer is expected to deal with surface water on site but from past experiences in this village that is definitely not the case!
6. Flood Zones
At the Public Hearing (HS19) in April 2014 the Independent Planning Inspector requested that the Planning Authority confirm whether or not this particular field was within designated Flood Zones
as MAP argued.
LPA to confirm whether alternative site ALT/159/006/N 'Land east of Llwyn Henry Farm' is within a TAN 15 DAM Flood Zone. This was done.
The map in Appendix 3 indicates the TAN 15 DAM Flood Zone maps for ALT/159/006/N
The southern and western sections of the site lie within Zone B, with a part of the site within Zone C2.
Nothing has changed. The lower section of the field lies within designated Flood Zones B and C2.
Although this portion of the field is not included in this revised site, MAP hopes that consideration will be given to the argument presented.

7. Pipeline
MAP is concerned about the proximity of this proposed allocation to the strategic main water pipeline from Nantgaredig Pumping Station to Felindre Water Treatment Works.
The Planning Consultant agreed back in 2014 that the pipeline 'skirts the site'.
MAP is aware that there should be a defined area of land on either side of the pipeline as a Buffer Zone or Corridor of Protection to protect the pipeline from damage.
Is it your opinion that the development of site SuV20/h1 would impinge on said Protection Corridor?

8. Proposed Entrance:
Minor adjustments have been made to try and overcome some of the hurdles faced last time e.g. a new entrance proposed. It is now suggested that an opening be created to access the proposed site from the initial section of the lane near the junction thus avoiding site vehicles utilising the narrow one-track lane which is 10 – 12 feet in places.
This plan may have solved the issue regarding said lane to some extent, however, proposing a new access at this location raises further concerns.
A different entrance definitely does not erase all the other serious issues.
This is not an ideal location for an entrance. The B4310 is a busy road especially twice daily during peak times and visibility in both directions is poor.
The road from Glenfryn/ Derwen Deg towards the village square is narrow and winding with a sharp bend to cross the bridge. As a terrace of properties to the right hand side of the road towards the A40 junction have no off road parking spaces or garages, there is no option but to park cars on the roadside.
It is important to be aware of other possible developments (as well as housing developments) that would have an impact on traffic in the future. Should funding become available SWTRA will review Phase 2 of the plan to close or adapt junctions between Crosshands and Caerfyrddin – the Foelgastell Junction in both directions and the Llanddarog Junction from the direction of Caerfyrddin - resulting in a massive increase in vehicles travelling through Porth-y-rhyd. All commuters from the neighbouring villages of Llanddarog, Llangyndeyrn, Cwm Mawr, Mynydd Cerrig, Foelgastell and Drefach will be using the B4310.
This is a quotation from a letter received from SWTRA.
'the closure of, or modifications to existing junctions will clearly result in traffic having to divert along minor roads and the implications of this needs to be fully taken into account.'
It is also important to keep in mind that each time an incident occurs on the A40 between Caerfyrddin and Crosshands traffic is diverted through Porth-y-rhyd. This occurs often.

9. Surface water problems
One of the main concerns regarding developments on unsuitable sites in the village is the impact on existing surface water problems.
There is a history of flooding in the village dating back many years. An elderly resident in her 90's used to describe an incident that happened in her childhood . Her recollection was vivid - of a river flowing towards the square and how the residents in those properties had to open the back door for the water to flow through as there was no other option.
Shortly after work began on the development known as Clôs y Wennol a 'lake' appeared surrounding two of the dwellings in Cwm Cati. The Fire Brigade officer exclaimed that there was absolutely nowhere the water could flow to. That was not the only time problems occurred as a result of surface water. Elderly residents in Cwm Cati had to call on their neighbours on numerous occassions following heavy rainfall to help them mop up, clean and protect their properties.
Some fields are prone to ponding and large ponds appear following heavy rainfall on both this field and the Wernfraith proposed site.
Enclosed photos testify to the result of building on a Flood Zone and on a natural drainage field in the centre of the village. Other photos show the flooding that happened in 2009.
Residents are so fortunate that another site on a flood plain was turned down as an allocation for the LDP in 2019 as serious issues would have ensued. It was such a relief!
Surface water problems have existed in the area of this proposed development for years. All surface water flows from the sloped area behind and from the development along the old lane into this field which lies within flood zones. A portion to the southern side lies within zone C2 and an extensive area within zone B. Anecdotal evidence will confirm that this field is often saturated with a pond forming in the lower corner.
Where will all the surface water flow to once the field is under concrete?
Further along the road by the A40 junction to Caerfyrddin there is another development that has caused severe surface water problems. This nightmare for neighbouring householders came as the result of negligence and the lack of planning and monitoring as culverts and ditches were blocked and built on.
MAP has a file of correspondence recording twenty years of misery as this development which began in the 1990's is still ongoing and has not been adopted by the County Council.
As one resident noted : “It is true that a developer will claim to be able to sort out the problems on site but, as history has proven, in reality this is not the case and residents are left to their own devices to cope with the negative impact and consequences”
10. Sewerage System
There has been a lot of publicity recently about discharging raw sewerage into rivers. According to Welsh Water data this occurred at Pontfaen 77 times in 2021. This number of course does not include those incidences when raw sewerage seeped accidentally onto fields and gardens as seen in the photos.
• The Pump at Pontfaen which pumps the waste to the treatment plant in Cwmisfael is unable to cope with the extra capacity although it was upgraded a few years ago. That is not surprising when one considers the increase in dwellings and the increase in volume of surface water flowing off concreted fields post developments.
• 40 dwellings have been built in the village since c.2000 – an increase of 43%

• All these properties were built but no upgraded work carried out to improve the system.
• How is the system expected to cope with further developments in Porth-y-rhyd and Llanddarog?
It must be remembered that both villages are on the same system!
• We appreciate that the Planning Authority carefully assess each individual application. However, it is felt that there is a need to view the wider picture.
• There is a plan to devlop a site of 42 dwellings at Wernfraith - an alternative site allocated in the LDP 2006 – 2018. If this plan goes ahead there will be catastrophic impacts to the village in terms of the sewerage system and surface water.
• A small cluster of dwellings is now proposed for site SuV20/h1 and possibly for a site near Tŷ Cynheidre. It's imperative to count all proposed numbers of dwellings in order to fully appreciate the strain that will be on the present system – a system that is NOT coping at present.
Porth-y-rhyd Wernfraith 42
SuV20/h1 6 6? 10? 14?
Cynheidre 5 ?
Llanddarog SuV19/h1 16 (0.903 hectar)
SuV19/h2 15 ( 0.863 hectar)

The total (minimum) is 84 dwellings but could be far higher.
Imagine the strain on an already ineffective system.
And what about Windfall Sites? It's imopossible to even hazard a guess at this stage!
Do you recall Porth-y-rhyd under threat sixty years ago back in 1963 when the Swansea Water Corporation wanted to drown the village?
Is there not a danger that the village will be drowned in 2023?
MAP contacted Welsh Water and as anticipated it was confirmed that upgrading work was required in most Welsh rural areas. Unfortunately there is no funding to carry out the improvements in the near future.
What will the situation be in the meantime?
Weather patterns are changing and will become more extreme in the future. We and future generations will have to cope with the impact. It will be too late to change things once fields have disappeared under concrete.
The experts are in agreement that it is unwise to build on land adjacent to Flood Zones as these are of vital importance with drainage.
The message is crystal clear in the letter sent to all Planning Authorities in Wales by Julie James AS
(November 23rd 2021)
Given the immediate and serious challenges posed by the climate emergency, a ’business as usual’ approach ... is no longer a viable option. Taking meaningful action to address climate change will mean taking difficult and sometimes unpopular decisions. The planning system is at the forefront of responding to the climate emergency and ensuring the well-being of current and future generations.
The decisions local planning authorities make today will have a profound effect on how we adapt to climate change now and in the future. It is particularly important that we protect homes from flooding, when we know the devastating impact it can have on health and well-being.
MAP appreciates the willingness of the Applicant to change and adapt plans.
MAP appreciates the decisions and recommendations made by Forward Planning officers .

HOWEVER
• despite the fact that the upper field has now been excluded

despite the fact that an attempt has been made to avoid the designated flood zone area
• and although the number of dwellings now proposed is more in line with what would be expected in a village the residents' concerns regarding the surface water and sewerage system OUTWEIGH the above ammendments.
• There is a strong feeling of opposition in the village as this field has been REFUSED in the past based on sound planning arguments and following a robust and rational site selection process.
• It was agreed that MAP register an OBJECTION to the inclusion of candidate site SuV20/h1 and kindly request that a representative / representatives be present at a Hearing Session during the Public Examination when this proposed site is discussed.

3. WERNFRAITH
In the Additional Comments section it is stated: This site is one of few opportunities in Porth-y-rhyd for new development, particularly with the de-allocation of the existing LDP allocation.
It was so ironic to read this knowing full well that an application will shortly be submitted by the developers POBOL Group and Jones Henllan to build 42 dwellings on this site at Wernfraith Farm.
MAP has scrutinized the developers' plans for this site.
The impact will be horrendous!
In the meantime the residents participated in the Pre Application Consultation (PAC).
165 letters of OBJECTION were handed in to Evans Banks in addition to several emails sent.
It is the intention of the residents to OPPOSE this proposed development once a planning application is submitted.

No change to Plan.

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/04/019, 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, one being the frontage part of a grazing field off the
northern side of Aberlash Road.
We have noted that this northern part of the Candidate Site is included within the Second
draft settlement limits. Our clients are very satisfied with this inclusion and wish to express
their support and gratitude to the Council.
Figure 1 below provides an indication of the location of the Candidate Site, which is edged in
red.

Figure 1 – Location plan of Candidate Site

As a result of the above Council assessment, Figure 2 presents an extract of the Second
Deposit LDP Proposals Map for Ammanford, which clearly now identifies part of our Clients’
land as within the defined development limits.

Figure 1 – Extract of Proposals Map for Aberlash part of Ammanford with site
included within settlement limits as shown by a red arrow

Our clients wholeheartedly welcome the decision of the Authority to concur with the
representation previously made in relation to our Clients land and fully support their
decision to include the land within the development limits.
Existing properties that are brought to market on this road are quickly sold to be lived in, not
investment properties. All present properties are owner-occupied. The site will be brought to
market quickly to an existing and increasing waiting list of self-build families, assisting to meet housing needs in this part of Ammanford and all within the proposed LDP Plan period.

They intend enacting upon this inclusion shortly after the LDP is formally adopted, by means of a formal planning application, and thereafter commence implementation of the development of the site within the early years of the Plan Period.

Include site within the development limits for Brechfa.

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

Our client owns a residential property with accompanying small enclosure of land set at the
north-western approaches to the village of Brechfa. The land falls to a roadside boundary
with the C2104 Brechfa to Llanllwni Road. It is marked by the presence of a pair of a
residential dwelling, together with a garden shed set alongside with its own independent
vehicular access onto the C road. Our Client is seeking inclusion of a very modest parcel of
land for future residential development within the defined settlement limits of Brechfa within
the Replacement Local Development Plan.
This formal Representation relates solely to the non-inclusion of ALL of this established 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 Brechfa, 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 Brechfa, 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 plan
Response to Council’s Setting of Brechfa Draft Settlement Limits

1.0 Integration of Site with Character and Setting of Locality

1.1 The Representation Site consists of a generally level section of land, equipped with a residential dwelling as well as a garden shed. The Second Draft of the Replacement LDP has repeated the settlement limits currently adopted in 2014 and imposed settlement limits carving adjacent to this section of land, so the consequence is that the dwelling and adjoining land is set outside the settlement limits. There appears to be no logic or rationale reasoning for the segregation of the property in this manner, and the Representation merely seeks that part of our client’s land 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 compacted about the site vehicular access

1.2 The Representation Site is shown in the following photographs where the distinction of the location of the settlement limits is shown.
Representation Site
Photo 1 – Representation Site entrence off C2104
Photo 2 – Site entrance along with current Settlement Limits
Consistency within Settlement Limits

1.3 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 Brechfa, the Authority has been found to be inconsistent.

1.4 Figure 4 below is an extract of the Deposit LDP Proposals Maps for an area just to the southeast of the Candidate Site at the northern edge of Brechfa.
Figure 4 – Extract of Deposit LDP Proposals Map for Brechfa

1.5 As can be seen, an undeveloped parcel of land has been included within the development limits of Brechfa at this location as part of the Deposit LDP, almost directly opposite the Representation Site.

1.6 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.

2.0 Conclusion
2.1 In conclusion, the Brechfa locality has numerous examples of minor additions to the extremities of defined settlement limits, where opportunities for new sensitive infilling development can be achieved such as the already developed curtilage of Llwyn yr Aderyn. 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 Brechfa be realigned to include the Representation Site, in the Proposals Map of the adopted Local Development Plan.

Change to the Plan

Dear Planning Manager

I wish to register my opposition to the inclusion of SuV20/h1 on the revised LDP 2018 - 2033 and the change of boundary to include the field near Ty Cynheidre. I’m worried that the inclusion of both of these will eventually result in further development within the village and will have a detrimental impact on the valley floor and will further impact the current sewerage and surface water problems. Problems that we have experienced directly over the past 10 years.

The expected planning at Wernfraith Farm is also of great concern to us as our property is currently effected by the surface water on this field and the inclusion on any development will surely add to this problem unless the current drainage system is fully re-planned and re-routed and not just ‘updated’. These concerns have been highlighted to our councillor Ann Davies and to Ben Kathrens B.Sc (Hons) MCIWEM MInstLM - Flood Defence and Coastal Protection Manager in the past when the flood water has reached a level that has flooded around/inside our property. Details of which should be on your flooding database.

Dim byd yn cael ei ddatgan

Nothing stated

Annwyl Syr/Fadam,

Parthed: Safle SuV20/h1 (tir ger fferm Llwyn Henri)
Ysgrifennaf i gofrestru fy ngwrthwynebiad llwyr i gynnwys Safle SuV20/h1 yng Nghynllun Datblygu Lleol Diwygiedig Sir Gaerfyrddin 2018 – 2033. Roedd gwrthwynebiad chwyrn i’r safle hwn gan bobl y pentref nôl yn 2014. Bryd hynny cafodd y safle ei wrthod yn unfrydol gan Ymgynghorydd Cynllunio Annibynnol ac Arolygydd Cynllunio Annibynnol. Cafodd y safle hefyd ei wrthod gan Adain Blaen-gynllunio’r Cyngor ar ôl gwneud ‘asesiadau trylwyr’. Roedd y pryderon ynghylch y safle ar y pryd yn cynnwys y ffaith bod rhan o’r safle ar barth llifogydd a bod yna eisoes broblemau’n ymwneud â llif dŵr glaw ar y safle a chapasiti’r system garthffosiaeth. Nid yw’r problemau hyn wedi diflannu nac wedi newid. Po fwyaf o ddatblygu fydd yn digwydd yn y pentref, y mwyaf o straen fydd ar y seilwaith carthffosiaeth a dŵr glaw, sydd eisoes yn methu ymdopi. Yn 2021 cafodd carthion heb eu trin eu rhyddhau i afon Gwendraeth Fach 77 o weithiau, gan Dŵr Cymru, o’r bibell ym Mhontfaen – dim ond un enghraifft yw hyn. Mae’r safle ger Llwyn Henri yn aml yn ddirlawn ar ôl glaw trwm ac yn aml gwelir llynnoedd o ddŵr yn sefyll arno, ac mae dŵr hefyd yn llifo i lawr y ffordd fach sy’n mynd heibio i fynedfa Llwyn Henri (hen heol Gelli-ddu Fach) – byddai unrhyw ddatblygu ar y safle hwn yn golygu colli amsugfa ddŵr naturiol a gwerthfawr a byddai’n anochel yn arwain at waethygu problemau llifogydd a charthffosiaeth yn y pentref.

