Polisi Strategol – SP4: Dull Cynaliadwy o Ddarparu Cartrefi Newydd

Allocate site for housing within Revised LDP.

Much of the historical growth of the communities in East Carmarthenshire has been by linear development, with concomitant advantages and disadvantages. In the Crosshands area, developments such as Maes yr Eithin have facilitated more efficient use of land for habitation in higher denisty developments, utilising land that was not good agricultural land, often being land recovered from previous industrial use. Rather than long strands of dwellings along the roads of the County, such developments have joined villages such as Crosshands and Cefneithin to generate a more cohesive community supported by nearby shops and other facilities. This could help to improve community health by residents walking or cycling to local shops, thereby improving sustainability by reducing car journeys. Local coffee shops also help to re-establish a sense of community and reduced isolation of residents.

The LDP strives to support the growth of the economy in Sir Gaerfyrddin and specifically in the Crosshands area. The area is also attractive to people living in the urban areas of the country seeking to move to an area with easier access to the beautiful coast and countryside of Sir Gaerfyrddin. It is clear, therefore, that additional residential developments will be required. Whilst the LDP allocates some land to this growth in residential property, for example 177 new homes at Emlyn Brickworks (PrC3/MU1), this does not appear to be sufficient to meet the foreseeable growth in future demand.

The location of Emlyn Home Farm has many positive aspects to facilitate the generation of a cohesive, sustainable and considerate community. Bordered by Penygroes, Crosshands and Gorslas, the 30 acres of the farm are insufficient to render the farm a viable agricultural entity, even if the land was of a prime agricultural standard, which it is unfortunately not. The ‘brownfield land’, which was previously a part of the Emlyn colliery and brickworks enterprise, provides and an ideal opportunity to regenerate this land which is now bisected by the new economic link road, which offers excellent access. The land is of a gently rolling nature with no flooding risks. Consequently, the land offers the opportunity for a number of possible development options.

Developing the entire 30 acres of the farm could generate a community of a variety of homes with the significant advantage that the pressure to build on open countryside would be reduced. A development of the entire farm could include green spaces, community areas and facilities, a playground and houses of high standards of construction. Sustainability would be the key guiding policy of the development, in terms of home construction (low-carbon heating and high levels of Welsh wool-based insulation), the access routes (pedestrian and cycling) to the local shops and facilities and the electronic communications infrastructure to facilitate home-working.

Construction in phases would minimise disruption to neighbours. Natural habitats will be included within the green spaces of the development to enable wildlife to live in harmony with the sustainable community.

No change to Plan.

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

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

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

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

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

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

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

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

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

Amend the Plan

Introduction

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

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

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

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

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

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

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

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

Policies and comments

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

No change.

Having reviewed the consultation document, Cwmpas sees a clear synergy between the key issues, challenges and vision statements within the Deposit Plan of the Revised LDP and community led housing programmes. Community-led housing is housing development where the community plays an integral role in identifying local needs and bringing a proposal forward with a view to delivering social and economic benefits to a local area. Such projects meet long term housing needs and provide affordable housing as defined within Welsh planning policy. Furthermore, there is support for community led housing within the Welsh Government ‘Programme for Government 2021 – 2026’.

Amend Plan

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

Amend the Plan

Barratt David Wilson Homes South Wales Ltd (“BDW Homes”) does not consider that the Deposit Revised Carmarthenshire LDP is sound as the Plan will not deliver the required number and mix of housing over the Plan period, for the reasons we have stated on the online consultation form, in relation to the deliverability of the proposed site allocations.
BDW has prepared a site-specific representation in support of the proposed allocation of Land off Heol-y-Mynydd, Bryn for residential use within the Second Deposit Revised Carmarthenshire Local Development Plan. This was previously submitted at the Candidate Sites stage of the LDP's preparation together with a Candidate Site Assessment Questionnaire. It is supported by the following documentation, which confirm the site’s suitability for residential development:
- Site Boundary Plan by Roberts Limbrick Ltd (ref: 9047 PL01);
- Concept Masterplan by Roberts Limbrick Ltd (ref: 9047 SK01A);
- Issues & Opportunities Plan by Roberts Limbrick Ltd (ref: 9047 SK02);
- Drainage Technical Note by BDW Homes (August 2018);
- Extended Phase I Habitat Survey by TerrAqua Ecological Services Ltd (July 2018);
- Initial Landscape and Visual Appraisal by Anthony Jellard Associates (28th July 2018); and
- Technical Note by Lime Transport (ref: 18130, 11th June 2018).
The above documentation is enclosed with this representation.
It is respectfully requested that Land off Heol-y-Mynydd, Bryn is included within the Deposit Revised LDP as a residential allocation for up to 160 homes.

