SD1: Terfynau Datblygu

Amend Plan to include site

2nd Deposit Revised Carmarthenshire Local Development Plan 2018 - 2033

Following my initial application to the Carmarthenshire County Council Local Development Plan, several years ago, I wish to submit the following which I hope will be favourably considered in the 2nd Deposit Revised LDP.

I have lived at 31 Heol Llanelli, Trimsaran, SA17 4AG for the past almost 10 years. This is a 3 acre smallholding site with a one 3 bedroom bungalow, which I live in as a single occupancy. Recently I have been diagnosed with arthritis and bony spurs on both hips, which is not curable and will only impede my mobility as the years go on.

I therefore request that part of my site be included in the 2nd Deposit Revised Carmarthenshire LDP 2018-2033. This would be in order for me in the future, should the need arise, to apply for planning permission for my daughter, or family member, to build a single dwelling in order that I would have assistance in my old age.

I attach my original Candidate Site Form from SNAP Survey, and a map showing the outline of my land (shown in red), and the proposed area (shown in green), which I would ask you to consider being added to the new LDP.

I can confirm that water, gas, electric, BT & broadband are already on the site and would be utilized for the new build. The lane is my private land and is maintained by myself.

I trust you will look favourably at my proposals.

Please can you confirm receipt of this email, and should there be anything else I need to submit I would be grateful if you could advise me of the same, before the deadline of 14th April 2023.

The development limits should remain as shown on the current LDP Proposals Map.

Consultation on Second Deposit Revised Local Plan - PrC3/MU1 - Emlyn Brickworks

I have just submitted representations via the online portal, which have been acknowledged and given ID: 4930.

The online portal did not permit me to upload all the documents I wished to submit, so I therefore submit these now. In anticipation there will be a limit on the size of attachments your email system will accept, I am submitting these documents across 7 separate emails.

In total, the documents you received should include the following

1. PED - PrC3-MU1 - 2023-04-13 [0] - Representation-form
2. PED - PrC3-MU1 - 2023-04-13 [1] - Reps 2nd Deposit Plan
3. PED - PrC3-MU1 - 2023-04-13 [2] - Parc Emlyn Initial Masterplan
4. PED - PrC3-MU1 - 2023-04-13 [3] - Tetra Tech Site Review pgs 1-9
5. PED - PrC3-MU1 - 2023-04-13 [4] - Tetra Tech Site Review pgs 10-23
6. PED - PrC3-MU1 - 2023-04-13 [5] - Tetra Tech Site Review pgs 24-39
7. PED - PrC3-MU1 - 2023-04-13 [6] - Tetra Tech Site Review pgs 40-55
8. PED - PrC3-MU1 - 2023-04-13 [7] - Tetra Tech Site Review Fig 1 Site location plan
9. PED - PrC3-MU1 - 2023-04-13 [8] - Tetra Tech Site Review Fig 2 Phasing plan (previous reports)
10. PED - PrC3-MU1 - 2023-04-13 [9] - Tetra Tech Site Review Fig 3 Site constraints plan
11. PED - PrC3-MU1 - 2023-04-13 [10] - Tetra Tech Site Review Appendix B page 78 map of peat deposits.

The first complements the details submitted online.
The second and third are as per the documents uploaded online.

If you have any questions regarding the above then please do not hesitate to contact me.


Planning statement:

1. INTRODUCTION
1.1 These representations are submitted in response to the consultation by
Carmarthenshire County Council (‘the Council’) on the Second Deposit Plan
version of the emerging Carmarthenshire Revised Local Development Plan
(2018 - 2033) (‘the Deposit Plan’).
1.2 These representations are made in respect of the proposed allocation of land
at the former Emlyn Brickworks for the delivery of community focused
development along with 177 new homes, site reference PrC3/MU1.
1.3 The relevant draft site allocation policy is SG1 (Regeneration and Mixed-Use
Sites).
1.4 The site is shown on the Proposals Map.
1.5 Other relevant draft policies are SD1 (Development Limits) and SP4 (A
Sustainable Approach to Providing New Homes).
1.6 These representations are made on behalf of Parc Emlyn Developments
Limited (‘Parc Emlyn’). Parc Emlyn own the majority of the land which the
Council propose be included in the site allocation, and all of the additional
land which Parc Emlyn propose be included.
1.7 In summary, the allocation of land at Emlyn Brickworks for a residential led
mixed-use development is supported and the timing and number of new
homes forecast to be delivered within the plan period is also supported.
However, the arbitrary exclusion of a large portion of the existing allocated
area from the proposed allocated area, and its exclusion from within the
defined settlement boundary, is not sound.
1.8 Parc Emlyn seek an amendment of the allocation boundary. An Initial
Masterplan drawing is submitted with these representations, the coloured
areas of which depict the extent of the land which should be allocated.
1.9 These representations are also accompanied by a technical report, the Desk
Top Study Review and Coal Mining Assessment (May 2022) by Tetra Tech
(the Tetra Tech Site Review). The information submitted includes the main
report and the three figures, but not the appendices, with the exception of an
extract from Appendix B.
2. SITE LOCATION AND DESCRIPTION
2.1 The site lies within the village of Penygroes and is in Cluster 3 (Ammanford /
Crosshands) of Tier 1 (Principal Centres); see Deposit Plan draft Strategic
Policy SP3: Sustainable Distribution Settlement Framework and Appendix 7
(Housing Trajectory Allocations).
PED – Site PrC3/MU1 – Emlyn Brickworks
PED – Representations on Second Deposit Plan 3
2.2 The site (both that proposed for allocation by the Council and the additional
land proposed for inclusion by Parc Emlyn) formed the larger part of the
Emlyn Colliery. The colliery operated from around 1880 until 19391. Part of
the site was used as a brickworks (the Parc Emlyn Brickworks), starting
before the closure of the colliery and operating until the mid 1990s.
2.3 The existing village wraps around the north, east and part of the south side of
the site. To the west and along part of the south side, the site is bounded by
open fields. The roads to the north, east and south are, respectively, Norton
Road, Bridge Street / Waterloo Road and Gors Ddu Road. The neighbouring
development is primarily residential, and on the east side includes the vacant
former rugby club building. In the south west corner, just outside the site, is a
small commercial site and beyond that further housing in the village of Morfa.
2.4 A newly constructed road (the Cross Hands Economic Link Road) lies a little
further west of the site and a spur link road from that now crosses the site to
link with Norton Road. The spur link road includes a roundabout, which has
been designed so a third arm, serving the southern part of the Emlyn
Brickworks site, may be connected to it at a later date.
2.5 The site is otherwise undeveloped. Most of it is covered by a layer of colliery
spoil. Adventitious plant growth has developed across the site. The western
side is bordered by a mature hedgerow. Along the eastern part of the northern
boundary, there is an established line of tree and plant growth, which lies just
outside the site.
3. PLANNING HISTORY
3.1 Following the closure of the site as a brickworks, applications for outline
planning permission across different parts of the site were approved in 2000,
with approval of reserved matters following in 2004. These permissions were
extended in 2007. By this time all existing buildings across the majority of the
former colliery / brickworks area had been demolished, the colliery spoil heap
had been removed, and the entire site subjected to major earthworks whereby
colliery spoil was redistributed across it. This was a major undertaking and a
fundamental step necessary to prepare the site for new development. These
works were the subject of a series of verification reports in 2007 (see the
Tetra Tech Site Review, sections 4.17 to 4.20), to confirm ground
contamination remediation had taken place.
3.2 Parc Emlyn Developments Limited (Parc Emlyn) took ownership of the site in
early 2010. The existing permissions across the site were due to expire, so a
series of new applications were made to extend them, which were approved
in October 2010. The latter extended the permissions for schemes first put
together ten years earlier. In July 2012 Parc Emlyn brought forward the first
application for full planning permission, based on an updated assessment of
1 ‘Penygroes, Caerbryn a Blaenau – History of the area in pictures’ by L Davies, D Thomas
and A Davies (2011) Penygroes History Society
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how best to develop the site. This opening application for nine units was
approved in March 2013. A subsequent application for a minor amendment
was submitted in January 2014 and approved in April 2014. This development
was subsequently built out. It is referred to as Phase I.
3.3 The current Local Plan for the period 2006 to 2021 was adopted by the
Council on 10 December 2014. It confirmed the allocation of the entire Emlyn
Brickworks site for a mix of uses consisting of residential (250 units),
community facilities and amenity (site reference GA3/MU2).
3.4 In July 2015 an application was submitted by Carmarthenshire Council for the
construction of the Cross Hands Economic Link Road. This included a spur
link to Norton Road, across land owned by Parc Emlyn. On 1 September 2015
an application was submitted by Parc Emlyn for full planning permission for 70
homes (referred to as Phase II). There was an overlap between the two
application areas, such that they could not both be implemented. Planning
permission for the Link Road was granted in October 2017. Subsequently, a
new application for the spur link only was submitted in December 2019, which
avoided any overlap with the scheme for 70 homes on Phase II. The revised
spur link road application was granted by notice dated 10 September 2020.
3.5 During the course of site investigations to inform the application for the Link
Road, ecologists acting for the Council (as applicant) found evidence of the
presence of dormice, a protected species, on sections of the main link road.
The location of this evidence was in sufficient proximity to the Phase II area
that the potential for dormice to be present on Phase II had to be taken into
consideration. Following investigation and assessment, a way forward in
principle on the planning application (subject to conditions) was agreed by
Natural Resources Wales in August 2022. Subsequently, Parc Emlyn and the
Council have been working together to enter into a planning obligation in
respect of some of the matters arising from the application for Phase II. The
issue of the formal decision is imminent.
3.6 The time taken to bring the application on Phase II to a conclusion has held
back work on the remainder of the site. The grant of permission for Phase II
will re-establish the confidence necessary to resource the preparation and
submission of further planning applications. In addition, the Link Road,
including the spur link, has been completed and opened, which affords new
suitable means of vehicular access to the remainder of the site. This is
another major step forward, supporting the delivery of development on the
site.
3.7 In January 2018 the Council resolved to prepare a revised local plan.
Between February and August 2018, the Council invited submissions from
developers and others for sites to be allocated for development (candidate
sites). A candidate site assessment questionnaire was completed and
submitted to the Council for Emlyn Brickworks. The Candidate Site reference
is SR/132/009.
PED – Site PrC3/MU1 – Emlyn Brickworks
PED – Representations on Second Deposit Plan 5
3.8 At that time a development partner (Low Carbon Construction Ltd) was
leading on all planning matters, on behalf of Parc Emlyn. The candidate site
questionnaire for Emlyn Brickworks was submitted by representatives acting
on behalf of Low Carbon. The questionnaire was accompanied by a Location
Plan (dwg 09.99.T/JE July 2018 by JCR Planning), an Indicative Masterplan
Layout (dwg 09.99.a/JE July 2018, by JCR Planning) and a Candidate Site
Supporting Statement (Aug 2018, by JCR Planning).
3.9 The Candidate Site Supporting Statement made clear, at paragraph 3.0.1,
that the Indicative Masterplan Layout was for illustrative purposes and other
design solutions for the site could also be reached. The Statement went on to
propose, in paragraph 3.2.1, that the Candidate Site be allocated for a mixed
use development, including up to 350 residential units. It is clear from this
paragraph that the allocation of the entire area, within the red line as shown
on the Location Plan, was proposed.
3.10 During the time which has elapsed since the submission of the candidate site
questionnaire there have been a number of changes which should be noted
• The arrangement between Low Carbon and Parc Emlyn has ended.
• The site area (questionnaire question 2) is now reduced slightly. Parc
Emlyn held options on two areas of land: a site containing a collection of
existing buildings in the south west corner, off Gors Ddu Road, and; the
land coloured light blue on the Initial Masterplan (accompanying this
representation) and labelled ‘Community Use’. Parc Emlyn no longer
holds options on these areas.
• Parc Emlyn supports the timing and rate of delivery of residential units as
set out in the Deposit Plan, and withdraws the answer given in response
to question 16 on the candidate site questionnaire.
4. SOUNDNESS TEST 2 – IS THE PLAN APPROPRIATE
4.1 The Welsh Government Development Plans Manual (Edition 3, March 2020)
sets out at paragraph 6.26
Section 64(2) of the 2004 Act specifically provides that an LPA must not
submit an LDP unless it considers the plan is ready for examination. This
means that ‘unsound’ plans should not be submitted for examination. The
LPA will need to demonstrate that the plan meets the three tests of
soundness set out in Table 27.
4.2 Parc Emlyn submit that the Deposit Plan as currently set out does not meet
the second test of soundness. The Deposit Plan is not appropriate because
• the rationale behind the plan’s policy has not been demonstrated
• real alternatives have not been properly considered
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• it is not logical and reasonable.
This is explained in more detail below.
4.3 The rationale behind the plan’s policy has not been demonstrated,
specifically, the Council has not demonstrated why only part of the area
should be allocated.
4.4 The Site Assessment Table 2023 presents in summary format the results of
the candidate site assessment process. Emlyn Brickworks appears on page
44, where under the comments column it says, ‘There are concerns regarding
the deliverability of the whole site, and so it is considered appropriate to
allocate part of the site for mixed use.’
4.5 More detail is to be found in the Site Allocation Assessments (Cluster 3)
document (Feb 2023). The pages are not numbered. The assessment of
Emlyn Brickworks starts on the 191st page. At the end of the 195th page there
is an ‘Additional Comments’ section at the end of Stage 2b of the assessment.
In these comments it says, ‘Given that the site has been previously allocated
with only a small portion of the previous allocation being developed, it is
considered more realistic that a smaller area of the site is carried forward into
the revised LDP which would be more manageable to develop.’ During the
Stage 2b assessment, at questions 28 and 29, the Council has scored the site
negatively in response to the questions on deliverability, viability and timing.
4.6 Although not explicitly mentioned in the Assessment, by proposing to allocate
only part of the site the Council also reduce the number of homes it expects
the allocation to deliver during the plan period, and it presumes they will be
delivered in the final third of the period. It is not unreasonable to see how this
approach is more robust within the overall housing delivery strategy the
Council must set out. Many other parties will seek, for various reasons, to
argue the Council strategy is unsound because it has been unrealistic in the
rate of delivery it has set out for various sites. Seen from this perspective and
with little information to support an expectation of a higher or earlier rate of
housing delivery, the approach of the Council is not unreasonable. Indeed,
Parc Emlyn support the position the Council has set out in respect of the rate
and timing of housing delivery for the site (PrC3MU1), in draft policy HOM1:
Housing Allocations, and consider it to be sound.
4.7 The above offers the only apparent explanation behind the decision by the
Council to propose the allocation of just part of the site. However, it is not an
adequate explanation, in that it is not necessary to reduce the amount of land
allocated in order to arrive at the rate and timing of delivery set down in draft
policy HOM1. The comments set out in the Site Assessment explain and
justify the approach taken to the rate and timing of delivery but not the
reduction in the area to be allocated. Furthermore, nor does it explain why the
policy defined settlement boundary line should also be changed, from that
shown in the current Local Plan, to the much reduced area shown in the
Deposit Plan.
PED – Site PrC3/MU1 – Emlyn Brickworks
PED – Representations on Second Deposit Plan 7
4.8 The Council has not properly considered real alternatives, specifically, the
Council did not properly consider allocating the whole site. The Site
Assessment does not report there having been any consideration of the
option to maintain the extent of the site allocation area (as per the current
Local Plan) but with the rate and timing of delivery as given in draft policy
HOM1.
4.9 The Council approach has not been logical and reasonable, specifically, the
choice about which part of Emlyn Brickworks to include in the allocation is
flawed. The extent of the area put forward by the Council is based largely on
the Indicative Master Plan submitted with the candidate site questionnaire in
2018, and partly on the final alignment of the spur link road. However, the
Candidate Site Supporting Statement emphasised, at paragraph 3.0.1, that
the Indicative Master Plan was submitted for illustrative purposes only and
other design solutions for the site could also be reached. Its’ use by the
Council to identify a smaller area of land to allocate for development is
therefore directly contrary to the purpose for which the Plan was produced.
4.10 Neither the Indicative Master Plan nor the Candidate Site Supporting
Statement suggest the area shown in greater detail on the Indicative Master
Plan would be or should be the first area to be brought forward for
development. Part of the site was shown in greater detail only for the purpose
of providing an indication of the proposed density of the scheme.
4.11 The Indicative Master Plan should not have been used by the Council to
identify a smaller area of land for allocation. The Indicative Master Plan does
not provide either a logical or reasonable basis for identifying the location and
extent of the area of land proposed for allocation in the Deposit Plan.
4.12 The Council therefore has not demonstrated that there is a rationale behind
allocating only part of the site put forward in the candidate site submission, it
has not shown it properly considered real alternatives and there is no logical
or reasonable basis for the location and extent of the area is has proposed to
allocate.
5. HOW THE PLAN CAN BE MADE SOUND
5.1 It is submitted that the Deposit Plan can be made sound with only a minor
modification to the details of the Plan. Within the structure of the Examination
process, this is formally to propose a site allocation but in practice all that is
proposed is that the remainder of the land under the ownership and control of
Parc Emlyn be included. This would be given effect by amending the Proposal
Map so the extent of the allocation and or the policy defined settlement
boundary line match the extent of the coloured areas on the accompanying
Initial Masterplan.
5.2 The rationale for making this change rests primarily on the principle that the
best judge of which part of the site (south of the spur link road) to first bring
PED – Site PrC3/MU1 – Emlyn Brickworks
PED – Representations on Second Deposit Plan 8
forward for development, is the developer, with that judgement mediated
through the development management process (including pre-application
consultation and engagement). This will allow for the proper planning of the
area as a whole to be considered, so that a comprehensive approach can be
taken that is not constrained by an arbitrary sub-division of the site.
5.3 This point is illustrated by the Tetra Tech Site Review, into the contamination
and stability of the ground across the site. Figure 3 from the Review, the Site
Constraints Plan, shows for example those parts of the site not suitable for
development until residual risks are further managed by investigation or
treatment. This information needs to be reviewed in the context of further
studies into, for example, ecology, public open space requirements and how
to create a sustainable urban drainage solution. As a result, the costs of
developing this area might marry with objectives for creating new green
infrastructure across the site, and suggest some or all of that area be
provided as green and public open space. At this stage, it is too early to say.
Allocating the whole site will allow for such issues to be investigated, debated
and decided in a comprehensive way. This is far more likely to be conducive
to the proper planning of the site.
The planning merits of allocating the whole site
5.4 The Site Assessment Table 2023 provides a summary of the analysis by the
Council of each candidate site submitted to them for consideration. Full detail
of the site assessment for Emlyn Brickworks is provided in the Site Allocation
Assessments (Cluster 3) document (Feb 2023) (‘the site assessment’). The
approach take by the Council to the assessments is explained in the Site
Assessment Methodology (Sep 2022) (‘the SAM’).
5.5 The assessment considered all the land Parc Emlyn seeks to have included,
against stages 1, 2a and 2b. At the end of stage 2b the Council decided to
take forward only part of the site for assessment against stage 3.
5.6 In passing stage 1, the whole of the candidate site as submitted was found to
be compatible against the location of future growth presented in the Preferred
Strategy (highlighted green: see site assessment question 1 and section 3 of
the SAM).
5.7 In passing stage 2a, the whole of the candidate site as submitted was found
to have no site based major constraints, that is
• it could accommodate five or more dwellings (see site assessment
question 2 and paragraphs 4.7 and 4.8 of the SAM)
• it is, in this case, directly related to an identified settlement in Tiers 1-3 of
the LDP Preferred Strategy, meaning, it is physically, functionally, and
visually linked to the settlement (see site assessment question 3 and
paragraphs 4.9 and 4.10 of the SAM)
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PED – Representations on Second Deposit Plan 9
• it is not located within a flood risk zone (see site assessment question 4
and paragraphs 4.13 and 4.14 of the SAM)
• it is not located within or immediately adjacent to any sites for importance
to nature conservation (see site assessment question 5 and paragraph
4.15 of the SAM), and
• it is not located within or immediately adjacent to any Scheduled
Monuments (see site assessment question 3 and paragraph 4.17 of the
SAM).
5.8 In passing most of stage 2b, the whole of the candidate site as submitted was
found to have no other site constraints, that is
• development will be in accordance with general planning principles (see
site assessment question 7 and paragraphs 19 and 20 of the SAM)
• development will not have a detrimental impact on the character and
setting of the settlement or its features (see site assessment question 8
and paragraph 4.21 of the SAM)
• development will involve the re-use of suitable previously developed land
(see site assessment question 9 and paragraph 4.22 of the SAM)
• development will be accessible from the existing public highway, from an
available access point with adequate visibility, with no significant highway
issues having been identified (see site assessment questions 10, 11 and
12 and paragraphs 4.23 to 4.26 of the SAM)
• development will have suitable access to public transport and active travel
routes (see site assessment question 13 and paragraph 4.27 of the SAM)
• development will have access to green space, leisure and recreational
facilities within a reasonable distance (see site assessment question 14
and paragraph 4.28 of the SAM)
• development will be in close proximity to employment and retail provision
and to other services and facilities (see site assessment question 15 and
paragraph 4.29 of the SAM)
• development will be within a reasonable distance to education facilities
(see site assessment question 16 and paragraph 4.30 of the SAM)
• development will not be within or adjacent to a mineral buffer zone (see
site assessment question 17 and paragraph 4.31 of the SAM)
• development will be within a Mineral Safeguarding Zone, for sandstone,
but the mineral resource is largely sterilised because it is within 200m of
sensitive development (housing) (see site assessment question 17,
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paragraph 4.32 of the SAM and the top of the 194th page of the site
assessment)
• development will not be within or immediately adjacent to an Air Quality
Management Area (see site assessment question 19 and paragraphs
4.33 and 4.34 of the SAM)
• development will be within an area which geologically contains high
carbon soil but it does not contain boglands and mitigative policies set out
within the Deposit Plan are expected to address the potentially negative
effects (see site assessment question 20, paragraph 4.35 of the SAM and
the 196th page of the site assessment)
• development will not include any high quality agricultural land (see site
assessment question 21 and paragraph 4.36 of the SAM)
• development will not be located within or immediately adjacent to any
Regionally Important Geological and Geomorphological Sites (see site
assessment question 22 and paragraph 4.37 of the SAM
• delivery of the development is not impacted by an elevated risk of flooding
(see site assessment question 23 and paragraphs 4.39 to 4.40 of the
SAM)
• development will have access to an available water connection (see site
assessment question Q24 and paragraph 4.41 of the SAM)
• development will not be within or adjacent to a phosphate sensitive (SAC)
catchment (see site assessment question 25 and paragraphs 4.42 to 4.45
of the SAM)
• development has connections to other infrastructure (see site assessment
question 26 and paragraph 4.47 of the SAM), and
• development will not have a detrimental impact on Welsh Language (see
site assessment question 27 and paragraphs 4.47 and 4.48 of the SAM).
5.9 Further to the reference above to peat deposits, the Tetra Tech Site Review
confirmed the British Geological Survey shows peat deposits are expected
within and adjacent to the site area. Ground investigations have confirmed
peat deposits underly part of the site (see geology section of Executive
Summary to the Tetra Tech Site Review). The survey mapping indicates peat
deposits lie across the northern and western areas of the site (see section
3.1.1 on page 9 of the Review, and the map on appendix page 78 to Appendix
B (Groundsure Report), of the Review). This deposit straddles both the areas
allocated and not allocated for development by the Council. It can therefore
be concluded that neither the presence or absence of peat deposits has been
or should be a factor in the inclusion or exclusion of land when deciding the
extent of the allocation at Emlyn Brickworks.
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PED – Representations on Second Deposit Plan 11
5.10 In conclusion therefore, the stage 2b assessment found no site constraints
which would make its development undeliverable and it is a reasonable site
both for inclusion with the development limits of the settlement and for
allocation for development (see paragraphs 4.2 and 2.1 of the SAM). This is
also consistent with the allocation of the whole site for development in the
current Local Plan.
5.11 The Council explain in the comments at the end of stage 2b why the whole
site did not go forward to stage 3. In summary, it was because of what they
felt to be a lack of progress. However, this explanation does not give due
weight to the planning history of the site
• substantial earthworks have taken place to ready the site for development
• Phase I, while only a modest scheme, was built out
• the responsibility for the time taken to reach a conclusion on the
application on Phase II, for 70 units, does not rest solely with the
landowner, and
• the spur link road has been completed and opened, providing new means
of access to the majority of the site.
5.12 Investor confidence to move forward with proposals for the remainder of the
site will be boosted when the planning permission is issued for Phase II.
5.13 Council comments at the end of the stage 2b assessment also refer to
potential remediation costs. Remediation work was undertaken as part of the
earthworks operation. While some further work will be needed to demonstrate
compliance with current standards, there are no grounds to suggest this
merits the special mention given in the Council comments. The Tetra Tech
Site Review provides a comprehensive assessment of work undertaken to
date and sets out conclusions and recommendations for further work (in
section 11, starting on page 52). The scope of that work is not unusual and is
no impediment to the delivery of a comprehensive scheme of development
across the site.
5.14 The Welsh Government Development Plans Manual (Edition 3, March 2020)
sets out at paragraph 5.20 (page 99) that the use of settlement boundaries on
the Proposals Map should make a clear distinction for plan users as to where
development is acceptable or not. The land Parc Emlyn wish to see ‘added’ to
the draft allocation is presently allocated for development in the current Local
Plan. This in itself speaks to the site being judged acceptable, on its planning
merits, for development. The assessment of the planning merits of the site
against the issues set out in stages 1, 2a and 2b of the site assessment
methodology shows that it continues to be an appropriate and acceptable
location for development. The assessment undertaken by the Council did not
identify any site constraints which would suggest otherwise and nor has the
Council otherwise identified any grounds for seeking to constrain growth at
this location (see paragraph 5.21 of the Manual). Independent of any matters
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relating the extent of the land to be allocated for development, there are no
grounds to justify a more tightly drawn settlement boundary at this location, as
the Council has proposed, and instead the boundary should remain as shown
in the current Local Plan.
6. SUSTAINABILITY APPRAISAL
6.1 Only that part of the site the Council proposed to allocate was subject to
Stage 3, the integrated sustainability appraisal. The following therefore looks
at the remainder of the area Parc Emlyn wish to see included in the allocation,
and considers it against the criteria in stage 3 of the site assessment
(integrated sustainability appraisal and habitat regulation assessment).
6.2 The Council produced an ‘Integrated Sustainability Appraisal – guide for
promoters of sites for development (Feb 2023) (‘the ISA Guide’). This asks
those promoting sites for allocation to complete a site assessment proforma
(at section 3). This proforma sets out exactly the same questions asked in
stages 1, 2a and 2b of the candidate site assessment. The whole of the
candidate site at Emlyn Brickworks, including the part Parc Emlyn want added
to the allocation, has already been assessed, by the Council, against those
questions in the Site Allocation Assessments (Cluster 3) document (Feb
2023). The latter provides the answers to the questions the proforma asks,
and therefore there is no need to repeat the exercise.
6.3 The proforma in the ISA Guide shows which of the questions, in the site
assessment, cross-reference to the Integrated Sustainability Appraisal
Objectives (‘ISA Objectives’). The Council gave a ‘score’ (‘the ISA score’)
against each ISA Objective, based on the response to the site assessment
question. On the basis the answers to the questions in site assessment
stages 1, 2a and 2b are the same for the whole site as they are for the part
the Council went on to assess against the ISA Objectives, the ISA scores for
the whole site will be the same as for the part the Council has already scored.
Again, therefore, there is no need to repeat the exercise. The findings will be
as set out in the Site Allocation Assessments (Cluster 3) document (Feb
2023).
7. CONCLUSIONS
7.1 The Deposit Plan as currently set out does not meet the second test of
soundness. This is because
• the rationale behind the decision to allocate only part of the candidate site
has not been demonstrated
• real alternatives, namely allocating the whole site, with the same rate and
timing of delivery, has not been properly considered, and
PED – Site PrC3/MU1 – Emlyn Brickworks
PED – Representations on Second Deposit Plan 13
• the way in which the candidate site has been divided, so only part is
advanced for allocation, is not logical or reasonable because it is based
on information which was not produced with the intention of informing
such a decision.
7.2 The Plan can be made sound by including all of the land owned by Parc
Emlyn, as shown on the Initial Masterplan, within the site allocation. This will
allow for a comprehensive approach to the proper planning of the area to be
dealt with through the development management process, without undue
constraint. In addition, or alternatively, the settlement boundary line should be
retained as shown in the current Local Plan.
7.3 The whole of the candidate site has been assessed as deliverable and the
part of the site not included in the proposed allocation has the same ISA
Score as the part that is. There is no reason not to allocate the whole site, and
indeed, given its planning merits, there is good reason to do so.
7.4 Parc Emlyn support the position of the Council with regard to the number and
timing of the delivery of new homes during the Plan period. Parc Emlyn are
not seeking to suggest the site will deliver more homes than the Council have
forecast during the plan period. Notwithstanding that, given the planning
merits of the whole site, no harm would arise if the site were to prove capable
of delivering more homes than is forecast during the plan period, or if it started
delivering homes sooner than anticipated. If it did not, it is not unreasonable to
expect the undeveloped portion would come forward during the following plan
period.
7.5 The Candidate Site Assessment concluded that, ‘The site presents an
opportunity to regenerate or redevelop a previously developed site’. That
opportunity remains and should continue to be made available.
7.6 The Examination Inspector is therefore respectfully requested to find the
Deposit Plan is not sound as currently presented and to invite the Council to
seek to make a minor modification by amending, as described above, the site
allocation and settlement boundary line on the Proposals Map.