Yn ychwanegol, mae’r map yn dangos newid yn ffin y pentref ar hyd ffordd y B4310. Yn ôl y map mae ffin ddeheuol y pentref wedi symud ymhellach i’r De – lle’r oedd yn gorffen gydag Awelfryn mae’r map newydd yn cynnwys darn o’r cae o flaen Tŷ Cynheidre. Beth yw’r rheswm am hyn a beth allai’r goblygiadau fod o ran y math o ddatblygu a allai gael ei ganiatáu yma?

Yn gywir

Remove land from development limits.

I wish to register my opposition to change the current LDP to include the field near Ty Cynheidre. There are significant potential developments being proposed elsewhere in the village, some near to this location. These are developments that would have big implications on the village in terms of population and capacity of current infrastructure to name some obvious examples. All current applications should be kept within the existing LDP so that the longer term picture and the effect on the village can be properly considered.

Ceri Brown, Ty Cynheidre

Include site within the development limits for Llandybie.

This representation objects to the exclusion of this site from the development limits for Llandybie. Its inclusion would not lead to additional environmental pressure, but instead will foster sustainable growth and allow for a wider choice of housing type within this high tier settlement and key service centre. Its development 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.
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 more sustainable and deliverable than those other sites that have been allocated within Llandybie.
The inclusion of this land within revised development limits would be fully supported.

Derwydd to be afforded development limits and the site in question to be included within those limits.

This representation objects to the removal of development limits for Derwydd.
Appropriate development within Derwydd 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.
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 revised development limits would be fully supported.

Amend Plan to include the site in development limits

1. Site Location:
Please identify the extent of the site on an Ordnance Survey Plan (Red Outline)

2. Site Area, please choose (m2 / acres / hectares):
0.33 hectares

3. Is the site within, immediately adjoining, or closely linked to an identified
settlement in the current LDP? Please identify the settlement:
Yes ☒ No ☐
Which Settlement? Nant y Bai, Rhandirmwyn SC29

4. What is the current use of the site? Grazing

5. What is the proposed use of the site? Residential

6. Are there any buildings on the site? Yes ☐ No ☒
If yes, are the buildings in use or are they vacant? Please provide details:
Click here to enter text.
Deliverability of the Site Site Ownership

7. Does the proposer own the site? Yes

8. If the proposer does not own the site, has the landowner been contacted
and agreed to any potential development of the site?
N/a

9. Does the proposer own or control any adjoining land? Yes No☐
If yes, please explain the interest and identify the extent on an Ordnance Survey
Plan (Blue Outline).
No
We do own and Farm Troedrhiwrhuddwen. SA20 0PL
10. Is your site an allocation in the current LDP? Yes ☐No☒

11. If so, has progress been made to develop the site? Yes ☐ No☐
If yes, please provide details of the progress.
If no, please provide details as to why it is not being developed.
NA
Residential Use

12. Are you proposing a residential use on the site? If so, is it for a housing
allocation (5+ units) or for small scale development (less than 5 units)?
Small scale development includes amendments to the development limits.
☐Housing Allocation ☒Small Scale ☐Not Applicable
Housing Development

13. If the site is to be considered as a housing allocation (5+ units), please
provide supporting information as set out in the guidance note.
Click here to enter text.
Deliverability Viability of the Site

14. For small scale developments (sites of less than 5 units), please provide
supporting information as set out in the guidance note.
We propose a single dwelling to promote the rural indigenous farming community.
The site proposed sits between Nant Y Bai Mill, and a modern Bungalow on one side and the
traditional cottage known as The Wern on the other.
The Wern marks the present boundary of Nant Y Bai settlement and are a stone’s throw apart. The
proposed area for proposed development is in effect in-fill between the two properties.
There is access to the highway along a straight stretch of road with good visibility. Mains electricity is
supplied to neighbouring properties; indeed a transformer is located in the field. Mains water runs
along the road. There is hedging around the site which would be unaffected unless planning or
highways requirements necessitate it
It is essentially low-grade grazing of limited agricultural value, of a type which proliferates in the
area.
The proposal would be low impact and respectful of its surroundings. The single dwelling would be
erected within the area marked in red in accordance and by agreement with planners.
Our proposal would sit between existing residential property and would have little or no
environmental impact.
It is essentially between the last Nant Y Bai buildings so would not extend the settlement, though if
preferred the dwelling could be positioned closer to Tegfan.
Schools Shops and general employment can be found in Llandovery, though part of our intention is
to provide an affordable home that allows our family to continue farming.
As we are a Welsh first language family such our proposal supports and will have a positive effect on
the local use of Welsh
It will have little or zero effect on the sand or gravel present.
Non-residential Land Use

15. For non-residential candidate sites, please identify how the site will be
developed for its intended use.
Click here to enter text.

16. When would you intend to bring the site forward for development?
Short Term (2021- 2024)
☒Medium Term (2024-2029)
☐xLong Term (2029-2033)
Infrastructure and Utilities Accessibility

17. What would be the land value of the site if the proposed use was
achievable?
*Only to be answered if an allocation is being proposed.
Click here to enter text.

18. Is the site accessible from the existing public (adopted) highway?
☒Yes ☐No

19. Does the site have a suitable access point with adequate visibility?
☒Yes ☐No
If yes, please identify how this is achieved.
If no, how would the access point and visibility be achieved?
There is lengthy frontage to the highway and an existing access. The proposed single would not
significantly increase traffic movements.

20. Is the site located within a flood risk zone as identified in the TAN 1
Development Advice Maps?
☒ Zone A ☐ Zone B ☐ Zone C1 ☐ Zone C2
*proposers should note that the Local Planning Authority may request further
information or evidence during the candidate site process where consultation
responses highlight issues relating to tidal, fluvial, surface water flooding and the
impacts of climate change.

21. Is the site previously developed (brownfield) or is it a greenfield site?
☐ Previously Developed ☒ Greenfield

22. Does the site have an available water connection?
☒ Yes No
If no, describe how these facilities will be obtained.
Mains water runs past the site, and neighbouring properties benefit from mains water.

23. Does the site have a suitable sewerage connection?
☐ Yes ☒ No
If yes, what would be the method of foul sewage disposal?
Click here to enter text.
If no, describe how these facilities will be obtained.
A septic tank or similar would be installed as part of the construction

24. Are there any historic or archaeological features or designations affecting
the site?
☐ Yes ☒ No
If yes, please provide details:
Environment, Infrastructure Other Considerations and Utilities

25. Are there any landscape or ecological features / designations or protected
species which may be impacted upon by the development of the site? Please
refer to the checklist for developers on Nature Conservation and Biodiversity.
☐ Yes ☒ No
If yes, please provide details:
The site has been used for sheep grazing for some years it is unlikely that any species of interest
would have survived - but in any event the bulk of the field would remain with its existing use

26. Are there any trees or hedgerows which may be impacted upon by the
proposed development?
☒ Yes ☐ No
If yes, please provide details:
There is hedgerow along the frontage and around the border of the field. The border of the field will
remain untouched whilst the frontage will only be altered as required by planners / highways if
necessary. There is an existing entrance to the highway.

27. If you have any further comments to make in support of the proposed site,
please set them out here and/or securely append additional sheets or other
evidence:
This land has been in my family’s ownership for many years, it was inherited from my mother by my
brother, and in turn following his passing has come to us. We are an indigenous farming family
settled in the Valley for hundreds of years, probably descended from Tom Sion Cati.
We now have 4 children and would like them to have the option to stay in the valley, indeed we
hope at least one of them will take over the farm, but for that to happen they will need somewhere
to live, with their own families. Neighbouring properties are unsuitable and unlikely to come to open
market.
Whilst property exists locally it is usually sold as retirement homes for incomers or second homes.
Accordingly, prices are too high for young people on a farming income to buy. Development here
would enable our children to live in a house that offers them the chance & space to live a working
rural lifestyle. We suggest that this fulfils the policy(s) supporting the sustainability of farming, rural
& Welsh communities.
We would like to erect a single modest home for a young farming family.
It would sit between existing housing and conform with the established building line, within the area
marked in red. The size and position of an appropriate home will be subject to planning advice and
input, We only intend building one house for to enable at least one of our children to continue living
securely in the village I was born and raised in, following in the steps of my father, grandparents and
their predecessors.

Include site within the Development Limits for Ammanford, under policy SD1.

This representation objects to the exclusion of this site from the development
limits for Ammanford. Its inclusion would not lead to additional environmental
pressure, but instead will provide the opportunity for an attractive, appropriate
development, thereby fostering sustainable growth and allowing a wider choice
of housing type within this Tier 1 Principal Centre. Its development 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 short term delivery is assured.
It is considered that this site is both sustainable and readily deliverable and
offers a valuable development option within this Tier 1 Principal Centre.
The inclusion of this land within revised development limits would be fully supported.

Include site within the Plan.

This representation objects to the removal of development limits for Heol Ddu. Appropriate development within Heol Ddu 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 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 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 deliverable and offers a valuable development option within the village.
The inclusion of this land within revised development limits would be fully supported.

Include Plan within the development limits for Pontyberem, under policy SD1.

This representation objects to the exclusion of this site from the development limits for Pontyberem. Its inclusion 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 2 Service Centre. Its development 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.
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 deliverable and offers a valuable development option within this Tier 2 Service Centre which otherwise has only one proposed allocation (SeC11/h1). The representation site is also within more convenient proximity to the settlement centre.
The inclusion of this land within revised development limits would be fully supported.

Amend plan to include site within limits

SECOND REVISED LOCAL DEVELOPMENT PLAN 2018 – 2033: CYNGOR SIR GÂR
Response to Public Consultation April 2023
RE. DEVELOPMENT LIMITS – LLANSTEFFAN VILLAGE SETTLEMENT

I am writing to request that the development limits for Llansteffan Village be extended to include the properties on Mill Pond Lane – SA33 5LG.
There are 6 traditional, long standing residential dwellings on Mill Pond Lane: Rose Cottage, I Millpond Cottage, 2 Millpond Cottage, Min yr Afon, Nantyfelin and Mullach Mor. They are separated from the properties on Old School Road, which are within the development limits, by a small stream.
Mill Pond Lane is an integral part of the village settlement, and there is no reasonable justification for its exclusion from the development limits. In fact it appears to be oversight.
A sensible “rounding-off” of boundaries has been applied to other areas of the village, which I support wholeheartedly.
Diolch yn fawr iawn,

Include site SR/004/038 within the Plan.

This representation objects to the exclusion of this site from the development limits for Ammanford. Its inclusion 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 1 Principal Centre. Its development 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.
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 deliverable and offers a valuable development option within this Tier 1 Principal Centre.
The inclusion of this land within revised development limits would be fully supported.

Amend Plan to include the site

This representation objects to the removal of development limits for Mynyddcerrig. Appropriate development within Mynyddcerrig 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 revised development limits would be fully supported.

Amend Plan to include limits

This representation objects to the removal of development limits for Mynyddcerrig. Appropriate development within Mynyddcerrig 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 revised development limits would be fully supported.

Amend Plan to include the site

Please see Supporting Statement. The vast majority of the site is allocated for residential development (Ref: SC16/h1) in the current LDP, with a non committal allocation for 10 dwellings. Efforts have been made to deliver this allocation, with this portion of the site having gained outline planning permission for the erection of 13 dwellings and associated infrastructure work (Ref: PL/00629), and a planning application was submitted in March 2023 concerning full planning permission for the construction of an access road in order to serve those dwellings (Ref: PL/05573). This proves that an attempt has been made to deliver the only housing allocation in the current LDP for Llanybri, therefore there is no logical reason for it`s removal within the deposit plan. It is the applicant’s intention to bring the site forward via the submission of reserved matters for the housing itself in the near future. The candidate site to the immediate south of the housing allocation is a natural extension of this. At present, this portion of the land contains old agricultural structures that are now in a state of disrepair.

Supporting statement (not including appendices):