Covering letter:

Dear Sir /Madam,
Carmarthenshire Second Deposit Revised Local Development Plan
Representation on behalf of Barratt David Wilson Homes South Wales Ltd regarding Land off
Heol-y-Mynydd, Bryn (SR/086/053)
We are pleased to submit this representation on behalf of Barratt David Wilson Homes South Wales
Ltd (‘BDW Homes’) in response to the current consultation on the Carmarthenshire Second Deposit
Revised Local Development Plan Consultation for the site Land off Heol-y-Mynydd, Bryn. The site is
recorded in the 2023 Site Assessment Table under reference SR/086/053 (Land off Heol-y-Mynydd,
Bryn).
Barratt Homes has an option agreement for the site, which has been promoted in part for residential
development through the previous LDP process. This submission is also made alongside the recent
representations in response to the Carmarthenshire Revised Local Development Plan 2018-2033.
Candidate Site and Preferred Strategy consultations.
Executive Summary
• We do not support the Council’s Strategic Policy SP4 housing requirement of 8,822 homes for
the plan period (2018-2033). We consider the Plan Period should be rolled forward by a further
two years, to 2021-2036, to take into account the time lost owing to the NRW intervention and
COVID-19 pandemic.
• We do not support Policy HOM1 which includes a number of housing allocations located within
Phosphate Sensitive Catchment Areas. The Council should reconsider their spatial distribution
of housing allocations to include additional allocations outside of phosphate areas.
• Accordingly, Bryn can accommodate future growth requirements, and the land off Heol-y-
Mynydd, Bryn should be included as an allocation.
Page 2 of 7
We have set out our full response to the 2nd Deposit Revised Plan below as well as our response
which was submitted as part of the previous Deposit Plan.
Paragraph 5.6 – A Carmarthenshire of Cohesive Communities
BDW Homes welcomes the recognition of the impact of the lack of delivery of new housing upon the
creation of Cohesive Communities. The delivery of new homes and the maintenance of a five year
supply of housing is essential to ensure that Cohesive Communities are created in line with the Well
Being of Future Generations Act. It is therefore crucial that proposed site allocations within the Plan
are deliverable. This is essential to ensure that the Plan accords with Test of Soundness 3. As
identified in later sections BDW Homes raise a number of concerns regarding proposed Allocations
and their impact upon the Council’s proposed Trajectory and lack of deliverability which has effects
Cohesive Communities.
Paragraph 6.4
BDW Homes is supportive of the proposed Vision for ‘One Carmarthenshire’ as it seeks to achieve an
appropriate balance between environmental, economic, social and cultural objectives. The proposed
Vision therefore complies with the holistic ‘Placemaking’ approach advocated by Planning Policy
Wales (Edition 10, p.16). The Vision also accurately reflects the Well-being Goals set out within the
WBFGA. BDW Homes particularly welcomes direct references within the Vision to securing
prosperous, cohesive and sustainable communities and the economic aspirations associated with the
Swansea Bay City Region.
Paragraph 7.6: Strong Connections - Strongly connected people, places and organisations that
are able to adapt to change.
BDW Homes is supportive of the wording of Strategic Objective SO6, which seeks to ensure that ‘The
principles of spatial sustainability are upheld by directing development to sustainable locations with
access to services and facilities..’. This Strategic Objective is therefore consistent with the ‘Key
Planning Principles’ set out within Planning Policy Wales (Edition 10, p.18) which seeks to ensure that
the planning system contributes to the long-term economic well-being of Wales, by making use of
existing infrastructure and facilities.
Paragraph 7.6: Prosperous People and Places - To maximise opportunities for people and
places in both urban and rural parts of our county.
BDW Homes supports Strategic Objective SO10, which refers to the delivery of an appropriate number
and mix of new housing meet society’s needs. The need to ensure that “there is sufficient housing
land available to meet the need for new private market and affordable housing” is one of the key issues
within the ‘Active & Social Places’ theme within Planning Policy Wales.