Include the site within the development limits for Ffynnonddrain, Carmarthen.

This representation objects to the exclusion of this site from the development limits for Ffynnonddrain. Its inclusion would not lead to additional environmental pressure, but instead will foster 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 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.
The inclusion of this land within revised development limits would be fully supported.

Change to the Plan to include the site.

This representation comprises an objection to the exclusion of this areas of land from the development limits for Tumble – part of the designated Tier 1 Cross Hands Principal Centre.
The delineation of this area of land and its allocation will reinforce the settlement pattern and provide certainty for future growth and investment. The proposer’s land is both sustainable and readily deliverable.
The site’s 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 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.
The inclusion of this land within revised development limits should be fully supported.

Inclusion of site within the development limits.

This representation objects to the exclusion of this site and surrounding development from the development limits for Llanddarog - Tier 3 Sustainable Village. Its inclusion would not lead to additional environmental pressure, but instead will foster 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 deliverable source of future housing for this sustainable community.
There is considerable investment in an equine enterprise within this cluster which will give rise to job creation and further investment. The delineation of development limits will provide certainty in land use terms for future investment decisions.
In addition, providing the opportunity for 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.
It is considered that this site is both sustainable and deliverable and offers a valuable development option within this Tier 3 Sustainable Village.
The inclusion of this land as an ‘outlier’ as part of the Llanddarog settlement within revised development limits would be fully supported.

Include the site within the Plan.

This representation objects to the exclusion of this site from the development limits for Carmarthen. 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.

Exclude the land from the development limits.

I would like to object to the inclusion of land detailed (highlighted in orange) of attached map (M1) for SA44 5YF area Rose Villa
The reasons are:
Environmental Land, this is not a plot but an area of woodland which has a pig sty and until the new owners moved to Rose Villa had an old caravan for storage. This was replaced by a much larger caravan and a parking area for one car. Much habitat and wild flowers exist in this area. Over the years much development has been completed by Rose Villa.
Conservation – this area is of scientific interest due to rare brown hairstreak butterfly monitored by the Butterfly Conservation at winter. Rare ferns and plants such as native primroses, wild roses, native daffodils exist at this parcel of land some already lost due to hedge at the front of this plot removed.
Access – Access to the land is not via a main tarmacced road, it is a narrow farm lane leading to 4 other properties. Any further traffic could cause dangers to walkers on the dedicated footpath or accidents to other residents along this lane. No one maintains this road except us over the last 30 years with evidence of repairs and maintenance. The road has gone into disrepair over the last couple of years with huge amount of traffic using it. Only this week we completed maintenance on some parts but due to the traffic now back to normal with very deep potholes.
This will create additional noise in what was a very peaceful beautiful valley. Currently with lots of trees, this will spoil the character of a beautiful conservation area.
River nearby – there are 2 rivers running alongside this woodland, one directly behind and when it rains the levels raise very quickly and flooding occurs if debris is not cleared further downstream.
Traffic – If planning is granted, this will generate more traffic, this road cannot take more traffic or any parking on the lane.
Ruin – This ruin is an old pigsty and not a cottage.
Road Condition – The road is in a very poor
Ownership of the road and grass verge - The owners of Rose Villa do not own this road, nor the grass verge.
Footpath - It has a registered footpath down the lane and many walkers use it. It is a highway maintained by public monies for the footpath only. There is nothing that ties owners of the properties to maintain the lane. We have maintained the lane for 28 years with no financial support from any of the dwellings using the land, we have full evidence of this.
If planning was granted it would have an overbearing impact on the surrounding lane and beautiful peaceful walk which would be spoilt forever.
Ancient Woodland - Loss of trees forever. Houses bats.
Access to Main Road – The entrance to the main road is on top of a brow and with more traffic approaching the B Road, would give great concerns to access and eggress.