1 Introduction
1.1 This supporting statement document for the Second Deposit Revised Local Development Plan for Carmarthenshire has been prepared in relation to an existing LDP allocation (SC16/h1 land adjacent to Parc Y Delyn) and adjacent candidate site (SR/108/001 land at Maes Y Meillion) in Llanybri, Carmarthenshire (E: 233989, N: 212783). It is submitted on behalf of Mr David Rhodri Davies.
1.2 The existing LDP allocation (SC16/h1) reproduced in Appendix 1 is proposed to be de-allocated. The reason specified in the Site Assessment Table is “the site has been allocated since the UDP without any indication of delivery”. It will be shown in this statement that an Outline Planning application for 13 dwellings was registered on the 20th October, 2020 and subsequently approved by the LPA on the 5th August, 2022 under planning reference PL/00629. The applicant has also subsequently submitted a full planning application for the access in order to bring forward such facilitating works and this has been registered by the LPA and pending determination under planning reference PL/05573. The above show a clear intent by the landowner to bring forward this existing housing allocation, and thus it should not be de-allocated.
1.3 The southern part of the site was previously submitted as a candidate site in 2018 in Appendix 2 (Ref: SR/108/001), but this has not been included within the Deposit Plan. The reason specified in the Site Assessment table is “site access taken through existing housing allocation which is to be taken out. Therefore this is not taken forward”. The reason is specific to the access aspect through the existing housing allocation, which should be retained as a housing allocation for the reasons mentioned above. The housing layout and access design is such that it facilitates the delivery of candidate site SR/108/001. The candidate site at present contains old agricultural buildings that are now in a state of disrepair.
1.4 In summary, this submission concerns the entire Maes y Meillion site including both the existing LDP allocation (SC16/h1) and adjacent candidate site (SR/108/001), and the applicant wishes for them to be brought within the settlement limits of Llanybri in order to comply with LDP Policy SD1 (Development Limits), along with being included as a housing allocation in order to accord with Policy HOM1 (Housing Allocation).
1.5 The site is situated in the village of Llanybri, lying to the north west of Llansteffan and situated south of Llangynnog. The site lies roughly 8.5 miles away from Carmarthen town centre where there are a host of amenities and services including supermarkets, a university and leisure centre.
1.6 This submission will demonstrate that the overall site in question, both the existing housing allocation (SC16/h1) and candidate site (SR/108/001) ought to be included within the settlement boundary of Llanybri in the Deposit LDP. Efforts have been made to deliver the existing allocation, with this portion of the site having gained outline planning permission for the erection of 13 dwellings and associated infrastructure work (Ref: PL/00629), and a planning application was submitted in March 2023 concerning full planning permission for the construction of an access road in order to serve those dwellings (Ref: PL/05573). This proves that an attempt has been made to deliver the only housing allocation in the current LDP for Llanybri, therefore there is no logical reason for its removal within the deposit plan. It is the applicant’s intention to bring the site forward via the submission of reserved matters for the housing itself in the near future. The candidate site SR/108/001 is a logical extension of this existing housing allocation and will be accessed through it. Appendix 3 and 4 provide copies of the outline layout plan
and approval respectively, whilst Appendix 5 and 6 provide copies of the proposed access plan and registration document.
1.7 In terms of the content of the submission Section 2 of this report 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 discusses the site’s general location and provides a brief description of the application site and its immediate surroundings.
2.2 Llanybri is categorised as a Tier 3 sustainable village situated in the unitary authority of Carmarthenshire. It is located approximately 8.5 miles to the south west of the county town of Carmarthen and approximately 6.5 miles to the south east of St Clears. The highway that runs to the northwest of the site has a 30mph speed limit on entry to the village.
2.3 The majority of the entire site comprises agricultural grazing land, along with the farm holding of Maes Y Meillion. Access to the farm itself can be gained from the county road to the north via the concreted farm road on the eastern side, leading onto a hard-standing area in the south-eastern corner. There is a small agricultural building, which is now redundant and partially collapsed, in this corner of the field. Agricultural grassland and hedgerow forms the north eastern and north western boundaries. The north east of the site is bound by an access track associated with Maes Y Meillion and to the south east by Maes Y Meillion grounds within the ownership of the applicant. The south western boundary is formed by the curtilage of properties within Parc Y Delyn whereas the north western boundary is formed by the main highway running through Llanybri. Lying to the south of the site is an off-road track and children`s play area.
2.4 The village of Llanybri contains few services and facilities. Those located within the village includes places of worship and a public house. Llansteffan located nearby the site contains a few more facilities including Llansteffan primary school, a convenience shop and amenities associated with the coastal location, place of worship and community hall. The nearest service centre to the site is St. Clears which features a wider range of services and facilities including:
• Surgery;
• Ysgol Griffith Jones (Primary);
• St. Clears Leisure Centre;
• Supermarket;
• Convenience Shops; and
• Takeaways
2.5 The site can be reached via the B4312 from Carmarthen, that passes through Llangain, whereas those travelling from a westerly/northerly direction will cross the busy A40 dual carriageway near Bancyfelin and head along a country lane that leads to the centre of Llanybri. The road situated to the northwest of the site currently has a 30mph speed limit as users enter the village of Llanybri. The nearest national cycle route is route no.4 which is a long distance course between London and Fishguard. The nearest point of access for potential users is by Gul Wales: Littlemoor, approximately three miles from the site. Ger y Marbell bus stop is a short walk from the site and is serviced by the 227 bus. This service commences at Ger y Marbell and terminates at Carmarthen, with 6 services heading in that direction, and another six terminating at Ger y Marbell from Carmarthen on the return journey. In terms of trains, the nearest station is in Carmarthen town centre, nine miles away. The station is situated on the West Wales Line and is predominantly served by Transport for Wales who run services to destinations further west, along with journeys to Swansea, Cardiff Central and Manchester Piccadilly. In addition to this, Great Western Railway operate one service daily to London in both directions, and additional services are provided by the operator on Sundays.
2.6 In terms of ecology, a Preliminary Ecological Appraisal was conducted in July 2020 at the site to accompany outline application PL/00629. As it was conducted over two years ago, an updated appraisal of the site was required to accompany the full application for the access. Consequently, Habitat Matters conducted an Ecological Appraisal of the site during December 2022. The Preliminary Ecological summarised that “The site conditions remain unchanged from the July 2020 proposal apart from the derelict building which has now lost all sections of the roof. The recommendations for ecological mitigation and enhancement remain as before”. A section of hedge requires removal to facilitate the proposed access and will be translocated as shown in Appendix 7. In terms of ecological enhancements, the report suggests that these will be delivered as part of the wider residential development, comprising of suitable landscape planting and bird/bat boxes.
2.7 Intrado were instructed to produce a drainage strategy for the access proposal that is provided in Appendix 8. The engineering layout highlights how drainage aspects have been incorporated into the construction of the access road. These include:
1. 2.75m minimum width (half of highway) to be constructed from permeable asphalt to be lined with permeable geotextile membrane to facilitate infiltration to groundwater network below;
2. Kerb drainage to be installed at low point in highway to drain surface water runoff to infiltration basin during storm events in excess of 1:100yr to avoid highway flooding; and
3. ACO swale inlet (or similar approved product) to be installed in infiltration basin.
In addition to this, the Kerbing Layout notes that the kerb drainage will be implemented at a low point of the highway in order to convey runoff to bioretention section during an extreme storm occurrence greater than 1:100 years. The access and subsequent housing will be subject of separate SAB approval also.
3 Comments on Planning Policy
3.1 Paragraph 9.3 of the Revised Draft LDP correctly recognises the role that smaller settlements within Carmarthenshire have in delivering local and sustainable growth. This is further expanded upon in Paragraph 9.16 which again correctly recognises that by supporting growth of a proportionate scale in such areas, a positive contribution can be made towards the long term sustainability and cohesiveness of rural communities and the rural economy.
3.2 It is clear that there is a reliance on larger sites within rural areas which can be difficult to deliver. Due to issues around deliverability, this has impacted the resilience of housing land supply, with these larger sites not delivering the dwellings promised. A different approach is warranted in certain areas of Carmarthenshire, with a large proportion of the County being rural in nature. Within Tier 3 settlements (Sustainable Villages), sites that are small in scale but are easily deliverable ought to be favoured as they will be able to meet the housing need in an easy manner whilst not hampering the character of the area.
3.3 The Moving Rural Carmarthenshire Forward Report conducted in 2019 stated that in order to make rural areas attractive for younger people adequate housing needed to be provided to ensure that they could remain within their local communities. The report stated that a shift was required from depending on large housing developments to focusing more on smaller scale residential developments that would address housing requirements in rural settlements. A survey produced during the report revealed only 15% of respondents were happy with the housing provided within their rural area.
3.4 It is imperative that a sustainable and proportionate amount of housing growth is allowed in rural areas of Carmarthenshire during the plan period. The lack of such housing at present has unfortunately resulted in younger individuals departing rural areas, looking for housing and work in urban areas which is having a detrimental impact upon the resilience of rural areas
3.5 In terms of policy within the deposit LDP, the two key policies are SD1 (Development Limits) and HOM1 (Housing Allocations). In terms of Policy SD1, the site discussed in this statement ought to be included within the settlement boundary of Llanybri as it would represent a natural extension of the settlement. There is no logical reason for moving the site outside settlement limits within the deposit plan, as the site currently lies within limits and efforts have been made to develop the site, with two planning applications having recently been submitted, with the outline approved confirming acceptance of housing on the site
in principle. The candidate site to the south of the existing housing allocation is a logical extension of this and can be delivered via the facilitating infrastructure being developed for the existing housing allocation. The candidate site element includes old agricultural buildings, many of which are now in a state of disrepair.
3.6 In respect of Policy HOM1, there is proof that the site will be delivered as the site has gained outline planning permission for 13 dwellings and associated works, and a full application has recently been submitted for the access works. Welsh Government advice is to remove sites which have proved to be undeliverable, however this is not the case in respect of this land. The land owner is keen to progress development of the site with the submission of reserved matters for the housing itself in the near future. Furthermore, as a result of pulling the site out as a housing allocation within the deposit plan, Llanybri does not have any sites allocated for residential development. Retaining the existing housing allocation and including the logical extension to it will address this deficiency.
3.7 Having considered the last two paragraphs, there is no logical reason for altering the settlement limit of Llanybri, as this reduces opportunity for residential development and sustainable growth within a sustainable village. Furthermore, there is no reason for it to be removed as a housing allocation as there is intent to develop the site as illustrated by the submission of recent applications. Within the current plan, the site accords with LDP policy, and nothing suggests that the site could not do this when it comes to the deposit plan, were it to lie within settlement limits and be allocated for residential development. The candidate site to the south of the existing housing allocation is a logical extension to it and can be facilitated via the access being proposed.
4 Appraisal
4.1 This section examines the characteristics and features of the site in question.
Availability of Previously Developed Land
4.2 The site is not brownfield land but is well-connected to the current settlement pattern of Llanybri and its development for residential purposes represents a logical area for development and inclusion within the settlement boundary, at this location. Lying west is the Parc Y Delyn residential development which has a similar number of residential dwellings to what has gained outline planning permission at the Maes Y Meillion site, along with a comparable layout. Several services and facilities are available in the nearby towns of St Clears and Carmarthen that are a short drive away from the site.
4.3 In order to achieve a sufficient range and choice of housing land opportunities, there will be a need to consider sites which help achieve resilience in rural settings, with this site capable of being delivered in the short to medium term. The existing housing allocation element of the site can offer up to 13 residential units as illustrated in Appendix 3, whilst a few more can be delivered on the candidate site to the south. This will make a positive contribution to housing land supply,
Accessibility
4.4 Although the land consists of undeveloped agricultural grazing land which does not benefit from formal access, the site can be entered via the wider Maes Y Meillion grounds. The proposed access application submitted in March 2023 to the LPA will lie thirty yards south west of the current access. This development will offer access to a highway that runs centrally to the site with the 13 properties situated on either side as shown in Appendix 5. It will provide access to the parking areas, along with a turning head to enable vehicles to enter and leave the site in a forward gear. A section of hedge requires removal to facilitate the proposed access and will be translocated, whereas ecological enhancements as part of the proposed access will comprise suitable landscape planting and bird/bat boxes.
4.5 In terms of facilities, these are limited to a public house, chapel and playground within Llanybri. A range of services and facilities are provided in nearby Carmarthen, that can be reached via a bus service that calls at the nearby Ger Y Marbell bus stop. In terms of trains, the nearest station lies in Carmarthen, where services run to several destinations across south Wales, along with Manchester Piccadilly and London Paddington. The nearest cycle route is no 4 which is a long-distance route between London and Fishguard running via Reading, Bristol, Swansea, Tenby and St. Davids.
4.6 It is evident that drivers travel along the main road running through the village in a sensible manner as residents have to walk along the side of the road due to no footway being constructed. Such an arrangement is not uncommon in rural settlements of Carmarthenshire and underlines that the development is occurring within a pedestrian safe environment.
Land Ownership
4.7 The land to which this submission refers is within the joint-ownership of the Site Promoter – Mr David Rhodri Davies. The landowner is fully committed to bringing forward the development of the site.
Capacity of Infrastructure
Utilities
4.8 All utilities are readily available within the proximity of the site. 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
4.9 The site is not affected by a flood risk area (which would prevent vulnerable forms of development such as housing), and it is considered that foul water will connect with the existing mains sewer. Drainage aspects have been clearly incorporated into the proposed access, with further detail provided in Appendix 8.
Access
4.10 Achieving sufficient widths and visibility at the site’s proposed access point will be achieved, with some of the hedge at the northern end of the site translocated. The development will provide the necessary pedestrian and cyclist infrastructure within the site to encourage residents to walk and cycle, with 2m wide footways included on both sides of the carriageway, and a potential path may be built in future in order to connect the site with the playground that lies south of the site. A S.106 completed in relation to the outline permission also secured a £25,000 contribution towards improving pedestrian facilities in the village of Llanybri.
Impact on the Community/Welsh Language
4.11 It is not considered that the development of the site for housing will have any significant adverse impact upon the Welsh language or any local communities. The nearest primary school is situated in Llansteffan, which is a Welsh medium school therefore enabling development of the site could increase the number of Welsh speakers in the village. A S.106 was completed in relation to the outline which secured 30% affordable housing and a financial contribution towards local education facilities.
Physical and Environmental Constraints
Ecology
4.12 The Preliminary Ecological Appraisal in Appendix 7 summarised that appropriate ecological enhancements will be provided a part of the access application, and the hedge removed to facilitate the access will be translocated.
Visual Impact
4.13 Overall it is considered that the proposal would not have any significant adverse impact upon the visual amenities of the area. Separation distances, to prevent any adverse or overbearing impacts, between proposed dwellings and existing dwellings can easily be provided.
Coalescence of settlements
4.14 Development on the site would not result in the coalescence of settlements. Development of the site would result in the retention of the existing housing allocation in Llanybri and a marginal extension of Llanybri`s development limits within the deposit plan, which makes sense considering a similar scale residential development lies west of the site. Furthermore, part of the site currently lies within settlement limits, and is allocated for residential development within the adopted plan. It has been proven in this submission that the existing allocation is deliverable with progress already made at significant expense to
the applicant by successfully obtaining outline planning permission and submitting a full application to bring forward access facilitating works.
Flood Risk
4.15 The site is not identified in the TAN 15 Development Advice Maps as being at risk from flooding.
Site Contamination
4.16 In terms of ground conditions there are no known constraints that prevent the development of the site for residential uses.
Compatibility with Neighbouring Uses
4.17 It is anticipated that all of the proposed dwellings would respond well to the established character of the surrounding area. It is anticipated that a range of dwelling types and sizes, including 30% affordable dwellings would be incorporated ranging from 2 beds up to 4 beds which forms the basis for interesting street scenes and helps establish a balanced community. Overall it is considered that the proposal would not have any significant adverse impact upon the residential amenities of existing or future occupiers.
The Potential to reduce carbon emissions through co-location with other uses
4.18 The site is proposed for residential uses. However, increasing Llanybri`s population will allow help sustain local facilities and potentially increase demand for additional services to benefit the village.
Relationship with Historic Environment
4.19 The site is not located within or adjacent to the boundary of a Conservation Area. The closest feature of historic importance is Scheduled Ancient Monument Yr Hen Gapel which sits together with Grade II
listed Tower of Yr Hen Gapel. These are situated within the village of Llanybri, roughly 0.4 kilometres to the south west of the development site.
Delivery of Key Placemaking Objectives
4.20 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 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.
Conclusion
5.1 This site representation is made by Asbri Planning Limited on behalf of Mr David Rhodri Davies. It in respect of the land at Maes Y Meillion, Llanybri which should be reinstated within the development limits of the village, as well as being included as a housing allocation as part of the Carmarthenshire County Council Second Deposit Revised Local Development Plan 2018 - 2033.
5.2 The extension of the settlement limit of Llanybri, and reintroduction of Maes y Meillion as a housing allocation for the Tier 3 settlement can ensure that a proportional amount of housing growth will be delivered across the plan period. Across the plan period it is highly unlikely that any other sites will come forward in the settlement, therefore it is essential that this site is reconsidered as part of the deposit plan, and as previously mentioned, the site is within limits and allocated for residential development in the current plan. The candidate site to the south is a logical extension of the existing housing allocation, with it currently including agricultural structures that are in a dilapidated state.
5.3 Whilst the soundness of the Plan is not challenged objections are made to the following policies within the deposit plan:
a) Object to SD1 (Development Limits) – the site shown in Appendix A ought to be reinstated within the settlement limits of Llanybri. Within the adopted plan, the site is within limits however it has been placed outside limits in the deposit plan. There is no justification for it`s removal, and allowing development at the land in Maes y Meillion enables a natural extension of the settlement. Lying west of the site is the Parc Y Delyn residential development which has a similar amount of residential dwellings to what has gained outline planning permission at the Maes Y Meillion site, along with a similar layout. The previous candidate site shown in Appendix B should also be included within the settlement limit as it is a natural extension of the existing housing allocation and can be facilitated by infrastructure developed as part of the current site that benefits from outline planning permission.
b) Object to HOM1 (Housing Allocation) – the Maes y Meillion housing allocation is not included within the deposit plan, although the site has been allocated for 10 dwellings within the adopted plan. The site layout in Appendix 3 shows 13 dwellings will be delivered in total. There is no reason for removing the site as an allocation, and it has gained outline planning permission for the erection of 13 dwellings and associated infrastructure work (Ref: PL/00629), and a subsequent planning application was submitted in March 2023 concerning full planning permission for the construction of an access road in order to serve those dwellings. The applicant is keen to progress with the reserved matters for the site shortly, therefore this would be considered a deliverable allocation were it to be included in the deposit plan. It is critical that this housing allocation is reinstated into the deposit plan as at present, no housing allocations are proposed for Llanybri, and there are limited opportunities for residential development in other parts of the settlement. The candidate site aspect as shown in Appendix B is a natural extension of this and should also be included.
5.4 Extending the development limit to incorporate this site would promote sustainable growth in a way that takes into consideration the nature of the current settlement. There needs to be an opportunity for some proportional housing growth within this tier 3 settlement that can be facilitated over the plan period until 2033. The site could potentially deliver 13-20 dwellings 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 suitable contribution to the area’s housing land supply. In addition to this, it is located in a sustainable area where some amenities can be accessed on foot, and nearby Carmarthen can be accessed via a bus service that runs nearby. It is also considered acceptable in terms of drainage and ecological aspects.
5.5 In summary, it is considered that Carmarthenshire County Council should, in its review of the Local Development Plan, include the site within the settlement boundary of Llanybri, and include the Maes y Meillion site as a housing allocation within the deposit plan.

No change to Plan.

This representation comprises both an objection and a supporting submission. The proposer's land ownership at Llangadog comprises a number of fields immediately adjacent to the settlement’s centre. A frontage portion at Heol Pendref has been identified as being suitable for residential development and has been included within development limits, the remainder of the land holding has however been excluded. The part-inclusion of this frontage portion is clearly supported, but an objection is hereby made to the exclusion of the remainder. The justification for including only part of the proposer's land will apply to the whole area.
The following objection is made to the exclusion of the majority part of this site from the development limits for Llangadog, an identified Tier 2 Service Centre. It must be emphasised that the proposed scheme includes a number of community benefits and does not seek residential development on the entire landholding. The proposer is keen to offer land for uses that will provide both short and long term benefit to village residents, both in a practical sense and from a more holistic well-being perspective.
A key element of the scheme is to offer land for a much needed car park which is indicated on the accompanying layout drawing as being located immediately adjacent to the village centre. Parking provision is scarce in Llangadog and such a community facility in this village centre location would be welcomed and would help alleviate current on-road congestion. A convenient village centre access is proposed from the A4069 road.
Also, of benefit to the community is a proposed communal garden adjacent to the car park, which would provide an open green public area in the village centre.
Also proposed is an area to be set aside for community allotments which again will benefit the residents of Llangadog and aid in promoting both physical and mental well-being and also benefit the local environment through biodiversity enhancement.
The residential element of the scheme would comprise a high quality phased development and would draw on local Welsh vernacular architectural design elements, making every effort to be sustainable, both through the employment of local contractors, the use of local suppliers, and in the long term, through the provision of residential units within convenient walking distance of village services and facilities.
The proposer’s land is in a vastly more sustainable location than the residential allocations included in the plan for Llangadog, particularly SeC17/h2, which is on the perimeter of the settlement and thereby will contribute towards additional private car usage and exacerbated congestion within the village. The other two sites (SeC17/h1 and SeC17/h3) have been partly constructed and again, are more distant from the village centre.
The inclusion of the proposer’s land 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 2 Service Centre. Its development 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.
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 more sustainable and deliverable than other sites that have been allocated within Llangadog.
The inclusion of this land within revised development limits would be fully supported.

Amend Plan to include limits and the site

This representation objects to the removal of development limits for Gelli Aur. The village is of significant size and is within walking distance of a key agricultural college, as well as an important historic building and parkland (Gelli Aur), the full potential of which has yet to be realised. The village has also enjoyed convenient access to a country park and café facility managed by Carmarthenshire County Council.
The village is also readily accessible to nearby Llandeilo, with its high order goods and services, including primary and secondary education, healthcare services, retail outlets, and the historic Dinefwr Park. The suggested site is considered an ideal ‘rounding off’ of the village and would provide a much needed residential opportunity for the locality.
Appropriate development within Gelli Aur 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.
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.

Amend plan to include the site

The site consists of gently sloping agricultural pasture land situated adjacent
to the existing LDP boundary.
The site has good access from the main B4299 and good visibility splays for a
development of this size.
All utilities and services are close at hand and have capacity for a development
of this size.
The site does not have any adverse ground conditions that may obstruct
development.
The site currently has a natural hedge bank boundary and it is not envisaged
that any works will be required to the boundaries.
We are not aware of any protected trees or wildlife within the site.

Include site within development limits in the Plan.

This representation objects to the exclusion of this site from the development
limits for Capel Dewi – a designated Tier 3 Sustainable Village. The inclusion of
this site within new development limits for this part of Capel Dewi would
reflect similar such ‘outliers’ elsewhere in Carmarthenshire.
The designation of development limits around this cluster of dwellings would
provide recognition and certainty for this section of Capel Dewi which has seen
incremental development over the years. This section of the village has grown
in similar fashion to the main section and its lack of development limits has
not protected the adjacent countryside from development.
Designating the proposed development limits will both afford control and the
opportunity for appropriate development in this sustainable Tier 3 village.
The site’s inclusion would not lead to additional environmental pressure, but
instead will lead to the fostering of sustainable growth and allow for a wider
choice of housing type.
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 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.
It is considered that this site is sustainable and readily deliverable and offers a
valuable development option within this Tier 3 Sustainable Village.
The inclusion of this land within designated development limits would be fully
supported.

Amend the development limits to include the site.

We are instructed by Mr. W. D. & Mrs G. I. Owens to a make a formal representation to the
“soundness” of the Second Deposit Draft of the Carmarthenshire Local Development Plan.
Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/100/007, seeking inclusion of their land for future residential development within the
defined settlement limits of Llannon within the Replacement Local Development Plan. The
Candidate Site comprised of the road frontage portion of a modest, undulating field
enclosure set off the eastern flank of Heol-y-Plas (A476 road).
The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our clients’ submission, reasons why the site was not selected for inclusion within the draft
settlement limits of Llannon, 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 result in a ribbon pattern of
development contrary to general planning principles.”

Our clients have considered this response and decided to revise their proposals to seek
inclusion of half the road frontage along Heol-y-Plas from that which was originally
submitted as a Candidate Site back in 2018.
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 Llannon, 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 Llannon, as reproduced below in Figure 1.
Figure 1 – Extract from Second Draft Proposals Map with site edged in red
This formal representation letter supplements the following documents which comprise a complete submission to the Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
- Location plan and indicative site layout plan
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits

1.0 Perception of “Ribbon Pattern of Development”

1.1 The Council consider that the inclusion of the site within defined settlement limits would represent a “ribbon pattern of development, contrary to general planning principles.” However, no detailed justification is made for that statement.
In response, our clients would point to the form at which established development takes within Llannon. The western flank of Heol-y-Plas (A476) consisting of a continuous frontage of residential properties stretching for several hundred
metres in a south to north alignment. Motorists travelling along this highway have already entered a built-up locality, and encountered speed humps on this section of highway, providing an indication that the settlement is immediately upon them.

1.2 The field frontage in question lies alongside a residential property, known as “Arosfa”, which forms the southern boundary of the field enclosure. Erw Non lies directly opposite, being a residential estate of several dozen properties. The proposals under this Representation have been revised from those submitted back in 2018.

1.3 Only the southern half of this field frontage is now put forward as proposed residential development, being a roadside frontage of some 118 metres, and extending back to an equivalent depth as Arosfa, namely to a depth of 40 metres. Such a depth will allow for detached and semi-detached houses or bungalows to be formed fronting the main highway and set back to allow for adequate vehicle turning areas to be formed, allowing residents and visitors to turn within each developed plot and exit the plots in forwared gear. Such a depth will also allow for traditional rear gardens of a minimum of 10 metres depth. Only four detached dwellinghouses are proposed.

1.4 The setting of roadside frontage properties along Heol-y-Plas is provided below as Figures 2 & 3, being an extract from Ordnance Survey Map and Google Earth respectively, and which graphically depict the setting of the revised Representation Site, directly opposite Erw Non.
Figure 2 – OS Map of site edged in red
Figure 3 – Extract from Google Earth illustrating established road frontage development at Heol-y-Plas

1.5 We therefore consider that the Council has adopted a rather inconsistent approach in the spatial pattern of allocating and subsequently granting planning permission of residential development within the settlement of Llannon. The allocated residential site in Llannon lies immediately north of Clos Rebecca, and it can be seen extending north, almost “ribboning” away from established properties, as shown in Figure 4.
Candidate Site
Figure 4 – illustration of Allocation at Clos Rebecca extendingout into open countryside to the northern side of village

1.6 We submit that our clients’ land opposite Erw Non is no different in form from the allocated field north of Clos Rebecca. Our clients’ field portion in question lies at a highly sustainable position along the A road, which would allow new residents to continue to access the excellent community facilities in the locality, such as the nearby Primary School and main bus route along Heol-y-Plas providing passengers non-car access between Cross Hands and Llanelli.

1.7 The Representation Site indicative site layout plan is reproduced below as Figure 5. It illustrates for only four detached dwellinghouses set fronting the eastern flank of Heol-y-Plas. The proposed site would be complementary in form to adjacent established forms of residential development along this highway, particularly at Erw Non as evidenced by the Proposal Map at Figure 1.
Allocation adjoining Clos Rebecca “ribbons” north of village
Figure 5 – Indicative site layout plan of proposed Representation Site

2.0 Overall Housing Supply at Llannon with Deposit Draft

2.1 The proposals under this Representation merely seek the addition of four residential
units to the overall housing supply of Llannon. The village forms part of the
Ammanford / Cross Hands Cluster (Cluster 3) as defined within the Second Draft
LDP.
The Ammanford / Cross Hands Cluster aims to provide an additional 1267 residential
units over the Plan period to 2033, and thus the addition of a site of 4 units will not
lead to an over-supply of dwellinghouses within the Cluster.

2.2 We have examined and researched sites which have been brought forward as
Residential Allocations with the Deposit Draft. Only one allocation remains at Llannon
as described above at land adjoining Clos Rebecca. Apart from that site, upon which
development has commenced, there does not appear to be any other
opportunities in Llannon for a small residential opportunity. Research of the
draft settlement limits reveals no “white land” readily apparent upon which a
handful of residential plots could be formed.

2.3 There is clear evidence in popular and “sought-after” villages such as Llannon, Foelgastell and Five Roads, which act as subordinate settlements to Llanelli and Cross Hands, that such minor sites are far more likely to be brought forward and developed in full by small housebuilders given that construction and development costs are more likely to be viable in relation to house sales and the general housing market in this part of Carmarthenshire.

2.4 In the case of Llannon, there are little signs within the immediate locality of properties for second sale, and no evidence of undeveloped land available within this part of the settlement limits, which is a strong indicator of a healthy property market at Llannon. Consequently, it is a location where housing proposals are deliverable, assisting to meet housing needs in this part of Ammanford / Cross Hands Cluster.
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.
Our clients have revised their indicative proposals to just 4 dwellinghouses, situated directly opposite Erw Non, and which will not appear at odds to the prevailing spatial pattern of development in Llannon, 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 Llannon realigned to include the Representation Site in the Proposals Map of the adopted Local Development Plan.

Include the site within the development limits, suitable for residential use.

1 General Description
1.1 This LDP Representation relates to the potential inclusion of a new
site allocation for residential development in the Carmarthenshire
Revised Local Development Plan 2018 – 2033.

2 LDP Representation
2.1 The statement has been prepared by Ceri Davies BA Hons, Dip UP,
MRTPI, (Director of Ceri Davies Planning Ltd). The statement is
based on information provided by the client and other consultants.
All stated dimensions and distances are approximates and based on
the best information available at the time. Please refer to the
submission plans for detailed information.
2.2 The LDP Representation details include:
• 2nd Deposit Revised LDP Representation Form
• Location & Site Plans
• Planning Statement

3 Client Details
3.1 The client is Noel Richards of Coedmoelion Farm, Pontyberem,
Llanelli, Carmarthenshire.

4 The Site
4.1 The site consists of an irregular shaped parcel of land which
currently forms part of a field enclosure. The parcel of land fronts
onto the C2068 and is located at the western end of the settlement
of Bancffosfelen.
4.2 The site lies on the southern flank of the C2068, immediately
adjacent to a row of recently built road frontage dwellings. Directly
opposite is an established garage and beyond the garage is a single
residential dwelling.
4.3 The site fronts directly onto the adjacent highway and is located in close proximity to a predominantly residential area at the western end of the settlement. To the north-east is Bro Mebyd Residential Estate. The site lies approximately 200 metres west of the B4306 (Heol y Banc) Road junction.
4.4 The proximity of the site to neighbouring dwellings and the nearby chapel (Capel Pisgah) and its proximity to the existing built form associated with this part of the village is illustrated on the map extract below (Figure i).
Figure i – Location Map of Bancffosfelen
4.6 Whilst the site currently occupies an open countryside location, it lies immediately adjacent to the settlement development limits associated with Bancffosfelen. In fact the site is less than 200 metres away from the centre of the village. The actual proximity of the site to the remainder of the village, which is predominantly residential in nature, is clearly shown on the aerial photograph below (Figure ii).
Figure ii – Aerial Photograph
4.7 The site is essentially a greenfield site, nevertheless, given the residential dwellings immediately north and east along the C2068, it clearly represents a site at the edge of the village.
4.8 Vehicular access into the field enclosure is currently gained via existing field entrances which come directly off the adjacent public highway.

5 The Development
5.1 The aim of the development advanced as part of this LDP representation would be to provide a single residential plot, fronting directly onto the adjacent highway.
5.2 Both the Location plan and Site plan below (Figures iii and iv) illustrate the configuration of the site and extent of the site boundaries in relation to the immediate environs and surrounding area.
The Site
Figure iii – Location Plan
5.3 The site plan extract below (Figure iv) illustrates the positioning of the plot in relation to the adjacent built form. The scale of the plot takes into full account the configuration of the site as well as the approximate plot sizes of nearby residential properties.
Figure iv – Site Plan