Amend Plan to include the site.

I would like to request the areas highlighted in orange on the Appendix map 1 and 2 be included on the new Policy SDI – Development limits. For additional housing to address the need for new housing for maximum 3 houses 1 being affordable housing.

Amend Plan to include the site

Context of Representation

The representation relates to the designation of the land to the rear of Lower Trostre Road, Llanelli.
The existing Local Development Plan (2006 - 2021) positions the site within the defined settlement limit.
The revised Local Development Plan (2018 - 2033), positions the site outside of the defined settlement limit.

Requested Change and Rationale

This representation simply requests that the settlement limit defined within the extant Local Development Plan is replicated within the revised version. It is considered that the area in question forms part of the urban area rather than a countryside location. The rationale for this is down to the fact that the land is more in keeping with the adjoining settlement, given the existence of a range of dominant and long-established outbuildings, which are intrinsically linked with the adjoining developments and accessed via existing highway infrastructure. The land is also used and maintained as garden space for well over the last decade and as such is fenced off to clearly differentiate from the open countryside.

Furthermore, authorised works undertaken to support current land uses on the wider site (such as the equestrian manège and stables) have further established the land as being part of the urban area within the settlement hierarchy. There is a distinct differential between this area and the wider countryside, especially in terms of site levels, character and land uses. It is considered that this was acknowledged in the designation within the extant Local Development Plan, subsequently reinforced by planning approvals attained on the land (stable block), which makes the proposed change in the revised Plan highly questionable and the rationale for its exclusion unsubstantiated.

I would urge that the proposed change is supported by the Council and would welcome the opportunity to review the above considerations via a site visit. Should you require further information, then I will be more than happy to provide it to inform the review process.

To supplement the commentary made above, I have set out below a range of photographs for your consideration:

Photograph 1: Captures the urban setting of the land, with highway access, defined boundaries and a collection of established buildings.

Photograph 2: Highlights the questionable proposed settlement boundary. Properties on the right are within, whilst the left side compound, the highway itself and the building ahead are outside.

Photograph 3: A collection of substantial buildings have been on the site for a number of years and are directly accessed from the adjoining highway.

Photograph 4: The land includes a recently constructed stable block, along with a landscaped and maintained garden space, totally detached and distinct from the adjoining wider open countryside.

Amend the Plan to include the site within limits.

We would like the Authority and the Planning Inspector to re-think its reason for not including this land and urge them to re-read our submitted evidence with our first submission.

Candidate site report:

1. Introduction
This report has been prepared in support for the inclusion of land which is part of the farm holding known as ‘Tan y Graig’ which is located in area known as Felinfoel which is within the settlement of Llanelli.
2. Site Details
The potential candidate site is located on the edge of the settlement of Llanelli. The site currently adjoins the settlement boundary of Llanelli. The land currently is used for pasture by the proposer of this site. There are currently no structures or buildings within the parcel of land. The site is located along the proposer’s property of Tan y Graig.
3. Proposed Use of the Site and it’s Deliverability
The site is proposed to be allocated for residential housing purposes. It is the aim of the land owner to provide a housing site for around 3-5 dwellings for local people. It is aimed that once this land is allocated for housing and included within the settlement boundary for Llanelli that a full planning application is prepared and submitted to Carmarthenshire County Council. The aim is to provide housing for local people within the area.
4. Site Assessment Methodology
The site is a relatively flat site that would be bale to accommodate housing without producing a visual impact on the local and wider area. The site is a greenfield site with no history or evidence of past activities which would have resulted in the contamination of any soils. The land is located within a High Risk Coal area, however a risk assessment would be produced and presented as part of any planning application to ensure that any development would not cause an adverse impact on this. The land is currently located within an area of special landscape as defined by the current Local Development Plan. Any development undertaken within this area would be designed to enhance and improve the character of the area and not cause any impact. The land is located within a High Specification Aggregate of Sandstone and Igneous Rock and area of Category 2 Aggregates Safeguarding for Sand and Gravel. The proposed development would be designed with this in consideration. An appropriate report would be produced as part of any planning application to ensure that there is no impact.
Aled Thomas Planning Design Ltd
The site is located in fairly close proximity to river, however having checked the Natural Resources Wales Flooding Maps, the proposed land does not fall within a flood zone. Therefore any development within this area would not increase the likelihood of flooding in extreme weather. In regards to the disposal of surface water, the site is sufficiently large enough to accommodate the provision of soakaways within good ground conditions, which will be able to drain freely with no signs of waterlogging or standing water.
The village is lucky to benefit from the provision of a public sewerage system, mains water supply and electricity. It would be possible to connect to the foul sewerage system through gravity linking into the sewer which is located within the public highway. If there are any capacity issues, this could be remedied by providing private sewerage system such as septic tanks or sustainable drainage systems. Accesses to all other services are readily available and would be easily accessible to any new development within the area.
A public footpath runs along the former railway track that adjoins the proposers’ land. Any development on this site would involve the retention of the hedgerow and trees that run along the site boundary to partially screen the development from the surrounding area. There is no current evidence of any current habitats or protected species within the site. Given its nature, prior to the submission of any planning application an ecological assessment would be undertaken to ensure there would be no adverse loss or impact on the current habitat.
5. Viability of the Site
The viability of the site is imminent. As previously mentioned the land owner intends to submit a planning application on this site as soon it is adopted and included within the settlement boundary of Llanelli.
6. Accessibility
Aled Thomas Planning Design Ltd
The site can be accessed from the existing property of Tan y Graig. This would be adequate to provide regular vehicle use and would have the provision to be widened to provide a footway as required. Visibility splays to comply with current standards from vehicles emerging onto the public highway are good in both directions. The highways itself would provide more than adequate viewing availability in and out of the new access point.
7. Sustainability
The potential candidate site is immediately adjacent to the settlement limit as identified and defined by the Local Development Plan. The extension to the settlement limit at this location would provide an appropriate location for rounding off the settlement boundary to provide much required residential properties within the area.
Llanelli and Felinfoel are served by good public transport bus services which operate through the village, with a bus stop located in close proximity. Bus routes provide links to Carmarthen and Swansea. There are good cycle facilities to surrounding settlements, and there is also an extensive footpath network available within the locality.
There are many facilities available within the village such as a community hall, a church, a chapel, an extensive range of facilities, such as shops, offices, industrial units, community facilities, medial and pharmacy facilities.
8. Conclusion
In conclusion, this site is believed to be a perfect site for inclusion within the Local Development Plan to allow for further residential properties within the locality for local people.

Amend Plan to include site within limits

Carmarthenshire Local Development Plan 2018-2033 – Deposit Draft
Objection to Policy SD1 on behalf of Evans Banks Planning Ltd

Further to the publication of the above document, we have been asked by our Clients to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so we consider it necessary to
make a formal representation to the “soundness” of the Carmarthenshire Deposit Local
Development Plan, including in relation to the provisions of part of Policy SD1 (Development
Limits). As a result, we offer the following for the Authority’s consideration, and Inspector’s in
due course.

Through the provisions of Policy SD1, ‘development limits’ have been defined for all
settlements within Tiers 1, 2 and 3 of the Settlement Framework. The Policy then sets out
that “Proposals within defined Development Limits will be permitted, subject to policies and
proposals of this Plan, national policies and other material planning considerations.”.

The Policy’s supporting text goes on to set out four situations that have influenced how the
proposed development limits have been set, with the first reading as follows: “Prevent
inappropriate development in the countryside and provide certainty and clarity as to where
exceptions proposals (adjacent to limits) may be considered appropriate;”. In order to ensure
‘certainty’ and ‘clarity’ from the Policy (and in turn ‘soundness of the Plan), there is an
assumption that all settlement limits have been drawn correctly and logically. However, as
has been seen from the numerous submissions made as part of the current consultation process with regards to the proposed settlement limits, this is not the case.
The submissions made on behalf of our Clients with regards to Policy SD1 and specific areas of land, and those made by other parties, highlights that the level of ‘clarity’ and ‘certainty – and indeed confidence – that Policy SD1 has sought to secure, has not been achieved.

The submissions highlight that residential gardens (as a whole or in part), natural infill plots and often domestic outbuildings have been illogically excluded from proposed settlement limits and in doing so, labelling them ‘open countryside’. As the aforementioned submissions clearly show, these areas of land and buildings are certainly not part of the ‘open countryside’ nor do they share their characteristics, and so should in fact be included within the defined development limits. However, under the current wording of Policy SD1 the above situations will in turn create confusion, with areas that quite clearly form a logical part of a settlement, in fact being defined by Policy SD1 as lying outside of it.

In order to secure greater consistency and clarity, it is proposed that Policy SD1 should be amended – either as part of its core text or supporting text – to allow for a ‘case by case’ assessment of the suitability of small areas of land or property for development at ‘edge of settlement’ locations. It is proposed that this could be done by including the same form of locational criteria as used by Policy HOM3, which are as follows:

• minor infill of a small gap between the existing built form; or,
• logical extensions and/or rounding off of the development pattern that fits in with the character of the settlement form and landscape; or
• conversion or the sub-division of large dwellings.

The above would then ensure that all edge of settlement locations with regards to appropriate development are assessed in a consistent and clear manner, compensating for any such instances that the Deposit Plan has done so in an erroneous manner.

We therefore respectfully request that this Representation be given careful examination, and that the above wording and provision should be included as part of Policy SD1 to ensure that the Plan adheres to the requirements of all three Tests of Soundness.

The development limits in this area should remain as drawn in the LDP 2006-2021.

See comments at start of rep.

Include the site within the Plan

This representation objects to the exclusion of this site from the development limits for Burry Port. The inclusion of the proposer’s land would make full and efficient use of a small area of urban land in the northern part of Burry Port. It would provide a valuable modest size developable area in contrast to the large scale allocations elsewhere in the town. 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 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 both more sustainable and deliverable than other sites that have been allocated within Burry Port.

The inclusion of this land within revised development limits would be fully supported.

Dim byd yn cael ei ddatgan

Nothing stated

Annwyl Reolwr,
Mae 2 argymhelliad ar gyfer pentref Porth—y-rhyd ac ymatebaf yn gryno iddynt isod.

1. Newid y ffin i gynnwys y tir ger Ty Cynheidre ar gyfer ei ddatblygu.

Yn anfiodus, nid oes manylion ar gael ar yr adeg hon yn y broses parthed y math o ddatblygiad, ei faint, nifer tai, math o dai ayyb.

O ganlyniad nid oes dewis gennyf ond GWRTHWYNEBU. Gofynnaf yn garedig am gael cyfle i ymateb eto unwaith y bydd manylion ar gael i'r cyhoedd am y cynlluniau ar gyfer y
tir hwn.

2. SuV20/h1 — tir ger Fferm Llwyn Henri
Rwy'n gwrthwynebu am y rhesymau canlynol:

Nid oes manylion ar gael i‘r cyhoedd ar yr adeg hon yn y broses parthed y math o ddatblygiad nac ychwaith nifer y tai. Mae'r 5+ braidd yn amwys a gwyddom o'r gorau sut
all y niferoedd chwyddo. (e.e. Lovells 32 - 52 a safle arfaethedig Wernfraith 27 - 42 ).

Gwrthodwyd y safle hwn yn y gorffennol yn dilyn misoedd lawer o gynnal profion ac asesiadau gwahanol, o ymgynghori gyda‘r asiantaethau perthnasol ac o goladu ffeiliau o dystiolaeth o amrywiol ffynonellau.
Gwrthod oedd barn yr Ymgynghorydd Cynllunjo annibynnol ar y pryd. Gwrthod oedd argymhelliad yr Adran Blaen-gynllunio. Gwrthod oedd dyfarniad yr Arolygydd Annibynnol yn dilyn Gwrandawiad Cyhoeddus a dyna oedd‘penderfyniad y Cyngor Sir yn seiliedig ar broses cadarn a rhesymegol.

Rwy‘n llwyr barchu hawl yr Ymgeisydd i ail gyflwyno'r safle ond er i'r cae gael ei docio y tro hwn mac rhannau ohono yn dal o fewn Parthau Llifogydd C2 a B ac njd yw newid
lleoliad mynedfa yn cael gwared o’r holl rwystrau ac ardrawiadau dwys eraill.

Mae prif bibell ddwr yn agos i‘r cae. Hyd yma ni dderbyniais ateb i gwestiwn syml:

Faint o le sydd angen ei gadw‘n glir o boptu'r bibell fel clustogfa neu Goridor Diogelwch rhag datblygiad?

Mae llawer o broblemau dwys dwr glaw a'r system garthffosiaeth. Teimlaf yn aml bod y drol
yn cael ei roi o flaen y ceffyl. Oni ddylid uwchraddio'r isadeiledd cyn caniatau datblygiadau.
Fel arall gall yr ardrawiad fod yn hunllefus fel y gwelwyd eisoes yn y pentref hwn.

Cofrestraf fy ngwrthwynebiad i ddyrannu'r cae hwn yn y Cynllun Datblygu Lleol Diwygiedig 2018-2033 a dymunaf siarad yn Gymraeg mewn sesiwn gwrandawiad yr
Archwiliad Cyhoeddus.

3. SAFLE WERNFRAITH
Rhyddhad yn wir oedd gweld bod y safle hwn wedi cael ei ddad-ddyrannu ac na fydd yn cael ei gynnwys yn y fersiwn diwygiedig o'r CDLI 2018 - 2033.

Yn anffodus, mae risg y caiff ei goncritio gyda datblygiad o 42 o anheddau ymhell cyn i'r CCDLI hwn ddod i rym ac y bydd yn cael ei gategoreiddio fel un o'r Hap-safleoedd.
Rhyfedd o fyd!
Yn gywir,
Mair Evans

Dear Manager,

There are 2 recommendations for the village of Porth-y-rhyd to which I will respond briefly below.

1. Change the boundary to include the land adjacent to Tŷ Cynheidre for development.

Unfortunately, no details are available at this point in the process regarding the type of development, its size, number of houses, type of houses etc.

As a result, I have no option but to OBJECT. I kindly ask for an opportunity to respond again once details are made available to the public concerning the plans for this land.

2. SuV20/h1 — land adjacent to Llwynhenry Farm

I object for the following reasons:

There are no details available to the public at this point in the process regarding the type of development nor the number of houses. 5+ is rather vague and we know full well how the numbers can increase (e.g. Lovells 32 - 52 and the proposed Wernfraith site 27 - 42 ).

This site has been rejected in the past following many months of conducting different tests and assessments, consulting the relevant agencies and collating files of evidence from various sources.

The opinion of the independent Planning Consultant at the time was to Object. The recommendation of the Forward Planning Department was to Object. The Independent Inspector's ruling following a Public Hearing was to Object, and that was the County Council's decision based on a sound and rational process.

I fully respect the Applicant's right to resubmit the site but although the field was made smaller this time parts of it are still within Flood Zones C2 and B and changing the location of an entrance does not remove all the other serious obstructions and impacts.

There is a water main close to the field. Thus far I have not received an answer to a simple question:
How much space needs to be kept clear around the pipe as a buffer zone or Safety Corridor from development?

There are many serious problems in terms of rainwater and the sewerage system. I often feel that the cart is being put before the horse. Should not the infrastructure be upgraded before development is allowed.
Otherwise, the impact can be terrible as already seen in this village.
I register my opposition to the allocation of this field in the Revised Local Development Plan 2018-2033 and wish to speak in Welsh at a Public Examination hearing session.

3. WERNFRAITH SITE
What a relief to see that this site has been de-allocated and that it will not be included in the revised version of the LDP 2018 - 2033.
Unfortunately, there is a risk that it will be concreted over with a development of 42 dwellings long before this LDP comes into force and that it will be categorised as one of the windfall sites.
Strange indeed!

Regards,
Mair Evans

Include site within the Plan

Please see Supporting Statement. The statement discusses a minor extension of the proposed development limits of Horeb in order to accommodate a modest form of development, i.e. 4 detached dwellings. This will not therefore go to the heart of the Plan or have a bearing on the soundness of the Plan as a whole. A development of this scale would complement the existing settlement, representing proportional growth in a controlled manner along with a clear rounding off of the settlement. Policy SD1 is objected to on the basis that the development limits of Five Roads/Horeb should be extended to include the site.