6 Policy Context
6.1 A review of the planning policy context associated with the site and the proposed development (at national and local level) is provided within this section of the Statement.
National Planning Policy
6.2 Well-Being of Future Generations (Wales) Act (2015)
6.2.1 The Act places a duty upon public bodies to produce well-being objectives that contribute to achieving a set of overarching well-being goals:
• A Prosperous Wales;
• A Resilient Wales;
• A Healthier Wales;
• A More Equal Wales;
• A Wales of Cohesive Communities;
• A Wales of Vibrant Culture and Thriving Welsh Language; and
• A Globally Responsible Wales.
6.2.2 Each public body is then required to take reasonable steps to meet their objectives in the context of the principle of sustainable development and whilst following a set of five ways of working.
6.2.3 The 'Resilient Wales' and 'Healthier Wales' goals are the key goals that open space and greenspace, as part of the planning process will contribute towards delivering.
6.3 Planning Policy Wales : Edition 11 (February 2021)
6.3.1 Planning Policy Wales (PPW) forms the overarching national planning policy document for Wales and sets out the land use planning policies of the Welsh Government. It is supplemented by a suite of Technical Advice Notes (TANs), Welsh Government Circulars, and policy clarification letters which together with PPW provide the national planning policy framework for Wales. The main objective of PPW is to promote place-making and sustainable forms of development.
6.3.2 The primary objective of PPW is to ensure that the planning system contributes towards the delivery of sustainable development and improves the social, economic, environmental and cultural well-being of Wales, as required by the Planning (Wales) Act 2015, the Well-being of Future Generations (Wales) Act 2015 and other key legislation. PPW and National Development Framework (NDF) set out how the planning system at a national. Regional and local level can assist in delivering these requirements through strategic Development Plans(SDPs) and Local development Plans (LDPs).
6.3.3 There are a number of key planning principles indicated within Planning Policy Wales (PPW) to achieve the right development in the right place.
6.3.4 Paragraph 1.18 emphasises that the legislation secures a presumption in favour of sustainable development in accordance with the development plan, unless material considerations indicate otherwise. The principles of sustainable development are defined in the Well-being of Future Generations Act.
6.3.5 Paragraph 1.22 of PPW states that up-to-date development plans are the basis of the planning system and that these set the context for rational and consistent decision making, where they have been prepared in accordance with up to date national planning policies.
6.3.6 These key planning principles are set out with a view to achieve a number of national sustainable placemaking outcomes, as explained in paragraphs 2.15-2.20 and outlined in Figure 4. The national sustainable placemaking outcomes are:
People and Places: Achieving Well-being Through Placemaking
• Growing our economy in a sustainable manner
• Making best use of resources
• Maximising environmental protection and limiting environmental impact
• Creating and sustaining communities
• Facilitating accessible and healthy environments
6.3.7 Paragraph 2.17 states “In responding to the key principles for the planning system, the creation of sustainable places and in recognition of the need to contribute to the well-being of future generations in Wales through placemaking, development plans and development proposals must seek to deliver development that address the national sustainable placemaking outcomes”.
6.3.8 Sustainable development forms a key consideration central to all policies contained within Planning Policy Wales (PPW). Paragraph 1.2 states: “The primary objective of PPW is to ensure that the planning system contributes towards the delivery of sustainable development and improves the social, economic, environmental and cultural well-being of Wales, as required by the Planning (Wales) Act 2015, the Wellbeing of Future Generations (Wales) Act 2015 and other key legislation.”
6.3.9 Paragraph 2.27 sets out how to assess the sustainable benefits of development: “Planning authorities should ensure that social, economic, environmental and cultural benefits are considered in the decision-making process and assessed in accordance with the five ways of working to ensure a balanced assessment is carried out to implement the Well-being of Future Generations Act and the Sustainable Development Principle. There may be occasions when one benefit of a development proposal or site allocation outweighs others, and in such cases robust evidence should be presented to support these decisions, whilst seeking to maximise contributions against all the well-being goals.”
6.3.10 Paragraph 2.17 states that “in responding to the key principles for the planning system, the creation of sustainable places and in recognition of the need to contribute to the well-being of future
generations in Wales through placemaking, development plans and development proposals must seek to deliver developments that address the national sustainable placemaking outcomes.”
6.4 Future Wales: The National Plan 2040
6.4.1 Future Wales – The National Plan 2040 is Wales’ national development framework which sets out the direction for development in Wales to 2040. It is a development plan that sets out a strategy for addressing key national priorities including sustaining and developing a vibrant economy, achieving decarbonisation and climate-resilience, developing strong ecosystems and improving the health and wellbeing of our communities.
6.4.2 The spatial strategy is a guiding framework which sets out the key national policies that will guide and encourage development which supports sustainable growth in both urban and rural areas across Wales.
Policy 1 – Where Wales will grow
6.4.3 Policy 1 is the overarching policy which sets out where sustainable growth will take place in Wales. Three National Growth Areas have been established where there will 14 be growth in employment and housing opportunities and investment in infrastructure. The National Growth Areas are:
• Cardiff, Newport and the Valleys;
• Swansea Bat and Llanelli; and
• Wrexham and Deeside.
6.3.4 These National Growth Areas are complemented by Regional Growth Areas, which will grow, develop and offer a variety of public and commercial services at regional scale. There are Regional Growth Areas in three regions:
• The South West;
• Mid Wales; and
• The North.
6.3.5 In addition to the above growth areas, there are a mix of smaller towns and villages and large areas of countryside. The policy states that ‘development in towns and villages in rural areas will support local aspirations and need, complementing rather than competing with efforts to grow our cities and towns.’
Local Planning Policy
6.4 The proximity of the site to the defined settlement development limits for Bancffosfelen in the current Local Development Plan 2006-2021 (LDP) is illustrated in the map extract below, Figure (v).
Figure v – Proposals Map (LDP 2006-2021)
6.5 The proximity of the site to the defined settlement development limits for Bancffosfelen in the 2nd Deposit Revised Carmarthenshire Local Development Plan (LDP) is illustrated in the map extract below, Figure (vi).
6.6 It is evident from the revised proposals map that the settlement development limits have been altered and reconfigured to include additional the recently built Bro Mebyd Residential estate to the east.
Figure vi – Proposals Map (Revised LDP 2018-2033)

7 Detailed Consideration
7.1 It is asserted that the site is deemed compatible with Strategic Policy SP3 of the revised LDP which seeks to ensure the provision of growth and development is directed to sustainable locations in accordance with the spatial framework.
7.2 Given its siting immediately adjacent to the settlement of Bancffosfelen / Pontyberem which is classed as a Tier 2 Service Centre, and, its proximity to nearby villages such as Pontyates, Tumble and Drefach, ISA Objective 1 (Sustainable Development) is satisfied in this instance.
7.3 As illustrated on the aforementioned site plan, the site can potentially accommodate a single residential dwelling which would be sited directly opposite an existing dwelling, adjacent to Erw Las Garage.
7.4 The site is directly related to the identified settlement of Banffosfelen. As already highlighted, the site represents a very sustainable location given its close proximity to Bancffosfelen, which falls within the Ammanford/Cross-Hands cluster and in conjunction with Pontyberem, is classed as a Service Centre in Strategic Policy SP3 of the LDP.
7.5 Natural Resources Wales Development Advice Maps indicate that the site does not lie within a Zone C1 or C2 flood area as defined by the development advice maps referred to in Technical Advice Note 15, Development and Flood Risk (TAN 15), as illustrated in the DAM extract below (Figure vii).
7.6 TAN15 states that new development should be directed away from Zone C and towards zone A, otherwise to zone B, where river or coastal flooding will be less of an issue. The site is not considered to be at risk of flooding during at least the 1 in 1000 year event.
7.7 The development advice maps supplemented by sediment data, held by the British Geological Survey (BGS), of historical flooding. The maps adopt a precautionary principle and are based on the best known information available at the time. It is noted that the NRW flood maps show the site as being flood free during the Q100 event and Q1000 event.
Figure vii – DAM Map
7.8 The Flood Map for Planning Wales also indicates that the site is not at risk from localised or surface water flooding; this is illustrated on the FMfP extract below (Figure viii). The Flood Risk Map below demonstrates that apart from a small section of the site frontage, the site falls outside of Flood Zone 2 and Flood Zone 3, as such falls within and an area deemed at low flood risk from rivers. The site will not be affected during the 1 in 1000 fluvial (Q1000 event or 0.1% event) and would also be flood free during the 1 in 100 (Q100) flood event.
Figure viii - FMfP
The Site
The Site
7.9 The site does not fall within a C1 or C2 flood risk zone as delineated by TAN15 DAM flood maps. Neither does it fall within a Flood Zone 2 or Flood Zone 3 as delineated by FMfP (Flood Map for Planning Wales). As such, ISA Objective 4 (Climatic Factors) and ISA Objective 5 (Water) are both satisfied in this instance.
7.10 The site is not located within or immediately any of the following designated sites:
• Sites of Special Scientific Interest (SSSI)
• Special Areas of Conservation (SAC)
• Special Protection Areas (SPA)
• National Nature Reserves (NNR)
• Local Nature Reserves (LNR)
• Common Land or registered village green
As such, ISA Objective 2 (Biodiversity) is satisfied in this instance.
7.11 The site is not located within or immediately adjacent to any Scheduled Monuments. As such, ISA Objective 8 (Cultural Heritage and Historic Environment) is satisfied in this instance.
7.12 The proposed development is deemed appropriate at this location in that it would not impact on any core planning principles. The proposed development would be sited immediately adjacent to existing residential dwellings and would also be sited directly opposite an existing dwelling. As such, given that it would not be extending beyond the existing dwelling opposite, it would not represent an inappropriate intrusion into the open countryside nor would it be seen as an unacceptable extension of the built form into the rural landscape.
7.13 The map extract below (Figure ix) illustrates the existing pattern of development at this part of the village and the proximity of the site to the existing built form associated with the settlement.
Figure ix – Location Plan
7.14 As already emphasised, given that the development would not extend beyond the existing dwelling directly opposite, the proposal would not lead to unacceptable ribbon development; it would not be deemed tandem development. It would not lead to unacceptable coalescence of settlements and given its siting immediately adjacent to an existing residential property, it cannot be described as unacceptable sporadic development or an unacceptable extension to the settlement. In addition it would not result in the loss of areas of public open space or formal recreational land. Given the aforementioned, it is asserted that the development would not be contrary to general planning principles.
7.15 The development would sit comfortably at this location without having any detrimental impact whatsoever on the character or setting of the settlement. Furthermore, the development would not have any detrimental impact on any features of the settlement such as landscapes, townscapes or buildings of importance as a result of its scale, density and prominence. As such, ISA Objective 8 (Cultural Heritage and Historic Environment) along with ISA Objective 9 (Landscape) are both satisfied in this instance.
7.16 The proposal would not involve the re-use of suitable previously developed land, hence it is acknowledged that the land is a greenfield site, as such, ISA Objective 7 (Soil) is not satisfied in this instance.
7.17 The site has a road frontage boundary that fronts onto the C2068. As such, the site is readily accessible from the existing public highway. The site has existing and established entrances with adequate visibility splays, which allows direct access into the site from the adjacent highway.
7.18 The C2068 is a relatively quiet road which serves primarily as access to a small number of farmsteads in addition to a link between Bancffosfelen and Pontyates. The road junction onto Heol Y Banc is also served by adequate visibility splays. The map below (Figure x) illustrates the number of crashes in the immediate vicinity of the site.
Figure x (Source:Crashmap.co.uk)
7.19 Data obtained from Crashmap.co.uk confirms that in the last 10 years, there have been no slight, serious or fatal crash incidents along this part of the C2068 classified road, and only one slight accident close to the Heol y Banc (B4306) road junction. This would suggest that there are no highway issues relating to the site or the public road(s) which serve the site.
7.20 The site lies in fairly close proximity to National Cycle Network Route 47, which is approximately 3 km away. This proximity of the site to this cycle route is illustrated on the Sustrans National Cycle Network Map extract below (Figure xi).
Figure xi (Source:Sustrans)
7.21 The site is readily accessible to a local bus services (First Cymru South & West Wales) Route No.s 166 and 195, with the nearest bus stop less than a 2 minute walk away. There’s a regular bus service which links the village to the commercial centres of Carmarthen, Llanelli and Cross Hands.
7.22 It is considered the site has suitable access to public transport as well as identified active travel routes, as such, satisfies the following ISA Objectives; ISA 3 (Air Quality), ISA 4 (Climatic Factors), ISA 6 (Material Assets), ISA 12 (Health & Well-being), ISA 13 (Education s& Skills), ISA 15 (Social Fabric).
7.23 Given its location, the site lies immediately adjacent to an accessible green space. In addition, the site is very accessible to an identified recreation play area in the settlement of Bancffosfelen. The nearest recreation / green space identified on the LDP Proposals Map is approximately 200 metres away which represents a reasonable walking distance. As such, it is considered the site satisfies ISA Objective 12 (Health & Well-being) and ISA Objective 15 (Social Fabric) .
7.24 The plan extract below (Figure xii), taken from the LDP Proposals Map highlights the proximity of the site to the identified green spaces in the village of Bancffosfelen.
Figure xii – LDP2 Proposal Map
7.25 The site is within a reasonable walking distance of a number of retail and employment provisions; and services and facilities that can be found in Bancffosfelen/Pontyberem service centre. Other provisions / services / facilities within a reasonable driving distance (approx. 5 minutes) can be found in nearby settlements such as Tumble, Drefach and Pontyates.
7.26 In addition, the site is within a reasonable distance of the commercial centre of Cross Hands which has a wide range of employment/retail provisions, services and facilities. Whilst the site occupies a rural location, it represents a very sustainable location given its close proximity to the service centre.
7.27 It is considered the site is within a reasonable distance of a number of employment and retail provisions as well as other local services and facilities, given its proximity to Cross Hands, Carmarthen and Llanelli. As such, the site satisfies the following ISA Objectives; ISA 6 (Material Assets), ISA 10 (Population), ISA 14 (Economy), ISA 15 (Social Fabric).
7.28 The site represents a sustainable location in terms of its proximity to nearby nursery schools and Bancffosfelen Primary School. The
site is also within a reasonable distance of Ysgol Maes y Gwendraeth (5km). As such, ISA Objective 13 (Education & Skills) is satisfied in this instance.
7.29 The site is not located within or adjacent to a mineral buffer zone, as such, ISA Objective 6 (Material Assets) is satisfied in this instance. The site is not located within a Mineral Safeguarding Area, as such, ISA Objective 6 (Material Assets) is satisfied in this instance. The site is not located within or immediately adjacent to an a Air Quality Management Area (AQMA), as such, ISA Objective 3 (Air Quality) is satisfied in this instance.
7.30 The site does not contain high carbon e.g. peatlands, as such, ISA Objective 7 (Soil) is satisfied in this instance. The site does not contain high quality agricultural land (grades 1,2 or 3A, as identified within the Agricultural Land Classification Maps). As such, ISA Objective 7 (Soil) is satisfied in this instance.
7.31 The site is not located within or immediately adjacent to any Regionally Important Geological or Geomorphological Sites. As such, ISA Objective 9 (Landscape) is satisfied in this instance.
7.32 The site is located within close proximity to a viable water connection and is also located within close proximity to other viable infrastructure requirements such as electricity and main sewer.
7.33 The site is not located within or adjacent to a phosphate sensitive SAC catchment. A such, As such, the site satisfies the following ISA Objectives; ISA 2 (Biodiversity), ISA 5 (Water) & ISA 7 (Soil).
7.34 The site by virtue of its scale and location, would not have the potential to have a detrimental impact on the Welsh Language. As such, ISA Objective 11 (Welsh Language) is satisfied in this instance.
7.35 The traffic movements associated with the development proposal will be marginal and the development could be accommodated on the highway network and will not have a detrimental impact on the free flow of traffic due to the existing volumes of traffic using the local highway network. There are no access or transport constraints to prevent the development of the site for residential purposes.
7.36 It is asserted that owing to the nature of the development proposal being advanced i.e. single dwelling, the development has due regard to the existing built form and also character and appearance of the surrounding area. Careful consideration has been given to the
proposed layout to ensure the relationship between the proposed dwelling and existing development in close proximity is acceptable. It is considered that a modestly sized residential dwelling would conform with the character and appearance of the immediate area in terms of siting and land use.
7.37 It is not disputed that the siting of a residential dwelling at this location would introduce built form at an otherwise undeveloped site. However, the dwelling would not represent a prominent or conspicuous form of development. While the proposed development would inevitably change the character of the site itself, the proposed changes would not be to the extent that would result in an unacceptable impact on the surrounding landscape.
7.38 The development would not be readily visible from the wider area; and would represent a logical extension to the existing built form. Given the aforementioned, it is considered that any resulting development would not be inappropriate or disproportionate in scale. It is on this basis that it is considered that the proposal would represent a sensitive form of development, commensurate with the existing built form, hence would not adversely affect the spatial character of the village.
7.39 The development would not have a significant impact on the amenity of adjacent land uses, properties, residents or the community. The impact on the amenity of nearby residents has been fully considered and duly discounted, particularly given the separation distance between the site and the nearest residential properties.
7.40 Overall, the proposed development would satisfy PPW’s objective of achieving sustainable development both by ensuring that the local community has access to sufficient housing and affordable options whilst also working to facilitate a modal shift to more sustainable methods of transport and reducing car borne journeys.

8 Summary and Conclusion
8.1 This Planning Statement has been completed on behalf of Noel Richards and provides planning support for the inclusion of additional land in the revised Local Development Plan to accommodate potential residential development at land adjacent to Heddfan, Bancffosfelen.
8.2 It has been established that the principle of residential development is compliant with both national and local policy and represents an acceptable form of infill development at this location. The development would assist with the housing land supply situation in the county.
8.3 While residential development at this location would inevitably change the character of the site itself, the proposed changes would not result in an unacceptable impact on the surrounding landscape nor would they have an adverse impact on the existing neighbouring development, highway network or local infrastructure.
8.4 In conclusion, it has been demonstrated that there are significant material considerations weighing in favour of the inclusion of this site for residential development in the upcoming revised local plan.

Nid yw'n cael ei nodi.

Not stated.

Annwyl Syr/Fadam,
Parthed: Safle SuV20/h1 (tir ger fferm Llwyn Henri)
Ysgrifennaf i gofrestru fy ngwrthwynebiad llwyr i gynnwys Safle SuV20/h1 yng Nghynllun Datblygu Lleol Diwygiedig Sir Gaerfyrddin 2018 – 2033. Roedd gwrthwynebiad chwyrn i’r safle hwn gan bobl y pentref nôl yn 2014. Bryd hynny cafodd y safle ei wrthod yn unfrydol gan Ymgynghorydd Cynllunio Annibynnol ac Arolygydd Cynllunio Annibynnol. Cafodd y safle hefyd ei wrthod gan Adain Blaen-gynllunio’r Cyngor ar ôl gwneud ‘asesiadau trylwyr’. Roedd y pryderon ynghylch y safle ar y pryd yn cynnwys y ffaith bod rhan o’r safle ar barth llifogydd a bod yna eisoes broblemau’n ymwneud â llif dŵr glaw ar y safle a chapasiti’r system garthffosiaeth. Nid yw’r problemau hyn wedi diflannu nac wedi newid. Po fwyaf o ddatblygu fydd yn digwydd yn y pentref, y mwyaf o straen fydd ar y seilwaith carthffosiaeth a dŵr glaw, sydd eisoes yn methu ymdopi. Yn 2021 cafodd carthion heb eu trin eu rhyddhau i afon Gwendraeth Fach 77 o weithiau, gan Dŵr Cymru, o’r bibell ym Mhontfaen – dim ond un enghraifft yw hyn. Mae’r safle ger Llwyn Henri yn aml yn ddirlawn ar ôl glaw trwm ac yn aml gwelir llynnoedd o ddŵr yn sefyll arno, ac mae dŵr hefyd yn llifo i lawr y ffordd fach sy’n mynd heibio i fynedfa Llwyn Henri (hen heol Gelli-ddu Fach) – byddai unrhyw ddatblygu ar y safle hwn yn golygu colli amsugfa ddŵr naturiol a gwerthfawr a byddai’n anochel yn arwain at waethygu problemau llifogydd a charthffosiaeth yn y pentref.

Yn ychwanegol, mae’r map yn dangos newid yn ffin y pentref ar hyd ffordd y B4310. Yn ôl y map mae ffin ddeheuol y pentref wedi symud ymhellach i’r De – lle’r oedd yn gorffen gydag Awelfryn mae’r map newydd yn cynnwys darn o’r cae o flaen Tŷ Cynheidre. Beth yw’r rheswm am hyn a beth allai’r goblygiadau fod o ran y math o ddatblygu a allai gael ei ganiatáu yma?

Yn gywir

Include the site within the development limits.

1 General Description
1.1 This LDP Representation relates to the potential revision of the
defined settlement limits to include a new site for residential
development in the Carmarthenshire Revised Local Development
Plan 2018 – 2033.
2 LDP Representation
2.1 The statement has been prepared by Ceri Davies BA Hons, Dip UP,
MRTPI, (Director of Ceri Davies Planning Ltd). The statement is
based on information provided by the client and other consultants.
All stated dimensions and distances are approximates and based on
the best information available at the time. Please refer to the
submission plans for detailed information.
2.2 The LDP Representation details include:
• 2nd Deposit Revised LDP Representation Form
• Location & Site Plans
• Planning Statement
3 Client Details
3.1 The client is Patricia Davies of 53 Greenfield Terrace, Pontyberem,
Llanelli, Carmarthenshire.
4 The Site
4.1 The site consists of broadly rectangular shaped piece of land blocks
of land which currently form part of a field enclosure associated
with 55 Greenfield Terrace. The site lies on the outskirts of the
settlement of Pontyberem.
4.2 The block of land lies on the northern flank of Greenfield Terrace at
the end of an established row of road frontage dwellings fronting
onto the adjacent highway. The site represents the last remaining
gap between the row of houses and the mature hedgerow to the
east.
4
4.3 The site fronts directly onto Greenfield Terrace and is located immediately adjacent to a row of houses which are located just outside the settlement limits associated with Pontyberem.
4.4 Beyond the block of land on the northern flank of Greenfield Terrace, to the east, there consists a small cluster of dwellings fronting onto Capel Seion Road.
4.5 The proximity of the site to neighbouring dwellings and its proximity to the existing built form associated with this part of the village, particularly along Greenfield Terrace is illustrated on the map extract below (Figure i).
Figure i – Location Plan
4.6 Whilst the site currently occupies an open countryside location, it lies immediately adjacent to an existing row of houses and in close proximity to the settlement development limits associated with Pontyberem. The actual proximity of the site to the predominantly residential area within the village is clearly shown on the aerial photograph below (Figure ii).
5
Figure ii – Aerial Photograph
4.7 Vehicular access into the site is currently gained via the existing field entrance which come directly off the adjacent public highway.
5 The Development
5.1 The aim of this representation is to extend the settlement development limits associated with Pontyberem, to incorporate the cluster of dwellings either side of Greenfield Terrace at this location including the vacant piece of land immediately adjacent to 55 Greenfield Terrace.
5.2 Both the Location and Site plans below (Figures iii and iv) illustrate the extent of land the client considers ought to be included in the revised settlement development limits associated with Pontyberem. The land in question consists of 13 residential properties along the northern flank of Greenfield Terrace and 5 residential properties along the southern flank; it also includes the vacant plot at the eastern most point.
The Site
6
Figure iii – Location Plan
5.3 The site plan below illustrates in greater detail the extent of the land deemed appropriate for inclusion in the revised settlement limits for the village.
Figure iv – Site Plan
7
6 Policy Context
6.1 A review of the planning policy context associated with the site and the proposed development (at national and local level) is provided within this section of the Statement.
National Planning Policy
6.2 Well-Being of Future Generations (Wales) Act (2015)
6.2.1 The Act places a duty upon public bodies to produce well-being objectives that contribute to achieving a set of overarching well-being goals:
• A Prosperous Wales;
• A Resilient Wales;
• A Healthier Wales;
• A More Equal Wales;
• A Wales of Cohesive Communities;
• A Wales of Vibrant Culture and Thriving Welsh Language; and
• A Globally Responsible Wales.
6.2.2 Each public body is then required to take reasonable steps to meet their objectives in the context of the principle of sustainable development and whilst following a set of five ways of working.
6.2.3 The 'Resilient Wales' and 'Healthier Wales' goals are the key goals that open space and greenspace, as part of the planning process will contribute towards delivering.
8
6.3 Planning Policy Wales : Edition 11 (February 2021)
6.3.1 Planning Policy Wales (PPW) forms the overarching national planning policy document for Wales and sets out the land use planning policies of the Welsh Government. It is supplemented by a suite of Technical Advice Notes (TANs), Welsh Government Circulars, and policy clarification letters which together with PPW provide the national planning policy framework for Wales. The main objective of PPW is to promote place-making and sustainable forms of development.
6.3.2 The primary objective of PPW is to ensure that the planning system contributes towards the delivery of sustainable development and improves the social, economic, environmental and cultural well-being of Wales, as required by the Planning (Wales) Act 2015, the Well-being of Future Generations (Wales) Act 2015 and other key legislation. PPW and National Development Framework (NDF) set out how the planning system at a national. Regional and local level can assist in delivering these requirements through strategic Development Plans(SDPs) and Local development Plans (LDPs).
6.3.3 There are a number of key planning principles indicated within Planning Policy Wales (PPW) to achieve the right development in the right place.
6.3.4 Paragraph 1.18 emphasises that the legislation secures a presumption in favour of sustainable development in accordance with the development plan, unless material considerations indicate otherwise. The principles of sustainable development are defined in the Well-being of Future Generations Act.
6.3.5 Paragraph 1.22 of PPW states that up-to-date development plans are the basis of the planning system and that these set the context for rational and consistent decision making, where they have been prepared in accordance with up to date national planning policies.
6.3.6 These key planning principles are set out with a view to achieve a number of national sustainable placemaking outcomes, as explained in paragraphs 2.15-2.20 and outlined in Figure 4. The national sustainable placemaking outcomes are:
9
People and Places: Achieving Well-being Through Placemaking
• Growing our economy in a sustainable manner
• Making best use of resources
• Maximising environmental protection and limiting environmental impact
• Creating and sustaining communities
• Facilitating accessible and healthy environments
6.3.7 Paragraph 2.17 states “In responding to the key principles for the planning system, the creation of sustainable places and in recognition of the need to contribute to the well-being of future generations in Wales through placemaking, development plans and development proposals must seek to deliver development that address the national sustainable placemaking outcomes”.
6.3.8 Sustainable development forms a key consideration central to all policies contained within Planning Policy Wales (PPW). Paragraph 1.2 states: “The primary objective of PPW is to ensure that the planning system contributes towards the delivery of sustainable development and improves the social, economic, environmental and cultural well-being of Wales, as required by the Planning (Wales) Act 2015, the Wellbeing of Future Generations (Wales) Act 2015 and other key legislation.”
6.3.9 Paragraph 2.27 sets out how to assess the sustainable benefits of development: “Planning authorities should ensure that social, economic, environmental and cultural benefits are considered in the decision-making process and assessed in accordance with the five ways of working to ensure a balanced assessment is carried out to implement the Well-being of Future Generations Act and the Sustainable Development Principle. There may be occasions when one benefit of a development proposal or site allocation outweighs others, and in such cases robust evidence should be presented to support these decisions, whilst seeking to maximise contributions against all the well-being goals.”
6.3.10 Paragraph 2.17 states that “in responding to the key principles for the planning system, the creation of sustainable places and in recognition of the need to contribute to the well-being of future
10
generations in Wales through placemaking, development plans and development proposals must seek to deliver developments that address the national sustainable placemaking outcomes.”
6.4 Future Wales: The National Plan 2040
6.4.1 Future Wales – The National Plan 2040 is Wales’ national development framework which sets out the direction for development in Wales to 2040. It is a development plan that sets out a strategy for addressing key national priorities including sustaining and developing a vibrant economy, achieving decarbonisation and climate-resilience, developing strong ecosystems and improving the health and wellbeing of our communities.
6.4.2 The spatial strategy is a guiding framework which sets out the key national policies that will guide and encourage development which supports sustainable growth in both urban and rural areas across Wales.
Policy 1 – Where Wales will grow
6.4.3 Policy 1 is the overarching policy which sets out where sustainable growth will take place in Wales. Three National Growth Areas have been established where there will 14 be growth in employment and housing opportunities and investment in infrastructure. The National Growth Areas are:
• Cardiff, Newport and the Valleys;
• Swansea Bat and Llanelli; and
• Wrexham and Deeside.
6.3.4 These National Growth Areas are complemented by Regional Growth Areas, which will grow, develop and offer a variety of public and commercial services at regional scale. There are Regional Growth Areas in three regions:
• The South West;
• Mid Wales; and
• The North.
11
6.3.5 In addition to the above growth areas, there are a mix of smaller towns and villages and large areas of countryside. The policy states that ‘development in towns and villages in rural areas will support local aspirations and need, complementing rather than competing with efforts to grow our cities and towns.’
Local Planning Policy
6.4 The proximity of the existing group of dwellings to the defined settlement development limits for Pontyberem in the current Local Development Plan 2006-2021 (LDP) is illustrated in the map extract below, Figure (v).
Figure v – Proposals Map (LDP 2006-2021)
6.5 The proximity of the existing group of dwellings to the defined settlement development limits for Pontyberem in the 2nd Deposit Revised Carmarthenshire Local Development Plan (LDP) is illustrated in the map extract below, Figure (vi).
6.6 It is evident from the revised proposals map that the settlement development limits have been altered and reconfigured to include additional land along the southern flank of Greenfield Terrace. However this alteration does not extend beyond Coed y Gaeaf.
12
Figure vi – Proposals Map (Revised LDP 2018-2033)
13
7 Detailed Consideration
7.1 It is asserted that the inclusion of this grouping of dwellings, including the additional plot, is compatible with Strategic Policy SP3 of the revised LDP which seeks to ensure the provision of growth and development is directed to sustainable locations in accordance with the spatial framework.