Include site within Plan

This consultation response seeks to include a small area of land (~0.1 hectare) between Brynglas and an existing agricultural building by aligning the development limits of Cwmffrwd with the rear curtilage of dwellings that form Llaingotten Terace.
Such an adjustment would neatly square-off the development limits of the village.
The proposed development limit within the draft 2018 to 2033 LDP is not contiguous with the curtilage of Brynglas, Cwmffrwd.
The provision of a housing allocation upon the land adjacent to Brynglas would not adversely effect neighbouring properties as the housing allocation would be at 90 degrees to the dwellings that form Llaingotten Terrace and separated by a Council highway.
A gated entrance already exists and would be used to provide a driveway for the housing allocation and associated off-road parking.
All utilities are available close by.
A housing allocation upon this land would provide a contribution to public finances.

Exclude the above land from development limits and protect from development.

For ease of reference, I have used the reference numbers from the first deposit as well as road names to identify areas that I am commenting on.
I fully support protecting of green space in Tycroes ward. All green spaces within the ward should be protected from development. Access to use these areas for recreational purposes is essential to the community to maintain and improve both physical and mental health well being. Nature is also a vital part of education.
In Tycroes -
Land including the woodland between Heol Brown and Hafod Road, the football field on Heol Brown as well as the land between Number 4 and 6 Heol Brown and to the right of number 8 Heol Brown as you are looking at it from Heol Brown and opposite the entrance to Tirprys (a public footpath runs through it) should be protected from development.
The woodland by Heol Brown park is home to a variety of wildlife e.g. foxes and badgers. Sightings also include a rare butterfly and owls who nest there. Residents state that this land was a gift from the Coal Board to the village of Tycroes to be used for recreational purposes. Residents feel very strongly that this should remain as an area for recreational activities. Access to this area would be from Hafod Road Tycroes which is a narrow lane.
Another consideration is that permission to develop this land would need to be sought from the Coal Board.
Land between Heol Ddu and Teglan Park – Access to this land is off a corner on Heol Ddu and also from Teglan Park. The area is used by children and should also be protected from development. I believe that there is a covenant in place restricting the use of the area to recreational purposes only.

There is a further large area of green open land between Tycroes, Penybank and Pantyffynon. This area has footpaths that are used on a regular basis. Any building on this land would be detrimental to the rural feel of the area currently enjoyed by the residents.
Land known as Cwmfferws Park between Cwmfferws Road and Hendre Road, bordering on to Ammanford Road. This should also be protected from development.

Footpaths within the ward are well used but the council should improve access and make every effort to maintain them. Tycroes has a walking group that meet at least twice a week and use these footpaths.
PrC3/h32
This area of land, currently a greenfield site, is outside the development limits and is not in the current LDP. The land referenced as PrC3/h32 is not one area of land but two separate areas. One half (the land behind Penygarn Road leading to the Rugby Club) already had planning permission for 37 houses which was granted in December 2019. The dwellings have now been built and occupied. This planning permission was approved with the reason given that the need for social housing allowed for an exemption from the County Council’s own policy. This was an exception, not the rule and should not be used to set a precedent to have more development on the other half of the land reference PrC3/h32 behind Tycroes Road (as far as number 69 Tycroes Road and Numbers 5 – 7 in Ffordd Y Deri.
Flooding issues - There is already known flooding issues within the ward. Further development could make matters worse.
Access to the dwellings – Access to the 37 dwellings built on one half of PrC3/h32 is through Ffordd Y Deri off Tycroes Road. Ffordd Y Deri is also a narrow road unsuitable for further traffic. The volume of traffic coming out on to Tycroes Road has increased. It is likely that most households would have two vehicles which will result in a sustained volume of traffic using the road throughout the day.
Ecology and Environment – Bats and Badgers have been sighted here. Bats are a protected species and any disturbance to their natural habitat would be catastrophic for the species. Valuable trees would be at risk should there be any further development.
Education
Tycroes Primary School is full to capacity. Provision of education to extra children is a real concern with some years currently running to full capacity and children already being refused admission.
In conclusion, the amount of houses that have been built is more than sufficient to meet local needs.
Land off Heol Ddu – Previously a factory site and others
This is an area of land situated off an unclassified road known as Heol Ddu. The land is close to Teglan Park a large housing estate leading off from Penygarn Road.
Although the land was used for factories, the land has planning permission for residential properties. Consideration should be given to the type of light industry that would be acceptable there due to the close proximity to Teglan Park.
Access – Heol Ddu is an unclassified road accessed from the A483. The road is not suitable for commercial traffic. The road would need to be improved and SWTRA consulted.
Noise disturbance to nearby dwelling – Close proximity to Teglan Park will in no doubt have an impact on residents quality of life due to noise as well as dust.
Education
Tycroes Primary School is full to capacity. There is room for a small extension, however any further building would impede on the school play areas. Provision of education to extra children is a real concern.
Other general ward observations

Agricultural land - The land in the ward currently used for agriculture should remain as it is. This enhances the rural feel of the ward and provides employment to local residents.

Business and retail parks - The ward is adequately served by a business park to the north of the ward and shops in the centre of Tycroes.

Planning - There is already planning permission for approximately 250 residential dwellings within the ward. This is more than adequate for current and future needs. Any further provision to this number could mean empty properties.
In general residents in the ward feel very strongly that there is that there is no need for further development in the ward. The residents also feel strongly that green field sites should be kept as they are.
Llanedi – The Village Green in front of Y Garreg Llwyd and opposite Tafarn Y Deri.
I request that this area is protected from development. This area is used regularly and has been for many years by children playing and various village groups to hold events such as the one held during the jubilee in 2022.

Include the site within new development limits for Felindre (Llangadog) within the Plan

We would like the Authority and the Planning Inspector to assess the reason
why a settlement boundary has not been provided around this significant
hamlet and further information is required regarding policy HOM4 regarding
what happens when the properties cannot be let or sold as an affordable
property.

Include the site within new development limits for Felindre (Llangadog) within the Plan

We would like the Authority and the Planning Inspector to assess the reason
why a settlement boundary has not been provided around this significant
hamlet and further information is required regarding policy HOM4 regarding
what happens when the properties cannot be let or sold as an affordable
property.

Include the site within new development limits for Felindre (Llangadog) within the Plan

We would like the Authority and the Planning Inspector to assess the reason
why a settlement boundary has not been provided around this significant
hamlet and further information is required regarding policy HOM4 regarding
what happens when the properties cannot be let or sold as an affordable
property.

Include the petrol station and retail park (mcdonalds – greggs) within development limits.

Omission of Business / Retail Park and Petrol Station in Revised 2nd Deposit LDP Off Britannia Terrace, Tenby Road, St Clears, SA33 4JW

This cover letter and supporting documentation is a formal response submission in respect of the 2nd Deposit Revised Plan, which has a deadline of 14th April 2023. This response is made on behalf of land owners Mr John Dyer, Mrs Gwyneth Thomas & Mr John Adam Lewis. This formal response consists of the following documents:

 Cover Letter (this document)
 LDP 2nd Deposit Revised LDP Representation Form
 Drawing L01 - Location & Block Plans for Site Identification at Scale A3 @ 1:2500
 Copies of planning consents PL/00978 & APP/M6825/A/19/3240281 (W/37120)
 Approved Block Plans of PL/00978 & W/37120 for the Business Park & Petrol Station

This representation is deemed a ‘commentary’ rather than an ‘objection’. It is a relatively simple comment and request in that is appears that the LPA has not included the delivery of the Business / Retail Park and Petrol Station at St Clears within this LDP 2 Revised Deposit Plan.

This Business / Retail Park is operating today with McDonald’s and Gregg’s businesses located on this site. Linked to this is an adjacent large Petrol Station, Sales Building and EV Charging Centre (that commenced in Spring 2023 and is expected to be completed within 12 months). The relevant planning consents are W/37120 (appeal allowed on 18th February 2020) and PL/00978 (granted on 14th October 2021).

This development will link into the allocated housing site SeC18/h1 for 60 houses which will use the existing access. This housing site did have a planning approval under W/21675 and will be progressed in the next few years as there is a lot of interest.

Extract of Draft Deposit Revised Local Development Plan (2018-2033), Showing Proposed Allocation of SeC18/h1 at T2/5/h4 (Brittania Terrace). However, adjacent Business / Retail Park is Missing

At a minimum the LDP ordnance survey should be updated on the adopted LDP to follow what has been delivered on site or alternatively the LPA should show it business use within the correct purple shading representing business development.

To help clarify matters we have produced a location and block plan (see attached Drawing L01) to illustrate what was built and in the process of being built and this is scanned below:

Finally, as this is not really an objection or creation of a new site no Test of Soundness Assessment has been undertaken as this is not relevant. All that is required is for the LPA to recognise and include within LDP2 this important, existing, business cluster at St Clears.

An alternative use is proposed for this site - refer to representations 5684 & 5685.

Remove this area from ”housing development” because ofthe difficulty for potential
developers to build roads from Tirycoed Road to the old maternity hospital. This is already a
busy road with old, weight restricted bridges at either end.
Change the listed ground to the west of the old Maternity Hospital from "housing
development" (See red circle on map) because of conservation and access restriction
concerns.
This area qualifies for SINC status given that the rhos pasture and hedges are protected
habitats and the Marsh Fritillary Butterfly is protected under UK law, listed under Schedule
5 of the Wildlife and Countryside Act, and the EU Habitats and Species Directive (Annex II).
I also object to the remaining development site (See purple box on map below) on
conservation grounds and lack of access. These plans have been pushed for a number of
years already and have always been refused. The circumstances have not changed 700
people objected to a housing development on this site under the aegis of both the RLDP and
the current PAC (521.186). (See online petition)
https://www.change.org/p/no-to-the-housing-deveIopment-on-tirycoed and door to door
petition https://thunderbolt.me.uk/Docs/Tirycoed%20Petition%20Redacted.rar
Furthermore actual size of this site would support a great deal more homes than the 25
currently being proposed in PAC 521.186 . However we also object on the understanding
that the current LDP cannot be met on the following grounds:
SP2 Retail and Town Centres
There are no large retail outlets, in Glanamman unless you travel to Ammanford. The Dentist
and GP surgery are oversubscribed, there are no leisure facilities nearby and the local
infrastructure is not able to cope with an influx of housing on this scale. The main road
though Glanamman already struggles to cope with too much traffic causing queues through
the village and consequently fumes from a steady flow of traffic passing through where a lot
of houses are situated very close to the main road.
SP3 Sustainable Distribution — Settlement Framework
There are very few services available in this location and this development would put huge
strain on existing ones. We constantly suffer from disrupted water supplies clue to the
ageing and an inadequate water supply system, which would be overwhelmed by the
additional capacity needed.
SP4 A Sustainable Approach to Providing New Homes
There is not an ”appropriate number” of homes being suggested for this site. Although 25
dwellings are currently being requested, it is very clear that the site has capacity for at least
100. That would be a massive burden on the local infrastructure and facilities. The access
road is not suitable for such volumes of traffic and there are already huge issues with water
supply and drainage which cannot be addressed.
SP9 Infrastructure
Those already living in Tirycoed Rd have already had to pay for the upgrading of their
electricity supply due to its lack of capacity and overall the local infrastructure is very poor.
SP12 Placemaking and Sustainable Places
Placemaking should be holistic and inclusive and rightly be at the heart of any planning
decision. Furthermore any development should; comply with Welsh Government policy on
sustainable places
https://researchsenedd.waleslresearch-articleslmaking-sustainable-places-what-role-can-t
he-planning-system-play/, and take account of the Well-being of Future Generations (Wales)
Act 2015 and be predicated on
-
Making the best use of resources;

-Facilitating accessible and healthy environments;

-Creating and sustaining communities; and

-Maximizing environmental protection and limiting environmental impact.

My concern is that this proposed housing development will fail to meet most of those
expectations. There are dangers that this development will destroy established habitat and
endangered species, it will cause light pollution and it will adversely affect community
cohesion into which it is being placed.
SP13 Rural Development
This proposed site is located in an area of outstanding natural beauty where wildlife
currently thrives. Allowing such a large development on such precious land is absolutely
against current rural development policy
httpszllresearch.senedd.waleslresearch-articleslthe-rural-development-plan-for-walesl
which is predicated on ”the sustainable management of natural resources and climate
action”
SP14 Maintaining and Enhancing the Natural Environment
Housing development will destroy our unique and bio diverse landscape and our protected
habitats and lead to loss of biodiversity. This development will lead to the de-wilding of the
site and the subsequent loss of the Marsh Fritillary Butterfly, Devils Bit Scabious and winter
visitors such as snipe and woodcock.
Devils Bit Scabious- Christian Fischer, CC BY—SA 3.0 <https://creativecommons.org/licenses/by-sa/3.0>, via Wikimedia Commons
Previous planning applications have absolutely failed to address the issue of habitat
destruction (Which the developers have been actively engaged in). Endangered species will
be displaced and lost and riparian corridors will be blocked preventing otters (which are low
in Wales) from travelling.
SP15 Protection and Enhancement of the Built and Historic Environment
The appropriate use of this redundant building is certainly not to allow its demolition and
replacement with a totally unsuitable housing development. Absolutely no consideration
has been given to the wishes of the local community nor the protection of this historic site.
SP16 Climate Change

There has been no carbon audit of potential housing development on this site. It has been
estimated (Drexler et al 2021, NERR094) that the current carbon stocks (rhos pasture,
shrubs and hedges) on the site (ca 2ha) are 220 T C which will be cut by 84.75 T C to 135.25
T C after housing development. The carbon emissions (Berners-Lee 2010) as a result of
development (25 houses plus roads, paths, drives, parking bays) will be approximately 3000
T C02 and there will be a sequestration reduction of 0.125 T C yr (NERR094).

The destruction of Rhos pasture, trees and grassy marsh/and on this site would be an
absolute disaster for the local environment. Paving over huge areas for roads and paths will
create hard standing that will cause rain water to surge onto surrounding roads and
properties, causing flooding. Previous planning applications have had few mitigating
measures for renewable energy, carbon negative building materials or energy conservation
schemes.

SP19 Waste Management

Safeguarding resources would not be achievable if planning permission were granted for this
site. The loss of trees and pasture would contribute to Climate Change while the amount of
carbon that would be released during the construction phase alone would be damaging to
the environment.

Could I request that CCC reclassify the development site as community or public spaceland
refer CCC to your obligations under the aegis of the placemaking guide 2020.
(https://dcfw.org/wp-contentlthemedecfw-child/assets/PIacemakingGuideDigitalENG.pdf)
The importance of community space was highlighted In a recent supreme court ruling -
Hilary Term (2023) UKSC 8 on appeal from (2020) EWCA civ 1751- (R (on the application of
Day) (Appellant) v Shropshire Council (Respondent) (landmarkchambers.co.uk)) where the
court ruled in favour of the local community.

Furthermore the importance of having access to community space was a frequent theme
highlighted in a consultation report on connected communities
https://www.govwales/sites/defaultifiles/consuItations/2019-03/summary-of—responses 2.
@

This site could provide so much benefit if it were used for well-being, conservation and
recreation (given the increasing number of people suffering with mental illnesses maybe a
well-being centre, a conservation area with pond, and board-walks for recreation and
conservation interpretation). This site is adjacent to the most important breeding ground for
the Marsh Fritillary Butterfly in the Amman Valley. Please note CCC’s obligations with
regards to placemaking charter (http://dcfw.org/placemaking/placemaking-charted) to
provide spaces to promote prosperity, health, happiness, and well-being in the widest
sense.
This would meet the current requirements on the following grounds:

SP1 Strategic Growth

The installation of Health and conservation facilities would be far more beneficial to the
community than housing. This site is within easy reach of local Schools, so could be used as
an outdoor education centre for children and adults alike.

SP2 Retail and Town Centres

Having a Community lead facility on this site benefits everyone.

SP3 Sustainable Distribution — Settlement Framework

Our suggested project (The Tirycoed Well-being Centre) not only uses the existing building
foundation as its base, but will also be managed sustainably, the exact opposite ofthe
current proposals.

SP6 Strategic sites

This project will invest in the local Community and provide much neededfacilities for all,
rather than benefiting already very rich people. This inward development will also create
local sustainable jobs, benefit local business and bring a much needed boost to the local
economy.