7.2 Given the siting of the dwellings and the vacant plot in close proximity to the village of Pontyberem which is classed as a Tier 2 Service Centre and its proximity to nearby villages such as Bancffosfelen, Tumble and Drefach, ISA Objective 1 (Sustainable Development) is satisfied in this instance.
7.3 As illustrated on the previous plans, the revision to the settlement development limit would equate to an additional 18 dwellings and one residential plot being included within the village boundary.
7.4 The land earmarked for potential inclusion is directly related to the identified settlement of Pontyberem, as illustrated on the location plan below (Figure vii).
Figure vii – Land considered suitable for inclusion in the revised limits
14
7.5 The plan below (Figure viii) provides a more detailed illustration of the extent of land deemed appropriate for inclusion in the revised limits. The suggested inclusion of land would strictly follow existing property boundaries, with the only exception being that of the small field enclosure immediately adjacent to No.55 Greenfield Terrace. This being the site proposed for inclusion as a new residential plot.
Figure viii – Location Plan
7.6 It is considered the highlighted land represents a sustainable location given its close proximity to Pontyberem, which falls within the Ammanford/Cross-Hands cluster and is classed as a Service Centre in Strategic Policy SP3 of the LDP.
7.7 Natural Resources Wales Development Advice Maps indicate that the land does not lie within a Zone C1 or C2 flood area as defined by the development advice maps referred to in Technical Advice Note 15, Development and Flood Risk (TAN 15), as illustrated in the DAM extract below (Figure ix).
7.8 TAN15 states that new development should be directed away from Zone C and towards zone A, otherwise to zone B, where river or coastal flooding will be less of an issue. The site is not considered to be at risk of flooding during at least the 1 in 1000 year event.
7.9 The development advice maps supplemented by sediment data, held by the British Geological Survey (BGS), of historical flooding. The maps adopt a precautionary principle and are based on the best known information available at the time. It is noted that the NRW
15
flood maps show the site as being flood free during the Q100 event and Q1000 event.
Figure ix – DAM Map
7.10 The Flood Map for Planning Wales also indicates that the land subject of this representation is not at risk from localised or surface water flooding; this is illustrated on the FMfP extract below (Figure x). The Flood Risk Map below demonstrates that apart from a small section of the site frontage, the site falls outside of Flood Zone 2 and Flood Zone 3, as such falls within and an area deemed at low flood risk from rivers. The land will not be affected during the 1 in 1000 fluvial (Q1000 event or 0.1% event) and would also be flood free during the 1 in 100 (Q100) flood event.
Figure x - FMfP
Existing dwellings
Land under consideration
16
7.11 The land does not fall within a C1 or C2 flood risk zone as delineated by TAN15 DAM flood maps. Neither does it fall within a Flood Zone 2 or Flood Zone 3 as delineated by FMfP (Flood Map for Planning Wales). As such, ISA Objective 4 (Climatic Factors) and ISA Objective 5 (Water) are both satisfied in this instance.
7.12 The land is not located within or immediately any of the following designated sites:
• Sites of Special Scientific Interest (SSSI)
• Special Areas of Conservation (SAC)
• Special Protection Areas (SPA)
• National Nature Reserves (NNR)
• Local Nature Reserves (LNR)
• Common Land or registered village green
As such, ISA Objective 2 (Biodiversity) is satisfied in this instance.
7.13 The land is not located within or immediately adjacent to any Scheduled Monuments. As such, ISA Objective 8 (Cultural Heritage and Historic Environment) is satisfied in this instance.
7.14 The proposed inclusion of additional land within the redefined settlement development limits is deemed appropriate at this location in that it would not impact on any core planning principles. The land would be located in very close proximity to existing residential dwellings, approximately 90 metres to be precise, and would represent a natural rounding off the existing built form.
7.15 It is asserted that the addition of one residential plot would not lead to unacceptable ribbon development as it is sited within a defined and mature hedgerow boundary. It would not be deemed tandem development, it would not lead to unacceptable coalescence of settlements and it cannot be described as unacceptable sporadic development or an unacceptable extension to the settlement. If anything the inclusion of these house along with the vacant plot represents a logical extension do the settlement.
7.16 In addition it would not result in the loss of areas of public open space or formal recreational land. Given the aforementioned, it is asserted that the development would not be contrary to general planning principles.
17
7.17 The addition of one plot would sit comfortably at this location without having any detrimental impact whatsoever on the character or setting of the settlement. Furthermore, the development would not have any detrimental impact on any features of the settlement such as landscapes, townscapes or buildings of importance as a result of its scale, density and prominence. As such, ISA Objective 8 (Cultural Heritage and Historic Environment) along with ISA Objective 9 (Landscape) are both satisfied in this instance.
7.18 The proposal would not involve the re-use of suitable previously developed land, hence it is acknowledged that the land is a greenfield site, as such, ISA Objective 7 (Soil) is not satisfied in this instance.
7.19 The site has a road frontage boundary that fronts onto an Greenfield Terrace. As such, the site is readily accessible from the existing public highway. The site has existing and established entrances with adequate visibility splays, which allows direct access into the site from the adjacent highway.
7.20 Greenfield Terrace is a relatively quiet road which serves primarily as a link between Pontyberem and Capel Seion. The road junction onto Heol Y Bryn is also served by adequate visibility splays. The map below (Figure xi) illustrates the number of crashes in the immediate vicinity of the site.
Figure xi (Source:Crashmap.co.uk)
18
7.21 Data obtained from Crashmap.co.uk confirms that in the last 20 years, there have been no slight, serious or fatal crash incidents along this part of Greenfield Terrace. Neither have there been any such accidents at the Heol y Bryn road junction. This would suggest that there are no highway issues relating to the site or the public road(s) which serve the site.
7.22 The site lies in fairly close proximity to National Cycle Network Route 47, which is approximately 1.8km away. This proximity of the site to this cycle route is illustrated on the Sustrans National Cycle Network Map extract below (Figure xii).
Figure xii (Source:Sustrans)
7.23 The site is readily accessible to a local bus services (First Cymru South & West Wales) Route No. 128, with the nearest bus stop less than a 3 minute walk away. There’s a regular bus service which links the village to the commercial centres of Carmarthen, Llanelli and Cross Hands.
7.24 It is considered the site has suitable access to public transport as well as identified active travel routes, as such, satisfies the following ISA Objectives; ISA 3 (Air Quality), ISA 4 (Climatic Factors), ISA 6 (Material Assets), ISA 12 (Health & Well-being), ISA 13 (Education s& Skills), ISA 15 (Social Fabric).
19
7.25 Given its location, the site lies immediately adjacent to an accessible green space. In addition, the site is very accessible to an identified recreation play area in the settlement of Pontyberem. The nearest play space identified on the LDP Proposals Map is approximately 800 metres away which represents a reasonable walking distance. As such, it is considered the site satisfies ISA Objective 12 (Health & Well-being) and ISA Objective 15 (Social Fabric) .
7.26 The plan extract below (Figure xiii), taken from the LDP Proposals Map highlights the proximity of the site to the identified green spaces in the village of Pontyberem.
Figure xiii – LDP2 Proposal Map
7.27 The site along with the existing houses are within a reasonable walking distance of a number of retail and employment provisions; and services and facilities that can be found in Pontyberem service centre. Other provisions / services / facilities within a reasonable driving distance (approx. 5 minutes) can be found in nearby settlements such as Tumble, Drefach and Pontyates.
7.28 In addition, the site is within a reasonable distance of the commercial centre of Cross Hands which has a wide range of employment/retail provisions, services and facilities. Whilst the site occupies a rural location, it represents a very sustainable location given its close proximity to the service centre.
7.29 It is considered the site is within a reasonable distance of a number of employment and retail provisions as well as other local services
20
and facilities, given its proximity to Cross Hands, Carmarthen and Llanelli. As such, the site satisfies the following ISA Objectives; ISA 6 (Material Assets), ISA 10 (Population), ISA 14 (Economy), ISA 15 (Social Fabric).
7.30 The site represents a sustainable location in terms of its proximity to nearby nursery schools and Pontyberem Primary School. The site is also within a reasonable distance of Ysgol Maes y Gwendraeth (5km). As such, ISA Objective 13 (Education & Skills) is satisfied in this instance.
7.31 The site is not located within or adjacent to a mineral buffer zone, as such, ISA Objective 6 (Material Assets) is satisfied in this instance. The site is located within a Mineral Safeguarding Area, as such, ISA Objective 6 (Material Assets) is not satisfied in this instance. The site is not located within or immediately adjacent to an a Air Quality Management Area (AQMA), as such, ISA Objective 3 (Air Quality) is satisfied in this instance.
7.32 The site does not contain high carbon e.g. peatlands, as such, ISA Objective 7 (Soil) is satisfied in this instance. The site does not contain high quality agricultural land (grades 1,2 or 3A, as identified within the Agricultural Land Classification Maps). As such, ISA Objective 7 (Soil) is satisfied in this instance.
7.33 The site is not located within or immediately adjacent to any Regionally Important Geological or Geomorphological Sites. As such, ISA Objective 9 (Landscape) is satisfied in this instance.
7.34 The site is located within close proximity to a viable water connection and is also located within close proximity to other viable infrastructure requirements such as electricity and main sewer.
7.35 The site is not located within or adjacent to a phosphate sensitive SAC catchment. A such, As such, the site satisfies the following ISA Objectives; ISA 2 (Biodiversity), ISA 5 (Water) & ISA 7 (Soil).
7.36 The site by virtue of its scale and location, would not have the potential to have a detrimental impact on the Welsh Language. As such, ISA Objective 11 (Welsh Language) is satisfied in this instance.
7.37 The traffic movements associated with one additional residential plot will be marginal and the development could be accommodated on the highway network and will not have a detrimental impact on
21
the free flow of traffic due to the existing volumes of traffic using the local highway network. There are no access or transport constraints to prevent the development of the site for residential purposes.
7.38 It is asserted that owing to the nature of the development proposal being advanced i.e. 1 additional residential plot, the development has due regard to the existing built form and also character and appearance of the surrounding area. Careful consideration has been given to the proposed layout to ensure the relationship between the proposed dwelling and existing development in close proximity is acceptable.
7.39 It is not disputed that the siting of an additional dwelling at this location would introduce built form at an otherwise undeveloped site. However, the dwelling would not represent a prominent or conspicuous form of development. While the proposed development would inevitably change the character of the site itself, the proposed changes would not be to the extent that would result in an unacceptable impact on the surrounding landscape.
7.40 Given the aforementioned, it is considered that any resulting development would not be inappropriate or disproportionate in scale. It is on this basis that it is considered that the proposal would represent a sensitive form of development, commensurate with the existing built form, hence would not adversely affect the spatial character of the village.
7.41 The development would not have a significant impact on the amenity of adjacent land uses, properties, residents or the community. The impact on the amenity of nearby residents has been fully considered and duly discounted, particularly given the separation distance between the site and the nearest residential properties.
7.42 Overall, the proposed development would satisfy PPW’s objective of achieving sustainable development both by ensuring that the local community has access to sufficient housing and affordable options whilst also working to facilitate a modal shift to more sustainable methods of transport and reducing car borne journeys.
22
8 Summary and Conclusion
8.1 This Planning Statement has been completed on behalf of Patricia Davies and provides planning support for the inclusion of additional land in the revised Local Development Plan to accommodate potential residential development at land adjacent to No.55 Greenfield Terrace, Pontyberem.
8.2 It has been established that the principle of residential development is compliant with both national and local policy and represents an acceptable form of infill development at this location. The development would assist with the housing land supply situation in the county.
8.3 While residential development at this location would inevitably change the character of the site itself, the proposed change would not result in an unacceptable impact on the surrounding landscape nor would they have an adverse impact on the existing neighbouring development, highway network or local infrastructure.
8.4 In conclusion, it has been demonstrated that there are significant material considerations weighing in favour of the inclusion of the existing group of dwellings along with the inclusion of one additional site for residential development in the upcoming revised local plan.