SP7 Employment and the Economy

This project will invest in the local Community and provide much need facilities for all,
rather than benefiting the Developers. This inward development will also create local
sustainable jobs, benefit local business and bring a much needed boost to the local
economy. It will also serve as a Community hub, allowing people to meet and interact,
something a housing estate will actively discourage.

SP8 Welsh Language and Culture

Our plan will bring the local community together and enhance its integration, keeping the
Welsh language alive, rather than causing its demise due to the influx of non-Welsh
speaking people.

SP9 Infrastructure

This site could be both built and managed to meet the needs of our local Community as
required by the conditions of this section of the RLDP.

SP12 Placemaking and Sustainable Places

Our proposal would fully comply with the placemaking charter
(http://dcfworglplacemakinglplacemaking-charter/) and we would endeavour to provide
spaces to promote prosperity, health, happiness, and well-being in the widest sense.
Furthermore we would endeavour to ensure the site was both sustainably managed
(possibly with help from INCC) and built to enhance and improve the local biodiversity, with
all the benefits this would bring.
SP13 Rural Development

This site absolutely fulfils the requirements ofthis section ofthe RLDP. It actively improves
and enhances the available facilities accessible to the local Community, while adding and
improving local facilities for all.

SP14 Maintaining and Enhancing the Natural Environment

Habitat conservation is at the heart of this proposal will include. Improving the landscape
naturally, by using cattle to graze the Rhos pasture, establishing ponds and encouraging
natural regeneration, meeting this requirement ofthe RLDP.

SP15 Protection and Enhancement of the Built and Historic Environment

The current proposal to simply destroy the existing building on this site will be revisited. Any
required works will be carried out sympathetically and in an environmentally sensitive way.
SP16 Climate Change

By using sustainable methods this proposal is protecting valuable natural assets. There
would be no need to destroy vast areas of natural land, as would be the case if a housing
development was allowed.

SP18 Mineral Resources

This proposal would actively promote improvements to the environment encouraging
carbon sequestration and improving the local landscape to the benefit ofthe environment.
SP19 Waste Management

Solar and wind power for this community site could be self sufficient for its energy and thus
reducing reliance in carbon generation.

References

Berners-Lee, M. ’What’s the Carbon Footprint of .....Bui|ding a House’. The Guardian, 2010,
Environment - Green Living Blog.

Drexler, S, A Gensior, and A Don. lCarbon Sequestration in Hedgerow Biomass and Soil in the
Temperate Climate Zone’. Regional Environmental Change 21, no. article number 74 (2021): 157-.
NERR094. ’Carbon Storage and Sequestation by Habitat: A Review of the Evidence (Second Edition)’.
Natural England, 2021.

An alternative use is proposed for this site - refer to representations 5688 & 5689.

To assist your interpretation of my very strong objections to certain elements of the RLDP, I have provided the following notes. I should however like to firstly reiterate the point that has been made to your team, many times now. This proposed site has received approximately 700 written objections from our local Community, to any Planning Application, for housing, being considered. In addition, The importance of community space was highlighted In a recent supreme court ruling - Hilary Term (2023) UKSC 8 on appeal from (2020) EWCA civ 1751- (R (on the application of Day) (Appellant) v Shropshire Council (Respondent) (landmarkchambers.co.uk)) where the court ruled in favour of the local community. This ruling has a direct bearing on your current proposals. I therefore urge you to listen to reasoned argument as to why your plans are currently not “Sound” and need amending before being approved. This is in order for them to have “ a direct and meaningful effect on the people and communities of Carmarthenshire and visitors alike” as you have suggested they should, in your introduction to the RLDP.

I support the removal of the ground to the west of the OHS from "housing development" (See below - red circle) on mainly conservation and access restriction grounds. I would also draw to your attention to the fact, that the actual size of this site would support a great deal more homes than the 25 currently being suggested. However I also do this on the understanding that the current LDP cannot be met on the following grounds:

SP2 Retail and Town Centres
Glanamman only has one small convenience store and a small Cooperative shop. There are no large retail outlets, unless you travel to Ammanford. The Dentist (Not available in the Glanamman area) and GP surgery facilities are oversubscribed and there are no leisure facilities nearby. The local infrastructure is therefore not able to cope with an influx of housing on this scale.
SP3 Sustainable Distribution – Settlement Framework
There are very few services available in this location and this development would put huge strain on existing ones. We constantly suffer from disrupted water supplies due to the ageing and over capacity water supply system, which would be overwhelmed by the additional capacity needed.
SP4 A Sustainable Approach to Providing New Homes
There is not an “appropriate number” of homes being suggested for this site. Although 25 dwellings are currently being requested, it is very clear that the site has capacity for at least 100. That would be a massive burden on the local infrastructure and facilities. The access road is not suitable for such volumes of traffic and there are already huge issues with water supply and drainage which cannot be addressed.
SP9 Infrastructure
Having recently been required to pay for the upgrading of my electricity supply, due to its lack of capacity, I am only too aware how poor the local infrastructure is. Broadband services are particularly poor and an increase in community size is only going to exacerbate this problem.
SP12 Placemaking and Sustainable Places
Placemaking should rightly be at the heart of any planning decision and this development clearly fails to meet any of those expectations. It will destroy established habitat and endangered species, it will cause light pollution and it will adversely affect the community in which it is being placed.
SP13 Rural Development
Instead of increasing the enjoyment of the countryside, this will seriously degrade it ! It is located at the very edge of an area of outstanding natural beauty, where wildlife currently thrives. Allowing such a large development on such precious land is absolutely against current Government policy.
SP14 Maintaining and Enhancing the Natural Environment
This plan will destroy the beautiful landscape and habitat that is supposed to be protected. Previous planning applications have absolutely failed to address the issue of habitat destruction (Which the current developers have been actively engaged in). Endangered species will be displaced and lost and riparian corridors will be blocked. The very idea that a housing development can be successfully accommodated here is ridiculous in the extreme.
SP15 Protection and Enhancement of the Built and Historic Environment
The appropriate use of this redundant building is certainly not to allow its demolition and replacement with a totally unsuitable housing development. Absolutely no consideration has been given to the wishes of the local community nor the protection of this historic site.
SP16 Climate Change
The destruction of Rhos pasture, trees and marshland on this site would be an absolute disaster for the local environment. Paving over huge areas for roads and paths will create hard standing that will cause rain water to surge onto surrounding roads and properties, causing flooding. Previous planning applications have had absolutely no mitigating ideas for renewable energy or energy conservation schemes, which will of course be repeated in the next attempt to bypass the planning regulations.
SP19 Waste Management
Safeguarding resources would not be achievable if planning permission were granted for this site. The loss of trees and pasture would contribute to Climate Change while the amount of carbon that would be released during the construction phase alone would be damaging to the environment.





I object to housing development on the remaining site (See map - purple box)- on conservation grounds and lack of access. I once again remind CCC that approximately 700 people objected to housing development on this site under the aegis of the RLDP and previous Planning Applications. The current LDP cannot be met on the following grounds:

SP2 Retail and Town Centres
Glanamman only has one small convenience store and a small Cooperative shop. There are no large retail outlets, unless you travel to Ammanford. The Dentist and GP surgery are oversubscribed and there are no leisure facilities nearby and the local infrastructure is not able to cope with an influx of housing on this scale.
SP3 Sustainable Distribution – Settlement Framework
There are very few services available in this location and this development would put huge strain on existing ones. We constantly suffer from disrupted water supplies due to the ageing and over capacity water supply system, which would be overwhelmed by the additional capacity needed.
SP4 A Sustainable Approach to Providing New Homes
There is not an “appropriate number” of homes being suggested for this site. Although 25 dwellings are currently being requested, it is very clear that the site has capacity for at least 100. That would be a massive burden on the local infrastructure and facilities. The access road is not suitable for such volumes of traffic and there are already huge issues with water supply and drainage which cannot be addressed.
SP9 Infrastructure
Having recently been required to pay for the upgrading of my electricity supply, due to its lack of capacity, I am only too aware how poor the local infrastructure is. Broadband services are poor and an increase in community size is only going to exacerbate this particular problem.
SP12 Placemaking and Sustainable Places
Placemaking should rightly be at the heart of any planning decision and this development clearly fails to meet any of those expectations. It will destroy established habitat and endangered species, it will cause light pollution and it will adversely affect the community in which it is being placed.
SP13 Rural Development
Instead of increasing the enjoyment of the countryside, this will destroy it ! It is located on the very edge of an area of outstanding natural beauty, where wildlife currently thrives. Allowing such a large development on such precious land is absolutely against current Government policy.
SP14 Maintaining and Enhancing the Natural Environment
This plan will destroy the beautiful landscape and habitat that is supposed to be protected. Previous planning applications have absolutely failed to address the issue of habitat destruction (Which the developers have been actively engaged in). Endangered species will be displaced and lost and riparian corridors will be blocked. The very idea that a housing development can be successfully accommodated here is ridiculous in the extreme.
SP15 Protection and Enhancement of the Built and Historic Environment
The appropriate use of this redundant building is certainly not to allow its demolition and replacement with a totally unsuitable housing development. Absolutely no consideration has been given to the wishes of the local community nor the protection of this historic site.
SP16 Climate Change
The destruction of Rhos pasture, trees and marshland on this site would be an absolute disaster for the local environment. Paving over huge areas for roads and paths will create hard standing that will cause rain water to surge onto surrounding roads and properties, causing flooding. Previous planning applications have had absolutely no mitigating ideas for renewable energy or energy conservation schemes, which will of course be repeated in the next attempt to bypass the planning regulations.
SP19 Waste Management
Safeguarding resources would not be achievable if planning permission were granted for this site. The loss of trees and pasture would contribute to Climate Change while the amount of carbon that would be released during the construction phase alone would be damaging to the environment.




I suggest that you reclassify the site as community or public space and refer you to your obligations under the aegis of the placemaking guide 2020. Please see https://dcfw.org/wpcontent/themes/dcfwchild/assets/PlacemakingGuideDigitalENG.pdf .
This would meet the current requirements on the following grounds:

SP1 Strategic Growth
The installation of either a conservation area or a Health facility, rather than housing, would be far more beneficial than housing. This site is within easy reach of local Schools, so could be used as an outdoor education centre for children and adults alike.
SP2 Retail and Town Centres
Having a Community lead facility on this site benefits everyone, rather than lining the pockets of rich developers, whose only interest is the destruction of habitat to increase their wealth.
SP3 Sustainable Distribution – Settlement Framework
Our plan not only uses the existing building as its base, but will also be managed sustainably, the exact opposite of the current proposals.
SP6 Strategic sites
This project will invest in the local Community and provide much need facilities for all, rather than benefiting already very rich people. This inward development will also create local sustainable jobs, benefit local business and bring a much needed boost to the local economy.
SP7 Employment and the Economy
This project will invest in the local Community and provide much need facilities for all, rather than benefiting already very rich Developers. This inward development will also create local sustainable jobs, benefit local business and bring a much needed boost to the local economy. It will also serve as a Community hub, allowing people to meet and interact, something a housing estate will actively discourage.
SP8 Welsh Language and Culture
The proposal to build houses on this site will simply allow wealthier people from outside the local area to have better homes. Our plan will bring the local community together and enhance its integration, keeping the Welsh language alive, rather than causing its demise due to the influx of non-Welsh speaking people.
SP9 Infrastructure
This site could be both built and managed to meet the needs of our local Community as required by the conditions of this section of the RLDP.
SP11 The Visitor Economy
With careful planning, the site could also be made to meet the requirements of local tourism and education. It is in an area of outstanding natural beauty and is full of rare and exotic wildlife.
SP12 Placemaking and Sustainable Places
This site absolutely fulfils the requirements of this section of the RLDP. The site can be both sustainably managed and built to enhance and improve the local biodiversity, with all the benefits this would bring. Allowing a poor executed housing estate would most definitely not.
SP13 Rural Development
Again, this site absolutely fulfils the requirements of this section of the RLDP. It actively improves and enhances the available facilities accessible to the local Community, while adding and improving local facilities for all.
SP14 Maintaining and Enhancing the Natural Environment
Habitat conservation is at the heart of what our proposal will include, unlike the ugly development currently proposed, which has habitat destruction at its heart. Improving the landscape naturally, by using cattle to graze the Rhos pasture for example, are one of the many ways our proposal would fully meet this requirement of the RLDP.
SP15 Protection and Enhancement of the Built and Historic Environment
The current proposal to simply destroy the existing building on this site will be revisited, with a suggestion to either repurpose or retain the existing structure. Any required works will be carried out sympathetically and in an environmentally sensitive way.
SP16 Climate Change
Again, our plans fully meet these requirements by using sustainable methods and by protecting valuable natural assets. There would be no need to destroy vast areas of natural land, as would be the case if a housing development was allowed.
SP17 Transport and Accessibility
This site already has transport links that can be used to reach it from all over Carmarthenshire. Our plans would include access to Electric vehicle charging points, to encourage sustainable travel to the site.
SP18 Mineral Resources
Our plans would actively promote improvements to the environment reducing Climate change agitators and improving the local landscape to the benefit of the environment.
SP19 Waste Management
We will be investing in solar and wind power installations to make the site self-sufficient for its energy and thus reducing reliance in carbon generation.


I propose that the site be used for well-being, conservation and recreation (with a well-being centre, a conservation area with pond, board-walks for recreation and conservation interpretation). I remind you that the site is adjacent to the most important breeding ground for the Marsh Fritillary Butterfly in the Amman Valley. I further remind you of your obligations under the placemaking charter to provide spaces to promote prosperity, health, happiness, and well-being in the widest sense. This would meet the current requirements on the following grounds:

SP1 Strategic Growth
The installation of either a conservation area or a Health facility, rather than housing, would be far more beneficial than housing. This site is within easy reach of local Schools, so could be used as an outdoor education centre for children and adults alike.
SP2 Retail and Town Centres
Having a Community lead facility on this site benefits everyone, rather than lining the pockets of rich developers, whose only interest is the destruction of habitat to increase their wealth.
SP3 Sustainable Distribution – Settlement Framework
Our plan not only uses the existing building as its base, but will also be managed sustainably, the exact opposite of the current proposals.
SP6 Strategic sites
This project will invest in the local Community and provide much need facilities for all, rather than benefiting already very rich people. This inward development will also create local sustainable jobs, benefit local business and bring a much needed boost to the local economy.
SP7 Employment and the Economy
This project will invest in the local Community and provide much need facilities for all, rather than benefiting already very rich Developers. This inward development will also create local sustainable jobs, benefit local business and bring a much needed boost to the local economy. It will also serve as a Community hub, allowing people to meet and interact, something a housing estate will actively discourage.
SP8 Welsh Language and Culture
The proposal to build houses on this site will simply allow wealthier people from outside the local area to have better homes. Our plan will bring the local community together and enhance its integration, keeping the Welsh language alive, rather than causing its demise due to the influx of non-Welsh speaking people.
SP9 Infrastructure
This site could be both built and managed to meet the needs of our local Community as required by the conditions of this section of the RLDP.
SP11 The Visitor Economy
With careful planning, the site could also be made to meet the requirements of local tourism and education. It is in an area of outstanding natural beauty and is full of rare and exotic wildlife.
SP12 Placemaking and Sustainable Places
This site absolutely fulfils the requirements of this section of the RLDP. The site can be both sustainably managed and built to enhance and improve the local biodiversity, with all the benefits this would bring. Allowing a poor executed housing estate would most definitely not.
SP13 Rural Development
Again, this site absolutely fulfils the requirements of this section of the RLDP. It actively improves and enhances the available facilities accessible to the local Community, while adding and improving local facilities for all.
SP14 Maintaining and Enhancing the Natural Environment
Habitat conservation is at the heart of what our proposal will include, unlike the ugly development currently proposed, which has habitat destruction at its heart. Improving the landscape naturally, by using cattle to graze the Rhos pasture for example, are one of the many ways our proposal would fully meet this requirement of the RLDP.
SP15 Protection and Enhancement of the Built and Historic Environment
The current proposal to simply destroy the existing building on this site will be revisited, with a suggestion to either repurpose or retain the existing structure. Any required works will be carried out sympathetically and in an environmentally sensitive way.
SP16 Climate Change
Again, our plans fully meet these requirements by using sustainable methods and by protecting valuable natural assets. There would be no need to destroy vast areas of natural land, as would be the case if a housing development was allowed.
SP17 Transport and Accessibility
This site already has transport links that can be used to reach it from all over Carmarthenshire. Our plans would include access to Electric vehicle charging points, to encourage sustainable travel to the site.
SP18 Mineral Resources
Our plans would actively promote improvements to the environment reducing Climate change agitators and improving the local landscape to the benefit of the environment.
SP19 Waste Management
We will be investing in solar and wind power installations to make the site self-sufficient for its energy and thus reducing reliance in carbon generation.