Draw development limits around the group of dwellings.

1 General Description
1.1 This LDP Representation relates to the potential revision of the
defined settlement limits to include a new site for residential
development in the Carmarthenshire Revised Local Development
Plan 2018 – 2033.
2 LDP Representation
2.1 The statement has been prepared by Ceri Davies BA Hons, Dip UP,
MRTPI, (Director of Ceri Davies Planning Ltd). The statement is
based on information provided by the client and other consultants.
All stated dimensions and distances are approximates and based on
the best information available at the time. Please refer to the
submission plans for detailed information.
2.2 The LDP Representation details include:
• 2nd Deposit Revised LDP Representation Form
• Location & Site Plans
• Planning Statement
3 Client Details
3.1 The client is Patricia Davies of 53 Greenfield Terrace, Pontyberem,
Llanelli, Carmarthenshire.
4 The Site
4.1 The site consists of broadly rectangular shaped piece of land blocks
of land which currently form part of a field enclosure associated
with 55 Greenfield Terrace. The site lies on the outskirts of the
settlement of Pontyberem.
4.2 The block of land lies on the northern flank of Greenfield Terrace at
the end of an established row of road frontage dwellings fronting
onto the adjacent highway. The site represents the last remaining
gap between the row of houses and the mature hedgerow to the
east.
4
4.3 The site fronts directly onto Greenfield Terrace and is located immediately adjacent to a row of houses which are located just outside the settlement limits associated with Pontyberem.
4.4 Beyond the block of land on the northern flank of Greenfield Terrace, to the east, there consists a small cluster of dwellings fronting onto Capel Seion Road.
4.5 The proximity of the site to neighbouring dwellings and its proximity to the existing built form associated with this part of the village, particularly along Greenfield Terrace is illustrated on the map extract below (Figure i).
Figure i – Location Plan
4.6 Whilst the site currently occupies an open countryside location, it lies immediately adjacent to an existing row of houses and in close proximity to the settlement development limits associated with Pontyberem. The actual proximity of the site to the predominantly residential area within the village is clearly shown on the aerial photograph below (Figure ii).
5
Figure ii – Aerial Photograph
4.7 Vehicular access into the site is currently gained via the existing field entrance which come directly off the adjacent public highway.
5 The Development
5.1 The aim of this representation is to extend the settlement development limits associated with Pontyberem, to incorporate the cluster of dwellings either side of Greenfield Terrace at this location including the vacant piece of land immediately adjacent to 55 Greenfield Terrace.
5.2 Both the Location and Site plans below (Figures iii and iv) illustrate the extent of land the client considers ought to be included in the revised settlement development limits associated with Pontyberem. The land in question consists of 13 residential properties along the northern flank of Greenfield Terrace and 5 residential properties along the southern flank; it also includes the vacant plot at the eastern most point.
The Site
6
Figure iii – Location Plan
5.3 The site plan below illustrates in greater detail the extent of the land deemed appropriate for inclusion in the revised settlement limits for the village.
Figure iv – Site Plan
7
6 Policy Context
6.1 A review of the planning policy context associated with the site and the proposed development (at national and local level) is provided within this section of the Statement.
National Planning Policy
6.2 Well-Being of Future Generations (Wales) Act (2015)
6.2.1 The Act places a duty upon public bodies to produce well-being objectives that contribute to achieving a set of overarching well-being goals:
• A Prosperous Wales;
• A Resilient Wales;
• A Healthier Wales;
• A More Equal Wales;
• A Wales of Cohesive Communities;
• A Wales of Vibrant Culture and Thriving Welsh Language; and
• A Globally Responsible Wales.
6.2.2 Each public body is then required to take reasonable steps to meet their objectives in the context of the principle of sustainable development and whilst following a set of five ways of working.
6.2.3 The 'Resilient Wales' and 'Healthier Wales' goals are the key goals that open space and greenspace, as part of the planning process will contribute towards delivering.
8
6.3 Planning Policy Wales : Edition 11 (February 2021)
6.3.1 Planning Policy Wales (PPW) forms the overarching national planning policy document for Wales and sets out the land use planning policies of the Welsh Government. It is supplemented by a suite of Technical Advice Notes (TANs), Welsh Government Circulars, and policy clarification letters which together with PPW provide the national planning policy framework for Wales. The main objective of PPW is to promote place-making and sustainable forms of development.
6.3.2 The primary objective of PPW is to ensure that the planning system contributes towards the delivery of sustainable development and improves the social, economic, environmental and cultural well-being of Wales, as required by the Planning (Wales) Act 2015, the Well-being of Future Generations (Wales) Act 2015 and other key legislation. PPW and National Development Framework (NDF) set out how the planning system at a national. Regional and local level can assist in delivering these requirements through strategic Development Plans(SDPs) and Local development Plans (LDPs).
6.3.3 There are a number of key planning principles indicated within Planning Policy Wales (PPW) to achieve the right development in the right place.
6.3.4 Paragraph 1.18 emphasises that the legislation secures a presumption in favour of sustainable development in accordance with the development plan, unless material considerations indicate otherwise. The principles of sustainable development are defined in the Well-being of Future Generations Act.
6.3.5 Paragraph 1.22 of PPW states that up-to-date development plans are the basis of the planning system and that these set the context for rational and consistent decision making, where they have been prepared in accordance with up to date national planning policies.
6.3.6 These key planning principles are set out with a view to achieve a number of national sustainable placemaking outcomes, as explained in paragraphs 2.15-2.20 and outlined in Figure 4. The national sustainable placemaking outcomes are:
9
People and Places: Achieving Well-being Through Placemaking
• Growing our economy in a sustainable manner
• Making best use of resources
• Maximising environmental protection and limiting environmental impact
• Creating and sustaining communities
• Facilitating accessible and healthy environments
6.3.7 Paragraph 2.17 states “In responding to the key principles for the planning system, the creation of sustainable places and in recognition of the need to contribute to the well-being of future generations in Wales through placemaking, development plans and development proposals must seek to deliver development that address the national sustainable placemaking outcomes”.
6.3.8 Sustainable development forms a key consideration central to all policies contained within Planning Policy Wales (PPW). Paragraph 1.2 states: “The primary objective of PPW is to ensure that the planning system contributes towards the delivery of sustainable development and improves the social, economic, environmental and cultural well-being of Wales, as required by the Planning (Wales) Act 2015, the Wellbeing of Future Generations (Wales) Act 2015 and other key legislation.”
6.3.9 Paragraph 2.27 sets out how to assess the sustainable benefits of development: “Planning authorities should ensure that social, economic, environmental and cultural benefits are considered in the decision-making process and assessed in accordance with the five ways of working to ensure a balanced assessment is carried out to implement the Well-being of Future Generations Act and the Sustainable Development Principle. There may be occasions when one benefit of a development proposal or site allocation outweighs others, and in such cases robust evidence should be presented to support these decisions, whilst seeking to maximise contributions against all the well-being goals.”
6.3.10 Paragraph 2.17 states that “in responding to the key principles for the planning system, the creation of sustainable places and in recognition of the need to contribute to the well-being of future
10
generations in Wales through placemaking, development plans and development proposals must seek to deliver developments that address the national sustainable placemaking outcomes.”
6.4 Future Wales: The National Plan 2040
6.4.1 Future Wales – The National Plan 2040 is Wales’ national development framework which sets out the direction for development in Wales to 2040. It is a development plan that sets out a strategy for addressing key national priorities including sustaining and developing a vibrant economy, achieving decarbonisation and climate-resilience, developing strong ecosystems and improving the health and wellbeing of our communities.
6.4.2 The spatial strategy is a guiding framework which sets out the key national policies that will guide and encourage development which supports sustainable growth in both urban and rural areas across Wales.
Policy 1 – Where Wales will grow
6.4.3 Policy 1 is the overarching policy which sets out where sustainable growth will take place in Wales. Three National Growth Areas have been established where there will 14 be growth in employment and housing opportunities and investment in infrastructure. The National Growth Areas are:
• Cardiff, Newport and the Valleys;
• Swansea Bat and Llanelli; and
• Wrexham and Deeside.
6.3.4 These National Growth Areas are complemented by Regional Growth Areas, which will grow, develop and offer a variety of public and commercial services at regional scale. There are Regional Growth Areas in three regions:
• The South West;
• Mid Wales; and
• The North.
11
6.3.5 In addition to the above growth areas, there are a mix of smaller towns and villages and large areas of countryside. The policy states that ‘development in towns and villages in rural areas will support local aspirations and need, complementing rather than competing with efforts to grow our cities and towns.’
Local Planning Policy
6.4 The proximity of the existing group of dwellings to the defined settlement development limits for Pontyberem in the current Local Development Plan 2006-2021 (LDP) is illustrated in the map extract below, Figure (v).
Figure v – Proposals Map (LDP 2006-2021)
6.5 The proximity of the existing group of dwellings to the defined settlement development limits for Pontyberem in the 2nd Deposit Revised Carmarthenshire Local Development Plan (LDP) is illustrated in the map extract below, Figure (vi).
6.6 It is evident from the revised proposals map that the settlement development limits have been altered and reconfigured to include additional land along the southern flank of Greenfield Terrace. However this alteration does not extend beyond Coed y Gaeaf.
12
Figure vi – Proposals Map (Revised LDP 2018-2033)
13
7 Detailed Consideration
7.1 It is asserted that the inclusion of this grouping of dwellings, including the additional plot, is compatible with Strategic Policy SP3 of the revised LDP which seeks to ensure the provision of growth and development is directed to sustainable locations in accordance with the spatial framework.
7.2 Given the siting of the dwellings and the vacant plot in close proximity to the village of Pontyberem which is classed as a Tier 2 Service Centre and its proximity to nearby villages such as Bancffosfelen, Tumble and Drefach, ISA Objective 1 (Sustainable Development) is satisfied in this instance.
7.3 As illustrated on the previous plans, the revision to the settlement development limit would equate to an additional 18 dwellings and one residential plot being included within the village boundary.
7.4 The land earmarked for potential inclusion is directly related to the identified settlement of Pontyberem, as illustrated on the location plan below (Figure vii).
Figure vii – Land considered suitable for inclusion in the revised limits
14
7.5 The plan below (Figure viii) provides a more detailed illustration of the extent of land deemed appropriate for inclusion in the revised limits. The suggested inclusion of land would strictly follow existing property boundaries, with the only exception being that of the small field enclosure immediately adjacent to No.55 Greenfield Terrace. This being the site proposed for inclusion as a new residential plot.
Figure viii – Location Plan
7.6 It is considered the highlighted land represents a sustainable location given its close proximity to Pontyberem, which falls within the Ammanford/Cross-Hands cluster and is classed as a Service Centre in Strategic Policy SP3 of the LDP.
7.7 Natural Resources Wales Development Advice Maps indicate that the land does not lie within a Zone C1 or C2 flood area as defined by the development advice maps referred to in Technical Advice Note 15, Development and Flood Risk (TAN 15), as illustrated in the DAM extract below (Figure ix).
7.8 TAN15 states that new development should be directed away from Zone C and towards zone A, otherwise to zone B, where river or coastal flooding will be less of an issue. The site is not considered to be at risk of flooding during at least the 1 in 1000 year event.
7.9 The development advice maps supplemented by sediment data, held by the British Geological Survey (BGS), of historical flooding. The maps adopt a precautionary principle and are based on the best known information available at the time. It is noted that the NRW
15
flood maps show the site as being flood free during the Q100 event and Q1000 event.
Figure ix – DAM Map
7.10 The Flood Map for Planning Wales also indicates that the land subject of this representation is not at risk from localised or surface water flooding; this is illustrated on the FMfP extract below (Figure x). The Flood Risk Map below demonstrates that apart from a small section of the site frontage, the site falls outside of Flood Zone 2 and Flood Zone 3, as such falls within and an area deemed at low flood risk from rivers. The land will not be affected during the 1 in 1000 fluvial (Q1000 event or 0.1% event) and would also be flood free during the 1 in 100 (Q100) flood event.
Figure x - FMfP
Existing dwellings
Land under consideration
16
7.11 The land does not fall within a C1 or C2 flood risk zone as delineated by TAN15 DAM flood maps. Neither does it fall within a Flood Zone 2 or Flood Zone 3 as delineated by FMfP (Flood Map for Planning Wales). As such, ISA Objective 4 (Climatic Factors) and ISA Objective 5 (Water) are both satisfied in this instance.
7.12 The land is not located within or immediately any of the following designated sites:
• Sites of Special Scientific Interest (SSSI)
• Special Areas of Conservation (SAC)
• Special Protection Areas (SPA)
• National Nature Reserves (NNR)
• Local Nature Reserves (LNR)
• Common Land or registered village green
As such, ISA Objective 2 (Biodiversity) is satisfied in this instance.
7.13 The land is not located within or immediately adjacent to any Scheduled Monuments. As such, ISA Objective 8 (Cultural Heritage and Historic Environment) is satisfied in this instance.
7.14 The proposed inclusion of additional land within the redefined settlement development limits is deemed appropriate at this location in that it would not impact on any core planning principles. The land would be located in very close proximity to existing residential dwellings, approximately 90 metres to be precise, and would represent a natural rounding off the existing built form.
7.15 It is asserted that the addition of one residential plot would not lead to unacceptable ribbon development as it is sited within a defined and mature hedgerow boundary. It would not be deemed tandem development, it would not lead to unacceptable coalescence of settlements and it cannot be described as unacceptable sporadic development or an unacceptable extension to the settlement. If anything the inclusion of these house along with the vacant plot represents a logical extension do the settlement.
7.16 In addition it would not result in the loss of areas of public open space or formal recreational land. Given the aforementioned, it is asserted that the development would not be contrary to general planning principles.
17
7.17 The addition of one plot would sit comfortably at this location without having any detrimental impact whatsoever on the character or setting of the settlement. Furthermore, the development would not have any detrimental impact on any features of the settlement such as landscapes, townscapes or buildings of importance as a result of its scale, density and prominence. As such, ISA Objective 8 (Cultural Heritage and Historic Environment) along with ISA Objective 9 (Landscape) are both satisfied in this instance.
7.18 The proposal would not involve the re-use of suitable previously developed land, hence it is acknowledged that the land is a greenfield site, as such, ISA Objective 7 (Soil) is not satisfied in this instance.
7.19 The site has a road frontage boundary that fronts onto an Greenfield Terrace. As such, the site is readily accessible from the existing public highway. The site has existing and established entrances with adequate visibility splays, which allows direct access into the site from the adjacent highway.
7.20 Greenfield Terrace is a relatively quiet road which serves primarily as a link between Pontyberem and Capel Seion. The road junction onto Heol Y Bryn is also served by adequate visibility splays. The map below (Figure xi) illustrates the number of crashes in the immediate vicinity of the site.
Figure xi (Source:Crashmap.co.uk)
18
7.21 Data obtained from Crashmap.co.uk confirms that in the last 20 years, there have been no slight, serious or fatal crash incidents along this part of Greenfield Terrace. Neither have there been any such accidents at the Heol y Bryn road junction. This would suggest that there are no highway issues relating to the site or the public road(s) which serve the site.
7.22 The site lies in fairly close proximity to National Cycle Network Route 47, which is approximately 1.8km away. This proximity of the site to this cycle route is illustrated on the Sustrans National Cycle Network Map extract below (Figure xii).
Figure xii (Source:Sustrans)
7.23 The site is readily accessible to a local bus services (First Cymru South & West Wales) Route No. 128, with the nearest bus stop less than a 3 minute walk away. There’s a regular bus service which links the village to the commercial centres of Carmarthen, Llanelli and Cross Hands.
7.24 It is considered the site has suitable access to public transport as well as identified active travel routes, as such, satisfies the following ISA Objectives; ISA 3 (Air Quality), ISA 4 (Climatic Factors), ISA 6 (Material Assets), ISA 12 (Health & Well-being), ISA 13 (Education s& Skills), ISA 15 (Social Fabric).
19
7.25 Given its location, the site lies immediately adjacent to an accessible green space. In addition, the site is very accessible to an identified recreation play area in the settlement of Pontyberem. The nearest play space identified on the LDP Proposals Map is approximately 800 metres away which represents a reasonable walking distance. As such, it is considered the site satisfies ISA Objective 12 (Health & Well-being) and ISA Objective 15 (Social Fabric) .
7.26 The plan extract below (Figure xiii), taken from the LDP Proposals Map highlights the proximity of the site to the identified green spaces in the village of Pontyberem.
Figure xiii – LDP2 Proposal Map
7.27 The site along with the existing houses are within a reasonable walking distance of a number of retail and employment provisions; and services and facilities that can be found in Pontyberem service centre. Other provisions / services / facilities within a reasonable driving distance (approx. 5 minutes) can be found in nearby settlements such as Tumble, Drefach and Pontyates.
7.28 In addition, the site is within a reasonable distance of the commercial centre of Cross Hands which has a wide range of employment/retail provisions, services and facilities. Whilst the site occupies a rural location, it represents a very sustainable location given its close proximity to the service centre.
7.29 It is considered the site is within a reasonable distance of a number of employment and retail provisions as well as other local services
20
and facilities, given its proximity to Cross Hands, Carmarthen and Llanelli. As such, the site satisfies the following ISA Objectives; ISA 6 (Material Assets), ISA 10 (Population), ISA 14 (Economy), ISA 15 (Social Fabric).
7.30 The site represents a sustainable location in terms of its proximity to nearby nursery schools and Pontyberem Primary School. The site is also within a reasonable distance of Ysgol Maes y Gwendraeth (5km). As such, ISA Objective 13 (Education & Skills) is satisfied in this instance.
7.31 The site is not located within or adjacent to a mineral buffer zone, as such, ISA Objective 6 (Material Assets) is satisfied in this instance. The site is located within a Mineral Safeguarding Area, as such, ISA Objective 6 (Material Assets) is not satisfied in this instance. The site is not located within or immediately adjacent to an a Air Quality Management Area (AQMA), as such, ISA Objective 3 (Air Quality) is satisfied in this instance.
7.32 The site does not contain high carbon e.g. peatlands, as such, ISA Objective 7 (Soil) is satisfied in this instance. The site does not contain high quality agricultural land (grades 1,2 or 3A, as identified within the Agricultural Land Classification Maps). As such, ISA Objective 7 (Soil) is satisfied in this instance.
7.33 The site is not located within or immediately adjacent to any Regionally Important Geological or Geomorphological Sites. As such, ISA Objective 9 (Landscape) is satisfied in this instance.
7.34 The site is located within close proximity to a viable water connection and is also located within close proximity to other viable infrastructure requirements such as electricity and main sewer.
7.35 The site is not located within or adjacent to a phosphate sensitive SAC catchment. A such, As such, the site satisfies the following ISA Objectives; ISA 2 (Biodiversity), ISA 5 (Water) & ISA 7 (Soil).
7.36 The site by virtue of its scale and location, would not have the potential to have a detrimental impact on the Welsh Language. As such, ISA Objective 11 (Welsh Language) is satisfied in this instance.
7.37 The traffic movements associated with one additional residential plot will be marginal and the development could be accommodated on the highway network and will not have a detrimental impact on
21
the free flow of traffic due to the existing volumes of traffic using the local highway network. There are no access or transport constraints to prevent the development of the site for residential purposes.
7.38 It is asserted that owing to the nature of the development proposal being advanced i.e. 1 additional residential plot, the development has due regard to the existing built form and also character and appearance of the surrounding area. Careful consideration has been given to the proposed layout to ensure the relationship between the proposed dwelling and existing development in close proximity is acceptable.
7.39 It is not disputed that the siting of an additional dwelling at this location would introduce built form at an otherwise undeveloped site. However, the dwelling would not represent a prominent or conspicuous form of development. While the proposed development would inevitably change the character of the site itself, the proposed changes would not be to the extent that would result in an unacceptable impact on the surrounding landscape.
7.40 Given the aforementioned, it is considered that any resulting development would not be inappropriate or disproportionate in scale. It is on this basis that it is considered that the proposal would represent a sensitive form of development, commensurate with the existing built form, hence would not adversely affect the spatial character of the village.
7.41 The development would not have a significant impact on the amenity of adjacent land uses, properties, residents or the community. The impact on the amenity of nearby residents has been fully considered and duly discounted, particularly given the separation distance between the site and the nearest residential properties.
7.42 Overall, the proposed development would satisfy PPW’s objective of achieving sustainable development both by ensuring that the local community has access to sufficient housing and affordable options whilst also working to facilitate a modal shift to more sustainable methods of transport and reducing car borne journeys.
22
8 Summary and Conclusion
8.1 This Planning Statement has been completed on behalf of Patricia Davies and provides planning support for the inclusion of additional land in the revised Local Development Plan to accommodate potential residential development at land adjacent to No.55 Greenfield Terrace, Pontyberem.
8.2 It has been established that the principle of residential development is compliant with both national and local policy and represents an acceptable form of infill development at this location. The development would assist with the housing land supply situation in the county.
8.3 While residential development at this location would inevitably change the character of the site itself, the proposed change would not result in an unacceptable impact on the surrounding landscape nor would they have an adverse impact on the existing neighbouring development, highway network or local infrastructure.
8.4 In conclusion, it has been demonstrated that there are significant material considerations weighing in favour of the inclusion of the existing group of dwellings along with the inclusion of one additional site for residential development in the upcoming revised local plan.

No change to Plan.

Parc y Bryn, Springfield Road SA31 1EG
This is in support of the recommendations of the LDP which extends the
Housing Development Limits along the Northern and Eastern boundaries
of the site.

See attachments