An alternative use is proposed for this site - refer to representations 5692 & 5693.

Thank you for the opportunity for us to reply to your plans. With the support of the Tirycoed Road Campaign Group (TRCG), we should like to make the following observations about your proposals.
We, like the TRCG, support the removal of the area to the west of the old Maternity Hospital from being classed as "housing development" (Please see the red circle on the map below). This objection is on conservation and access restriction grounds.
We understand, from the TRCG, that the area qualifies for SINC status, given that the Rhos pasture and hedges are protected habitats. We also understand that the Marsh Fritillary Butterfly is protected under UK law, listed under Schedule 5 of the Wildlife and Countryside Act, and the EU Habitats and Species Directive (Annex II).

We also support the removal of this area from “housing development” because it would make it difficult for potential developers to build roads from Tirycoed Road to the old maternity hospital. As you are no doubt aware, Tirycoed Road is already a single track road for the majority of the day and is potentially very hazardous for pedestrians and equestrians. We have been informed that in both recent petitions (Daffyd Wyn and TCG) local residents cited traffic issues as a main reason for objecting to PAs PACs and LDPs. The prospect of at least 50 new cars on this road is simply not realistic.
We object to housing development on the remaining development site (Please see the purple box on the map below) on conservation grounds and lack of safe access. We have been told, by the TRCG, that nearly 700 people objected to the housing development on this site, during a door to door petition, caried out by the TRCG.

It is also a fact that the actual size of this site would easily support a great deal more homes than the 25 currently being proposed by the Developers. We clarify our objections on the understanding that the current RLDP cannot be met on the following grounds:
SP2 Retail and Town Centres
Glanamman only has one small convenience store. There are no large retail outlets, unless you travel to Ammanford. All local dentists are oversubscribed or in the case of Margaret Street Ammanford are closed. The GP surgeries are also oversubscribed and there are no leisure facilities nearby and the local infrastructure is not able to cope with an influx of housing on this scale.

SP3 Sustainable Distribution – Settlement Framework
There are very few services available in this location and this development would put huge strain on existing ones. Glanamman constantly suffers from disrupted water supplies due to the ageing and an inadequate water supply system, which would be overwhelmed by the additional capacity needed.
SP4 A Sustainable Approach to Providing New Homes
There is not an “appropriate number” of homes being suggested for this site. Although 25 dwellings are currently being requested, it is very clear that the site has capacity for at least 100. That would be a massive burden on the local infrastructure and facilities. The access road is not suitable for such volumes of traffic and there are already huge issues with water supply and drainage which cannot be addressed.
SP9 Infrastructure
It is understood from the TRCG that some Tirycoed residents have had to pay for the upgrading of their electricity supply, due to its lack of capacity, we are only too aware how poor the local infrastructure is. Broadband services are poor and an increase in community size is only going to make this problem worse.
SP12 Placemaking and Sustainable Places
We believe that Placemaking should be inclusive and rightly be at the heart of any planning decision. Furthermore, we understand from the TRCG that any development should take account of the Well-being of Future Generations (Wales) Act 2015 which we believe is based on:
• Making the best use of resources;
• Facilitating accessible and healthy environments;
• Creating and sustaining communities; and
• Maximising environmental protection and limiting environmental impact.
Apparently, this housing development will fail to meet most of those expectations. There are also dangers that this development will destroy established habitat and endangered species, it will cause light pollution and it will adversely affect the community cohesion, in which it is being placed.
SP13 Rural Development
Instead of increasing the enjoyment of the countryside, a housing development would seriously decrease it! The site is located on the borders of an area of outstanding natural beauty where wildlife currently thrives. Allowing such a large development on such precious land is, we understand, absolutely against current rural development policy.
SP14 Maintaining and Enhancing the Natural Environment
We understand that any housing development will destroy our unique and bio diverse landscape and our protected habitats and lead to loss of biodiversity. There are very real dangers that any development will lead to the de-wilding of the site and the subsequent loss of the Marsh Fritillary Butterfly, Devils Bit Scabious and other winter visitors. Previous planning applications have absolutely failed to address the issue of habitat destruction (Which, we understand, the developers have been actively engaged in). Endangered species will be displaced and lost and riparian corridors will be blocked preventing otters (which I understand have low numbers in Wales) from travelling.
SP15 Protection and Enhancement of the Built and Historic Environment
We understand that the appropriate use of this redundant building is certainly not to allow its demolition and replacement with a totally unsuitable housing development. Absolutely no consideration has been given to the wishes of the local community nor the protection of this historic site, in the current Developers plans.
SP16 Climate Change
We have been told that the destruction of Rhos pasture, trees and grassy marshland on this site would be an absolute disaster for the local environment. Paving over huge areas for roads and paths will create hard standing that will cause rain water to surge onto surrounding roads and properties, causing flooding. Previous planning applications have had few mitigating measures for renewable energy, carbon negative building materials or energy conservation schemes.
SP19 Waste Management
We have been informed that safeguarding resources would not be achievable if planning permission were granted for this site. The loss of trees and pasture would contribute to Climate Change while the amount of carbon that would be released during the construction phase alone would be damaging to the environment. We would therefore suggest that CCC reclassify the development site as community or public space.
We understand that the importance of community space was highlighted In a recent supreme court ruling - Hilary Term (2023) UKSC 8 on appeal from (2020) EWCA civ 1751- (R (on the application of Day) (Appellant) v Shropshire Council (Respondent) (landmarkchambers.co.uk)) where the court ruled in favour of the local community.
We would suggest that the plan by the TRCG for the site to be used for well-being, conservation and recreation (with a well-being centre, a conservation area with pond, and board-walks for recreation and conservation interpretation), would be better. We would also remind you that the site is adjacent to the most important breeding ground for the Marsh Fritillary Butterfly in the Amman Valley and to your obligations to provide spaces to promote prosperity, health, happiness, and well-being in the widest sense. This would meet the current requirements on the following grounds:
SP1 Strategic Growth
The installation of Health and conservation facilities would be far more beneficial to the community than housing. This site is within easy reach of local Schools, so could be used as an outdoor education centre for children and adults alike.
SP2 Retail and Town Centres
Having a Community lead facility on this site benefits the whole Community, not just the Developers.
SP3 Sustainable Distribution – Settlement Framework
We understand that the suggested project (The Tirycoed Well-being Centre) not only uses the existing building foundation as its base, but will also be managed sustainably, the exact opposite of the current proposals.

SP6 Strategic sites
This project, we have been told, will invest in the local Community and provide much need facilities for all, rather than benefiting already very rich people. This inward development will also create local sustainable jobs, benefit local business and bring a much needed boost to the local economy.
SP7 Employment and the Economy
We understand that his project will invest in the local Community and provide much need facilities for all, rather than benefiting Developers. This inward development will also create local sustainable jobs, benefit local business and bring a much needed boost to the local economy. It will also serve as a Community hub, allowing people to meet and interact, something a housing estate will actively discourage.
SP8 Welsh Language and Culture
The proposal to build houses on this site will simply allow wealthier people from outside the local area to have better homes. Our plan will bring the local community together and enhance its integration, keeping the Welsh language alive, rather than causing its demise due to the influx of non-Welsh speaking people.
SP9 Infrastructure
This site could be both built and managed to meet the needs of our local Community as required by the conditions of this section of the RLDP.
SP11 The Visitor Economy
With careful planning, the site could also be made to meet the requirements of local tourism and education. It is in an area of outstanding natural beauty and is full of rare and exotic wildlife.
SP12 Placemaking and Sustainable Places
We believe that the proposed Community development would endeavour to provide spaces to promote prosperity, health, happiness, and well-being in the widest sense. Furthermore the site would be both sustainably managed and built to enhance and improve the local biodiversity, with all the benefits this would bring.
SP13 Rural Development
Again, this site absolutely fulfils the requirements of this section of the RLDP. It actively improves and enhances the available facilities accessible to the local Community, while adding and improving local facilities for all.
SP14 Maintaining and Enhancing the Natural Environment
Habitat conservation is at the heart of what we understand this proposal will include, unlike the ugly development currently proposed, which has habitat destruction at its heart. Improving the landscape naturally, by using cattle to graze the Rhos pasture, establishing ponds and encouraging natural regeneration, are just some of the many ways, we have been told, that this proposal would fully meet this requirement of the RLDP.

SP15 Protection and Enhancement of the Built and Historic Environment
The current proposal to simply destroy the existing building on this site should be revisited. Any required works could be carried out sympathetically and in an environmentally sensitive way.
SP16 Climate Change
Again, the proposal fully meets these requirements by using sustainable methods and by protecting valuable natural assets. There would be no need to destroy vast areas of natural land, as would be the case if a housing development was allowed. The building of a well-being centre (with carbon negative and eco-friendly building materials) would have minimal impact on carbon stocks and carbon emissions.
SP17 Transport and Accessibility
This site already has transport links that can be used to reach it from all over Carmarthenshire. We understand that the plans would include access to Electric vehicle charging points, to encourage sustainable travel to the site.
SP18 Mineral Resources
These proposals would actively promote improvements to the environment encouraging carbon sequestration and improving the local landscape to the benefit of the environment.
SP19 Waste Management
We believe these proposals would be investing in solar and wind power installations to make the site self-sufficient for its energy and thus reducing reliance in carbon generation.

An alternative use is proposed for this site - refer to representations 5696 & 5697.

Thank you for the opportunity to reply to your proposed revision of the Local Development Plan. With the support of the Tirycoed Road Campaign Group (TRCG), I should like to make the following observations about your proposals and why I believe they should be amended.
I support the removal of the area to the west of the old Maternity Hospital from being classed as "housing development" (Please see the red circle on map below). This objection is on conservation and access restriction grounds.
I understand, from the TRCG, that the area qualifies for SINC status, given that the Rhos pasture and hedges found within them, are protected habitats. I also understand that the Marsh Fritillary Butterfly, which is found on this site, is also protected under UK law, listed under Schedule 5 of the Wildlife and Countryside Act, and the EU Habitats and Species Directive (Annex II).

I also support the removal of this area from “housing development” because it would make it difficult for potential developers to build roads from Tirycoed Road to the old maternity hospital. As you are aware, Tirycoed Road is already a single track road for much of the day and is potentially very hazardous for pedestrians and equestrians. I have been informed by the TRCG, that in both recent petitions (Daffyd Wyn and TCG) local residents cited traffic issues as a main reason for objecting to PAs PACs and LDPs. The prospect of at least 50 new cars on this road is simply not realistic.
2. I object to housing development on the remaining development site (Please see the purple box on the map below) on conservation grounds and lack of safe access. I have been told that nearly 700 people objected to the housing development on this site, during a door to door petition, caried out by the TRCG.

It is also a fact that the actual size of this site would easily support a great deal more homes than the 25 currently being proposed by the Developers. I clarify my objections on the understanding that the current RLDP cannot be met on the following grounds:
SP2 Retail and Town Centres
Glanamman only has one small convenience store. There are no large retail outlets, unless you travel to Ammanford. The Dentist (Which is not in Glanamman) and GP surgery are oversubscribed and there are no leisure facilities nearby. The local infrastructure is not able to cope with an influx of housing on this scale.
SP3 Sustainable Distribution – Settlement Framework
There are very few services available in this location and this development would put huge strain on existing ones. Glanamman constantly suffers from disrupted water supplies due to the ageing and an inadequate water supply system, which would be overwhelmed by the additional capacity needed.
SP4 A Sustainable Approach to Providing New Homes
There is not an “appropriate number” of homes being suggested for this site. Although 25 dwellings are currently being requested, it is very clear that the site has capacity for at least 100. That would be a massive burden on the local infrastructure and facilities. The access road is not suitable for such volumes of traffic and there are already huge issues with water supply and drainage which cannot be addressed.
SP9 Infrastructure
It is understood that some Tirycoed residents have had to pay for the upgrading of their electricity supply, due to its lack of capacity, I am only too aware how poor the local infrastructure is. Broadband services are not to a very high standard and an increase in community size is only going to make this problem worse.
SP12 Placemaking and Sustainable Places
I believe that Placemaking should be inclusive and rightly be at the heart of any planning decision. Furthermore, I understand, from the TRCG, that any development should take account of the Well-being of Future Generations (Wales) Act 2015 which I believe is based on:
• Making the best use of resources;
• Facilitating accessible and healthy environments;
• Creating and sustaining communities; and
• Maximising environmental protection and limiting environmental impact.
Apparently, this housing development will always fail to meet most of those expectations. There are also dangers that this development will destroy established habitat and endangered species, it will cause light pollution and it will adversely affect the community cohesion, in which it is being placed.
SP13 Rural Development
Instead of increasing the enjoyment of the countryside, a housing development would seriously decrease it! The site is located on the borders of an area of outstanding natural beauty where wildlife currently thrives. Allowing such a large development on such precious land is, I understand, absolutely against current rural development policy.
SP14 Maintaining and Enhancing the Natural Environment
I understand that any housing development will destroy our unique and bio diverse landscape and our protected habitats and lead to loss of biodiversity. There are very real dangers that any development will lead to the de-wilding of the site and the subsequent loss of the Marsh Fritillary Butterfly, Devils Bit Scabious and other winter visitors. Previous planning applications have absolutely failed to address the issue of habitat destruction (Which, I understand, the developers have been actively engaged in). Endangered species will be displaced and lost and riparian corridors will be blocked preventing otters (which I understand have low numbers in Wales) from travelling.
SP15 Protection and Enhancement of the Built and Historic Environment
I understand from the TRCG, that the appropriate use of this redundant building is certainly not to allow its demolition and replacement with a totally unsuitable housing development. Absolutely no consideration has been given to the wishes of the local community nor the protection of this historic site, in the current Developers plans.
SP16 Climate Change
I have been told that the destruction of Rhos pasture, trees and grassy marshland on this site would be an absolute disaster for the local environment. Paving over huge areas for roads and paths will create hard standing that will cause rain water to surge onto surrounding roads and properties, causing flooding. Previous planning applications have had few mitigating measures for renewable energy, carbon negative building materials or energy conservation schemes.
SP19 Waste Management
I have been informed that safeguarding resources would not be achievable if planning permission were granted for this site. The loss of trees and pasture would contribute to Climate Change while the amount of carbon that would be released during the construction phase alone would be damaging to the environment. I would therefore suggest that CCC reclassify the development site as community or public space.
I understand that you have already been informed of the importance of community space, which was highlighted In a recent supreme court ruling - Hilary Term (2023) UKSC 8 on appeal from (2020) EWCA civ 1751- (R (on the application of Day) (Appellant) v Shropshire Council (Respondent) (landmarkchambers.co.uk)) where the court, quite rightly, ruled in favour of the local community.
I would suggest that the plan, by the TRCG, for the site to be used for well-being, conservation and recreation (with a well-being centre, a conservation area with pond, and board-walks for recreation and conservation interpretation), would be much better. I would also remind you that the site is adjacent to the most important breeding ground for the Marsh Fritillary Butterfly in the Amman Valley and to your obligations to provide spaces to promote prosperity, health, happiness, and well-being in the widest sense. This would meet the current requirements on the following grounds:
SP1 Strategic Growth
The installation of Health and conservation facilities would be far more beneficial to the community than housing. This site is within easy reach of local Schools, so could be used as an outdoor education centre for children and adults alike.
SP2 Retail and Town Centres
Having a Community lead facility on this site benefits the whole Community.
SP3 Sustainable Distribution – Settlement Framework
I understand that the suggested project (The Tirycoed Well-being Centre) not only uses the existing building foundation as its base, but will also be managed sustainably, the exact opposite of the current proposals.

SP6 Strategic sites
This project, I have been told, will invest in the local Community and provide much need facilities for all, rather than benefiting already very rich people. This inward development will also create local sustainable jobs, benefit local business and bring a much needed boost to the local economy.
SP7 Employment and the Economy
I understand that his project will invest in the local Community and provide much need facilities for all, rather than benefiting Developers. This inward development will also create local sustainable jobs, benefit local business and bring a much needed boost to the local economy. It will also serve as a Community hub, allowing people to meet and interact, something a housing estate will actively discourage.
SP8 Welsh Language and Culture
The proposal to build houses on this site will simply allow wealthier people from outside the local area to have better homes. Our plan will bring the local community together and enhance its integration, keeping the Welsh language alive, rather than causing its demise due to the influx of non-Welsh speaking people.
SP9 Infrastructure
This site could be both built and managed to meet the needs of our local Community as required by the conditions of this section of the RLDP.
SP11 The Visitor Economy
With careful planning, the site could also be made to meet the requirements of local tourism and education. It is in an area of outstanding natural beauty and is full of rare and exotic wildlife.
SP12 Placemaking and Sustainable Places
I believe that the proposed Community development would endeavour to provide spaces to promote prosperity, health, happiness, and well-being in the widest sense. Furthermore the site would be both sustainably managed and built to enhance and improve the local biodiversity, with all the benefits this would bring.
SP13 Rural Development
Again, this site absolutely fulfils the requirements of this section of the RLDP. It actively improves and enhances the available facilities accessible to the local Community, while adding and improving local facilities for all.
SP14 Maintaining and Enhancing the Natural Environment
Habitat conservation is at the heart of what I understand this proposal will include, unlike the ugly development currently proposed, which has habitat destruction at its heart. Improving the landscape naturally, by using cattle to graze the Rhos pasture, establishing ponds and encouraging natural regeneration, are just some of the many ways I have been told that this proposal would fully meet this requirement of the RLDP.
SP15 Protection and Enhancement of the Built and Historic Environment
The current proposal to simply destroy the existing building on this site should be revisited. Any required works could be carried out sympathetically and in an environmentally sensitive way.
SP16 Climate Change
Again, the proposal fully meets these requirements by using sustainable methods and by protecting valuable natural assets. There would be no need to destroy vast areas of natural land, as would be the case if a housing development was allowed. The building of a well-being centre (with carbon negative and eco-friendly building materials) would have minimal impact on carbon stocks and carbon emissions.
SP17 Transport and Accessibility
This site already has transport links that can be used to reach it from all over Carmarthenshire. I understand that the plans would include access to Electric vehicle charging points, to encourage sustainable travel to the site.
SP18 Mineral Resources
These proposals would actively promote improvements to the environment encouraging carbon sequestration and improving the local landscape to the benefit of the environment.
SP19 Waste Management
I believe these proposals would be investing in solar and wind power installations to make the site self-sufficient for its energy and thus reducing reliance in carbon generation.


I therefore hope you will now give due consideration to both my and the Communities wishes to ammend your current proposals and allow the correct usage of this land.

An alternative use is proposed for this site - refer to representations 5700 & 5701.

We support the Council’s decision to remove this site from housing allocation, and
to remove the land to the west of this site from development limits. We would also
suggest that this site should not be considered as suitable for any potential future
housing development. We believe this to be necessary for compliance with the
strategic policies we have mentioned.
We would also suggest that the land to the East of this site (at 51.809167 ,
-3.923369) should also be removed from development limits, as it is currently a
valuable wildlife habitat, and should be conserved as such.
We would suggest that the site be allocated under SP2, SG1: Regeneration and
Mixed-Use Sites, as public amenity space, for any future redevelopment, and we
feel that such a reclassification would be to the benefit of the local community, and
would assist the Council in meeting its obligations regarding nature conservation,
sustainable development, and placemaking.
As members of the Tirycoed Campaign Group, we would refer you to the
submission made by Dr. John Studley, on behalf of the group, for full and detailed
reasoning, reference to supporting information, and suggestions for potential
future use of this site.

An alternative use is proposed for this site - refer to representations 5704 & 5705

1. We (the Tirycoed Campaign Group) support the removal of the ground to the west of the old Maternity Hospital from "housing development" (See red circle on map) on conservation and access restriction grounds.
In terms of conservation the area qualifies for SINC status given that the rhos pasture and hedges which are protected habitats1. The habitats are currently supporting or capable of supporting the following species; bats2, dormice3, hedgehogs4, badgers5, otters6, newts7, lizards8, herons9, eels10 (in Nant Llwyd), water voles11, Marsh Fritillary Butterflies12, Scabious spp (Succisa pratensis in particular)13, Purple Moor Grass (Molinia caerulea)14, Brambles (Rubrus fruticosus) and Bracken (Pteridium aquilinum).
1 https://naturalresources.wales/guidance-and-advice/environmental-topics/wildlife-and-biodiversity/protected-areas-of-land-and-seas/types-of-protected-areas-of-land-and-sea/?lang=en
2 All bat species (and their breeding sites) are protected under schedule 5 of the Wildlife & Countryside Act 1981 and since 2007 the
effective protection for bats now comes from Schedule 2 of the Conservation (Natural Habitats &c) Regulations 1994, and in the EU under
Article 12 of the Habitats Directive, which means that capture, killing, deliberate disturbance and destruction of their breeding sites and
resting places is prohibited.
3 Dormice (Muscardinus avellanarius) are protected under the aegis of the Wildlife and Countryside Act 1981 – schedule 5, a conservation
priority species in the UK (Environment Wales 2016 Act) and a European Protected Species (Habitats Directive 92/43/EEC – schedule 2).
Schedule 2 states it is an offence to destroy their habitat (breeding site or resting place).
4 Hedgehogs (Erinaceinae europaeus) are listed on Schedule 6 of the Wildlife and Countryside Act 1981 and the Wild Mammal Protection
Act 1996.
5 Badgers and their setts are legally protected from intentional cruelty and from the results of lawful human activities (The Protection of
Badgers Act 1992)
6 Otters (Lutra lutra) are strictly protected by the Wildlife and Countryside Act 1981 and the EU Habitats Directive (92/43/EEC – Annex 4)
and a priority species for maintaining biodiversity (Environment (Wales) Act 2016).
7 All newt species are protected under the aegis of the Wildlife and Conservation Act 1981 and the Great Crested Newt (Triturus cristatus)
is a priority species (Environment (Wales) Act 2016) and a EU protected species (Habitats Directive 92/43/EEC- Annex 4)
8 The common Lizard (Zootoca vivipara) is protected under the aegis of the Wildlife and Conservation Act 1981 and a priority species
(Environment (Wales) Act 2016) and the UK post 2010 Biodiversity Framework.
9 The heron is a protected species under the Wildlife and Countryside Act 1981, with fines or prison sentences available for anyone killing
or attempting to kill one
10 Eels are protected as an endangered species by the Convention on International Trade in Endangered Species of Wild Fauna and Flora
(CITES)
11The water vole is fully protected under Schedule 5 of the Wildlife and Countryside Act 1981 and is a priority conservation species.
12Marsh Fritillary Butterflies are protected under schedule 5 of the Wildlife and Countryside Act 1981 and Wildlife (NI) order 1985, a
priority species (Environment (Wales) Act 2016), and an EU protected species (Habitats Directive 92/43/EED – Annex 2).
13 Important food for Marsh Fritillary Butterfly caterpillars

Marsh Fritillary Butterfly - Charles J. Sharp, CC BY-SA 4.0 <https://creativecommons.org/licenses/by-sa/4.0>, via Wikimedia Commons
More on the importance of conservation in this area can be found at https://thunderbolt.me.uk/Docs/DrStudley-Objection-Rev3.pdf which were submitted under the aegis of PA E/38266, but applies equally to the RLDP

We also support the removal of this area from “housing development” because it would make it difficult for potential developers to build roads from Tirycoed Road to the old maternity hospital. It was removed because CCC considered the area was undeliverable and was aware of the extent of opposition against its inclusion (Neil Bateman pers. comm 27/2/23). Tirycoed Road is already a single track road for much of the day (See photo gallery) and is potentially very hazardous for pedestrians and equestrians. In both petitions (Daffyd Wyn and TCG) local residents cited traffic issues as a main reason for objecting to PAs PACs and LDPs. The prospect of up to 50 new cars in not tenable.
2. We object to possible housing development on the remaining development site (See purple box on map below) on conservation grounds and lack of access. The management of Amman Valley Hospital have stated to us that they would not support any housing development on the old maternity hospital site.
We would remind CCC that nearly 700 people objected to housing development on this site under the aegis of both the RLDP and the current PAC (S21.186). (See online petition https://www.change.org/p/no-to-the-housing-development-on-tirycoed and door to door petition https://thunderbolt.me.uk/Docs/Tirycoed%20Petition%20Redacted.rar )

We would also draw your attention to the fact, that the actual size of this site would support a great deal more homes than the 25 currently being proposed in PAC S21.186. However we also object on the understanding that the current LDP cannot be met on the following grounds:
SP2 Retail and Town Centres
Both the Brecon Beacons and Glanamman have an ageing demographic. Glanamman only has one small convenience store. There are no large retail outlets, unless you travel to Ammanford. There is no Dentist, the GP surgery is oversubscribed, there are no leisure facilities nearby and the local infrastructure is not able to cope with an influx of housing on this scale.
SP3 Sustainable Distribution – Settlement Framework
There are very few services available in this location and a housing development would put huge strain on existing ones. We constantly suffer from disrupted water supplies due to the ageing and inadequate water supply system, which would be overwhelmed by the additional capacity needed.
SP4 A Sustainable Approach to Providing New Homes
There has never been an “appropriate number” of houses suggested for this site. Although 25 dwelling houses are currently being requested, it is very clear that the site has capacity for at least 100. That would be a massive burden on the local infrastructure and facilities. The access road is not suitable for such volumes of traffic and there are already huge issues with water supply and drainage which have never been addressed.
SP9 Infrastructure
Given that some Tirycoed residents have had to pay for the upgrading of their electricity supply, due to its lack of capacity, we are only too aware how poor the local infrastructure is but especially water, electricity capacity and drainage.
SP12 Placemaking and Sustainable Places
Sustainable Placemaking should be holistic and inclusive and rightly be at the heart of any planning decision. It is important to recognise that sustainable placemaking is contingent upon local “sense of place” (comprised of place attachment, place identity, and place meaning), intrinsic value of place, and well-being (aka satisfaction, happiness). Most communities are resilient in the face of small changes that take place gradually. Sense of place, intrinsic value of place and well-being are distinctive in rural communities and may take several generations to develop. Rapid population growth or an influx of new people who are not wanted and who do not share the same sense of place or intrinsic value undermines social cohesion, place identity and place-making. There was some evidence that placemaking was undermined as a result of the introduction of flats on Tirycoed Road and this would be exacerbated should housing development go ahead.

Integrating wellbeing with sense of place helps make more explicit a range of social issues important for human welfare. Furthermore it draws out the importance of the phenomenological meanings that people attach to places through place attachment, place
dependence, place identity, and place satisfaction. There are other often less tangible matters that arise as a consequence of changes in population size and structure that can impact wellbeing. This is a reflection of people's capacity to adapt to change, especially if change occurs at a rapid pace. For example, rapid increases in the size of a community can engender a sense of pessimism about the future and so affect people's sense of wellbeing. Similarly, changes in the composition of the population, in terms of demographics can lead to anxiety or tension impacting on the cohesion of society.

Very little has been done in Tirycoed under the aegis of PAs PACs or LDPs to assess the impact of housing development in terms of local identity sense of place, social cohesion, wellbeing or the undermining of the Welsh language
Furthermore any development should; comply with Welsh Government policy on sustainable places https://research.senedd.wales/research-articles/making-sustainable-places-what-role-can-the-planning-system-play/, and take account of the Well-being of Future Generations (Wales) Act 2015 and be predicated on
• Making the best use of resources;
• Facilitating accessible and healthy environments;
• Creating and sustaining communities; and
• Maximising environmental protection and limiting environmental impact.
Seemingly housing development will fail to meet most of those expectations. There are dangers that development will destroy established habitat and endangered species, it will cause light pollution and it will adversely affect community cohesion in which it is being placed.
SP13 Rural Development
Instead of increasing the enjoyment of the countryside, housing development would destroy it! The site is located close an area of outstanding natural beauty and the Amman Valleys unique cloud forest where wildlife currently thrives. Allowing such a large development on such precious land appears to be contrary to current rural development policy https://research.senedd.wales/research-articles/the-rural-development-plan-for-wales/ which is predicated on “the sustainable management of natural resources and climate action”
SP14 Maintaining and Enhancing the Natural Environment
Housing development will destroy our unique and bio diverse landscape and our protected habitats and lead to loss of biodiversity. There are very real dangers that development will lead to the de-wilding of the site and the subsequent loss of bats, dormice, hedgehogs, badgers, otters, newts, lizards, herons, eels (in Nant Llwyd), water voles, Marsh Fritillary Butterflies, Scabious spp (Succisa pratensis in particular), Purple Moor Grass (Molinia caerulea) and winter visitors such as snipe and woodcock

Devils Bit Scabious- Christian Fischer, CC BY-SA 3.0 <https://creativecommons.org/licenses/by-sa/3.0>, via Wikimedia Commons
Previous planning applications have absolutely failed to address the issue of habitat destruction (Which the developers have been actively engaged in). Endangered species will be displaced and lost and riparian corridors will be blocked preventing otters (which are low in Wales) from travelling.

Example of habitat destruction on the site
SP15 Protection and Enhancement of the Built and Historic Environment
The old maternity hospital is unique and is considered the “heart” of the community. It still has an iconic status on the basis that the first NHS baby was born there on 5/7/1948. Given that many local people were born there and they retain a very strong sense of emotional attachment it would be sacrilege to demolish it. Furthermore the carbon cost of demolishing it (13 T C) and replacing it (242 T C) would be 255 TC which is more than double the carbon cost of refurbishing or retrofitting it which would be 120 T C (Hurst 2021: O’Hegerty 2021)
255 T C is the equivalent of the sequestration of 4,216 tree seedlings over 10 years (Greenhouse Gas Equivalencies Calculator | US EPA)
If it were replaced by 20 houses the carbon cost would be about 2,410 T C or the equivalent of the sequestration of 40,000 trees over 10 year (Berners-Lee 2010)
It would be better to refurbish and retrofit the existing building in terms of its carbon saving and its historic and psychological (place attachment) value.
Absolutely no consideration has been given to the wishes of the local community nor the protection of this historic site.
SP16 Climate Change
The destruction of Rhos pasture, trees and grassy marshland on this site would be an absolute disaster for the local environment and for the loss of carbon stocks. Paving over huge areas for roads and paths will create hard standing that will cause rain water to surge onto surrounding roads and properties, causing flooding. Previous planning applications have had few mitigating measures for renewable energy, carbon negative building materials or energy conservation schemes.
There has been no carbon audit of potential housing development on this site. It has been estimated (Drexler et al 2021, NERR094) that the current carbon stocks (rhos pasture, shrubs and hedges) on the whole site (ca 2ha) are 220 T C which will be cut by 84.75 T C to 135.25 T C after housing development. The carbon emissions (Berners-Lee 2010) as a result of development (25 houses plus roads, paths, drives, parking bays) will be approximately 3000 T CO2 and there will be a sequestration reduction of 0.125 T C yr (NERR094)
SP19 Waste Management
Safeguarding resources would not be achievable if planning permission were granted for this site. The loss of trees and pasture would contribute to Climate Change while the amount of carbon that would be released (3000 T CO2) during the construction phase alone would be damaging to the environment.
3.We suggest to CCC that the development site it taken into public ownership or classified as community or public space1 and refer CCC to your obligations under the aegis of the placemaking guide 2020. (https://dcfw.org/wp-content/themes/dcfw-child/assets/PlacemakingGuideDigitalENG.pdf)
The importance of community space was highlighted In a recent supreme court ruling - Hilary Term (2023) UKSC 8 on appeal from (2020) EWCA civ 1751- (R (on the application of Day) (Appellant) v Shropshire Council (Respondent) (landmarkchambers.co.uk)) where the court ruled in favour of the local community.
Furthermore the importance of having access to community space was a frequent theme highlighted in a consultation report on connected communities, and is especially important for Tirycoed’s aging population https://www.gov.wales/sites/default/files/consultations/2019-03/summary-of-responses_2.pdf
4.We propose that the site be used for well-being, conservation and recreation (with a well-being centre, a conservation area with pond, and board-walks for recreation and for interpretative trails (perhaps inter-connecting with Glyndrainog and Ty Llwyd farms). I would also remind CCC that the site is adjacent to the most important breeding ground (on Glyndrainog Farm) for the Marsh Fritillary Butterfly in the Amman Valley and to your obligations under the placemaking charter (http://dcfw.org/placemaking/placemaking-charter/) to provide spaces to promote prosperity, health, happiness, and well-being in the widest sense.
This would meet the current requirements on the following grounds:
SP1 Strategic Growth
The installation of Health and conservation facilities would be far more beneficial for Tirycoed’s aging demographic than housing for outsiders. Furthermore the site and its interpretive trails would be within easy reach of local Schools, so could be used as an outdoor education centre for children and adults alike.
SP2 Retail and Town Centres
Having a Community lead health and conservation facility on this site benefits everyone.
SP3 Sustainable Distribution – Settlement Framework
Our suggested project (The Tirycoed Well-being Centre) not only uses the existing building foundation as its base but it will be refurbished, retrofitted and managed sustainably, the exact opposite of the current proposals.
Retrofitting is the act of fitting new systems designed for high energy efficiency and low energy consumption to buildings previously built without them. This can range from small activities such as fitting energy-efficient light bulbs to installing state of the art heating systems. The reasons for doing this are simple. A more efficient building will be cheaper to run, have a lower impact on the environment and the higher energy rating that comes with this can increase the value of the property. There is a broad spectrum of commonly used methods of sustainably retrofitting properties. These include solar panels, smart meters and sustainable water and heating systems. It should be noted that the maintenance of these systems is just as important a consideration as their energy efficiency. https://www.elmhurstenergy.co.uk/blog/2022/06/29/what-is-retrofit-in-construction/#:~:text=Retrofitting%20is%20the%20act%20of,of%20the%20art%20heating%20systems.
SP6 Strategic sites
This project will invest in the local Community and provide much needed facilities for all, but especially our ageing population1. This inward development will also create local sustainable jobs, benefit local business and bring a much needed boost to the local economy.
1 In Carmarthenshire between 2011 and 2021 there was an increase of 18.9% in people aged 65 years and over, a decrease of 2.5% in people aged 15 to 64 years, and a decrease of 0.8% in children aged under 15 years https://www.ons.gov.uk/visualisations/censuspopulationchange/W06000010/
SP7 Employment and the Economy
This project will invest in the local Community and provide much needed facilities for all, but especially Tirycoeds aging population. Currently there are no leisure facilities. This inward development will also create local sustainable jobs, benefit local business and bring a much needed boost to the local economy. It will also serve as a Community hub, allowing people to meet and interact, something a housing estate appears to discourage.
SP8 Welsh Language and Culture
The plan to build houses on this site will simply allow wealthier people from outside the local area to have better homes. Our plan will bring the local community together and enhance its integration, keeping the Welsh language alive, rather than causing its demise due to the influx of non-Welsh speaking people.
SP9 Infrastructure
This centre could be both refurbished, retrofitted and managed to meet the felt needs of our local demographic and include features such as water harvesting, solar panels and ev points.
SP11 The Visitor Economy
With careful planning, the site could also be made to meet the requirements of local tourism and education. It is very close to an area of outstanding natural beauty and cloud oak forests which are full of rare and exotic wildlife.
SP12 Placemaking and Sustainable Places
Our proposal would fully comply with the placemaking charter (http://dcfw.org/placemaking/placemaking-charter/) and we would endeavour to provide spaces to promote prosperity, health, happiness, and well-being in the widest sense. Furthermore we would endeavour to ensure the site was both sustainably managed (possibly with help from INCC) and built to enhance and improve the local biodiversity, with all the benefits this would bring.
More on the importance of placemaking in this area can be found at https://thunderbolt.me.uk/Docs/DrStudley-Objection-Rev3.pdf (part b) which were submitted under the aegis of PA E/38266, but applies equally to the RLDP
SP13 Rural Development
Again, this site absolutely fulfils the requirements of this section of the RLDP. It actively improves and enhances the available facilities accessible to the local Community, while adding and improving local facilities for all.
SP14 Maintaining and Enhancing the Natural Environment
Habitat conservation is at the heart of what our proposal will include, unlike the questionable development currently proposed, which has habitat destruction at its heart. Efforts will be made to improving the landscape and biodiversity naturally, by using cattle to lightly graze the Rhos pasture, establishing ponds and encouraging natural regeneration. These are just some of the many ways our proposal would fully meet this requirement of the RLDP.
SP15 Protection and Enhancement of the Built and Historic Environment
The current proposal to simply destroy the existing iconic building on this site is not tenable on the basis of history, heritage, place attachment and carbon cost.
Any required works (such as refurbishment and retrofitting) would be carried out sympathetically and in an environmentally sensitive way.
SP16 Climate Change
Again, our proposal fully meets these requirements by using sustainable methods and by protecting valuable natural assets. There would be no need to destroy vast areas of natural land, as would be the case if a housing development was allowed. The refurbishment and retrofitting of the old hospital building as a well-being centre will have a carbon cost of ca 120 T C and will have minimal impact on carbon stocks, carbon emissions and carbon sequestration rates. Carbon stocks on the remaining area (ca 0.7663 ha) will be approximately 85 T C with an annual sequestration rate of 0.38 T C (NERR094)
SP17 Transport and Accessibility
This site already has transport links that can be used to reach it from all over Carmarthenshire. The site is close to the Amman valley cycleway and if the Swansea 9 Lines project comes to fruition train visitors would be a possibility. Our plans would include access to Electric vehicle charging points, to encourage sustainable travel to the site.
SP18 Mineral Resources
Our proposal would actively promote improvements to the environment encouraging carbon sequestration and improving the local landscape to the benefit of the environment.
SP19 Waste Management
We will be investing in solar and wind power installations to make the site self sufficient for its energy and thus reducing reliance in carbon generation.

References
Berners-Lee, M. ‘What’s the Carbon Footprint of .....Building a House’. The Guardian, 2010, Environment - Green Living Blog.
Drexler, S, A Gensior, and A Don. ‘Carbon Sequestration in Hedgerow Biomass and Soil in the Temperate Climate Zone’. Regional Environmental Change 21, no. article number 74 (2021): 157-.
Hurst, W. (2021) Derby Assembly Rooms’ carbon cost of demolishing laid bare, Architects Journal, 22 June 2021
NERR094. ‘Carbon Storage and Sequestration by Habitat: A Review of the Evidence (Second Edition)’. Natural England, 2021.
O’Hegarty, R. (2021) The embodied carbon of buildings, Share Your Green Design

An alternative use is proposed for this site - refer to representations 5708 & 5709.

As the County Councillor of Glanamman and Cwmamman Town Councillor for Tirycoed Ward, I am writing to support the consultation response form entered by Dr John Studley - Secretary of the Tirycoed Campaign Group on behalf of the campaign group regarding LDP proposals map reference - SeC10/h4 Coordinates [51.809101,-3.925159] [51.808981,-3.923050]

The extensive and thorough work Dr Studley (with help from Mr. Mark Vickers) has done completing LDP response form, leaves nothing for me to add except that I fully support all points raised within said form and sincerely hope that all matters within the form are seriously considered.

An alternative use is proposed for this site - refer to representations 5714 & 5715.

Thank you for the opportunity to reply to your proposed revision of the Local Development Plan. With the support of the Tirycoed Road Campaign Group (TRCG), I should like to make the following observations about your proposals and why I believe they should be ammended.
I support the removal of the area to the west of the old Maternity Hospital from being classed as "housing development" (Please see the red circle on map below). This objection is on conservation and access restriction grounds.
I understand, from the TRCG, that the area qualifies for SINC status, given that the Rhos pasture and hedges found within them, are protected habitats. I also understand that the Marsh Fritillary Butterfly, which is found on this site, is also protected under UK law, listed under Schedule 5 of the Wildlife and Countryside Act, and the EU Habitats and Species Directive (Annex II).

I also support the removal of this area from “housing development” because it would make it difficult for potential developers to build roads from Tirycoed Road to the old maternity hospital. As you are aware, Tirycoed Road is already a single track road for much of the day and is potentially very hazardous for pedestrians and equestrians. I have been informed by the TRCG, that in both recent petitions (Daffyd Wyn and TCG) local residents cited traffic issues as a main reason for objecting to PAs PACs and LDPs. The prospect of at least 50 new cars on this road is simply not realistic.
2. I object to housing development on the remaining development site (Please see the purple box on the map below) on conservation grounds and lack of safe access. I have been told that nearly 700 people objected to the housing development on this site, during a door to door petition, caried out by the TRCG.

It is also a fact that the actual size of this site would easily support a great deal more homes than the 25 currently being proposed by the Developers. I clarify my objections on the understanding that the current RLDP cannot be met on the following grounds:
SP2 Retail and Town Centres
Glanamman only has one small convenience store. There are no large retail outlets, unless you travel to Ammanford. The Dentist (Which is not in Glanamman) and GP surgery are oversubscribed and there are no leisure facilities nearby. The local infrastructure is not able to cope with an influx of housing on this scale.
SP3 Sustainable Distribution – Settlement Framework
There are very few services available in this location and this development would put huge strain on existing ones. Glanamman constantly suffers from disrupted water supplies due to the ageing and an inadequate water supply system, which would be overwhelmed by the additional capacity needed.
SP4 A Sustainable Approach to Providing New Homes
There is not an “appropriate number” of homes being suggested for this site. Although 25 dwellings are currently being requested, it is very clear that the site has capacity for at least 100. That would be a massive burden on the local infrastructure and facilities. The access road is not suitable for such volumes of traffic and there are already huge issues with water supply and drainage which cannot be addressed.
SP9 Infrastructure
It is understood that some Tirycoed residents have had to pay for the upgrading of their electricity supply, due to its lack of capacity, I am only too aware how poor the local infrastructure is. Broadband services are not to a very high standard and an increase in community size is only going to make this problem worse.
SP12 Placemaking and Sustainable Places
I believe that Placemaking should be inclusive and rightly be at the heart of any planning decision. Furthermore, I understand, from the TRCG, that any development should take account of the Well-being of Future Generations (Wales) Act 2015 which I believe is based on:
• Making the best use of resources;
• Facilitating accessible and healthy environments;
• Creating and sustaining communities; and
• Maximising environmental protection and limiting environmental impact.
Apparently, this housing development will always fail to meet most of those expectations. There are also dangers that this development will destroy established habitat and endangered species, it will cause light pollution and it will adversely affect the community cohesion, in which it is being placed.
SP13 Rural Development
Instead of increasing the enjoyment of the countryside, a housing development would seriously decrease it! The site is located on the borders of an area of outstanding natural beauty where wildlife currently thrives. Allowing such a large development on such precious land is, I understand, absolutely against current rural development policy.
SP14 Maintaining and Enhancing the Natural Environment
I understand that any housing development will destroy our unique and bio diverse landscape and our protected habitats and lead to loss of biodiversity. There are very real dangers that any development will lead to the de-wilding of the site and the subsequent loss of the Marsh Fritillary Butterfly, Devils Bit Scabious and other winter visitors. Previous planning applications have absolutely failed to address the issue of habitat destruction (Which, I understand, the developers have been actively engaged in). Endangered species will be displaced and lost and riparian corridors will be blocked preventing otters (which I understand have low numbers in Wales) from travelling.
SP15 Protection and Enhancement of the Built and Historic Environment
I understand from the TRCG, that the appropriate use of this redundant building is certainly not to allow its demolition and replacement with a totally unsuitable housing development. Absolutely no consideration has been given to the wishes of the local community nor the protection of this historic site, in the current Developers plans.
SP16 Climate Change
I have been told that the destruction of Rhos pasture, trees and grassy marshland on this site would be an absolute disaster for the local environment. Paving over huge areas for roads and paths will create hard standing that will cause rain water to surge onto surrounding roads and properties, causing flooding. Previous planning applications have had few mitigating measures for renewable energy, carbon negative building materials or energy conservation schemes.
SP19 Waste Management
I have been informed that safeguarding resources would not be achievable if planning permission were granted for this site. The loss of trees and pasture would contribute to Climate Change while the amount of carbon that would be released during the construction phase alone would be damaging to the environment. I would therefore suggest that CCC reclassify the development site as community or public space.
I understand that you have already been informed of the importance of community space, which was highlighted In a recent supreme court ruling - Hilary Term (2023) UKSC 8 on appeal from (2020) EWCA civ 1751- (R (on the application of Day) (Appellant) v Shropshire Council (Respondent) (landmarkchambers.co.uk)) where the court, quite rightly, ruled in favour of the local community.
I would suggest that the plan, by the TRCG, for the site to be used for well-being, conservation and recreation (with a well-being centre, a conservation area with pond, and board-walks for recreation and conservation interpretation), would be much better. I would also remind you that the site is adjacent to the most important breeding ground for the Marsh Fritillary Butterfly in the Amman Valley and to your obligations to provide spaces to promote prosperity, health, happiness, and well-being in the widest sense. This would meet the current requirements on the following grounds:
SP1 Strategic Growth
The installation of Health and conservation facilities would be far more beneficial to the community than housing. This site is within easy reach of local Schools, so could be used as an outdoor education centre for children and adults alike.
SP2 Retail and Town Centres
Having a Community lead facility on this site benefits the whole Community.
SP3 Sustainable Distribution – Settlement Framework
I understand that the suggested project (The Tirycoed Well-being Centre) not only uses the existing building foundation as its base, but will also be managed sustainably, the exact opposite of the current proposals.

SP6 Strategic sites
This project, I have been told, will invest in the local Community and provide much need facilities for all, rather than benefiting already very rich people. This inward development will also create local sustainable jobs, benefit local business and bring a much needed boost to the local economy.
SP7 Employment and the Economy
I understand that his project will invest in the local Community and provide much need facilities for all, rather than benefiting Developers. This inward development will also create local sustainable jobs, benefit local business and bring a much needed boost to the local economy. It will also serve as a Community hub, allowing people to meet and interact, something a housing estate will actively discourage.
SP8 Welsh Language and Culture
The proposal to build houses on this site will simply allow wealthier people from outside the local area to have better homes. Our plan will bring the local community together and enhance its integration, keeping the Welsh language alive, rather than causing its demise due to the influx of non-Welsh speaking people.
SP9 Infrastructure
This site could be both built and managed to meet the needs of our local Community as required by the conditions of this section of the RLDP.
SP11 The Visitor Economy
With careful planning, the site could also be made to meet the requirements of local tourism and education. It is in an area of outstanding natural beauty and is full of rare and exotic wildlife.
SP12 Placemaking and Sustainable Places
I believe that the proposed Community development would endeavour to provide spaces to promote prosperity, health, happiness, and well-being in the widest sense. Furthermore the site would be both sustainably managed and built to enhance and improve the local biodiversity, with all the benefits this would bring.
SP13 Rural Development
Again, this site absolutely fulfils the requirements of this section of the RLDP. It actively improves and enhances the available facilities accessible to the local Community, while adding and improving local facilities for all.
SP14 Maintaining and Enhancing the Natural Environment
Habitat conservation is at the heart of what I understand this proposal will include, unlike the ugly development currently proposed, which has habitat destruction at its heart. Improving the landscape naturally, by using cattle to graze the Rhos pasture, establishing ponds and encouraging natural regeneration, are just some of the many ways I have been told that this proposal would fully meet this requirement of the RLDP.
SP15 Protection and Enhancement of the Built and Historic Environment
The current proposal to simply destroy the existing building on this site should be revisited. Any required works could be carried out sympathetically and in an environmentally sensitive way.
SP16 Climate Change
Again, the proposal fully meets these requirements by using sustainable methods and by protecting valuable natural assets. There would be no need to destroy vast areas of natural land, as would be the case if a housing development was allowed. The building of a well-being centre (with carbon negative and eco-friendly building materials) would have minimal impact on carbon stocks and carbon emissions.
SP17 Transport and Accessibility
This site already has transport links that can be used to reach it from all over Carmarthenshire. I understand that the plans would include access to Electric vehicle charging points, to encourage sustainable travel to the site.
SP18 Mineral Resources
These proposals would actively promote improvements to the environment encouraging carbon sequestration and improving the local landscape to the benefit of the environment.
SP19 Waste Management
I believe these proposals would be investing in solar and wind power installations to make the site self-sufficient for its energy and thus reducing reliance in carbon generation.


I therefore hope you will now give due consideration to both my and the Communities wishes to ammend your current proposals and allow the correct usage of this land.

No change

Please find my comments below re LDP

1. – I would like to give my support to the 2 sites included in Llanboidy and Llangynnin.
2. Look at policy regarding converting Barn/ Commercial buildings to residential use. At present you have to advertise the property on open market for 1 year before applying for planning and pay Section 106 contributions. Where by if you applied for holiday let the above are waivered.
3. Must look at building council houses in rural villages for young local families to rent. This would boost the local schools and shops and the welsh language.
4. Need to look at policy regarding how housing needs are monitored. At present you have to register for a council house in your area. There are no council houses in rural areas. That means young people are not going to register as they don’t want to live in towns miles away.
5. I would like to see the 10% policy re building in rural villages increased.
6. Regarding local need and affordable homes, the m2 build rate at present is not adequate with modern day needs.

Finally I fully support the Plaid’s response to the consultation to protect our rural communities and welsh language .