Paragraph 8.2
BDW Homes agrees that the use of the WG 2018-based subnational projections (4,359 homes) would
impact upon the historic growth of the County and would not deliver the quantity of homes required.
To this end, BDW broadly Homes supports the Council’s Preferred Strategic Growth Option, the tenyear
trend-based projection which would allow for 8,822 homes, on the basis that it seeks an ambitious
Page 3 of 7
but achievable level of growth to support the aspirations of the Strategic Regeneration Plan for
Carmarthenshire. However, BDW feels that a higher level of growth should be sought on the basis of
the National Development Framework’s aspirations for the South West National Growth Area, with its
focus on the Llanelli Area and secondary town of Carmarthen.
Preferred Option – Balanced Community and Sustainable Growth Strategy
BDW Homes is broadly supportive of the ‘Balanced Community and Sustainable Growth Strategy’ and
note that the strategy considers the role and function of settlements in seeking to assign growth. This
should ensure that new housing is directed to those areas that are likely to attract higher levels of
employment generation. In this regard, it is considered that more growth could be accommodated
within the Llanelli and South Gwendraeth Area.
Paragraph 9.11
BDW Homes supports the strategy of building in flexibility to ensure the delivery of sustainable growth
and to overcome any potential unforeseen deliverability issues, in line with national guidance.
However, the Council should ensure that sites are viable and deliverable before they are taken forward
as firm allocations in the LDP. There are concerns about several sites and their ability to contribute to
delivering the housing growth projected over the Plan period. Paragraph 4.2.10 of PPW (Edition 10)
states that, “The supply of land to meet the housing requirement proposed in a development plan must
be deliverable.”
Paragraph 11.79
It is acknowledged that windfalls can make an important contribution to the overall housing
requirement for the County. However, in order to ensure the deliverability of the housing requirement
then sufficient sites should be identified and allocated to meet this requirement. Windfall sites are
unidentified by definition and therefore should form part of the flexibility allowance only.
Strategic Policy SP4: A Sustainable Approach to Providing New Homes
Draft Strategic Policy SP4 sets out the Council’s overall housing requirement of 8,822 homes for the
plan period (2018-2033) and so provision has been made for 9,704 new homes. Owing to the delays
caused by COVID-19, which has resulted in a second Deposit Plan consultation, we consider it
necessary for the plan period, currently set at 2018-2033 to be rolled forward to 2021-2036.
Consequently, the Authority should consider the need for a higher provision of housing to
accommodate the additional two years for the plan period. Carmarthenshire County Council (CCC)
have noted that they consider that the Deposit Plan meets the ‘Tests of Soundness’ and so is in
general conformity with Future Wales 2040. According to the Planning and Compulsory Purchase Act
2004 and set out within National Planning Policy, there is a fundamental requirement for any Local
Development Plan to be found sound. To ensure that this policy meets the tests of soundness and is
justified, and effective, those allocations located within phosphate sensitive areas should be removed
and replaced with sites located outside of these areas.
To this end, BDW consider the inclusion of housing allocations within phosphate sensitive areas in the
2nd Deposit Revised Plan to be unsound as it fails the Council’s own Test of Soundness in respect of:
Page 4 of 7
• Test 2 the housing allocations located within phosphate areas are not sufficiently robust or
flexible to ensure compliance with national policy as set out in Planning Policy Wales (PPW),
and;
• Test 3 in allowing the inclusion of phosphate sensitive housing allocations the plan will not be
implemented owing to the lack of an agreed mitigation measure for phosphorous sites. To this
end, the projected housing figure will not be met.
To ensure the consistent delivery of dwellings, it is considered that additional sites should be allocated
within the Draft LDP to provide a contingency, should some allocated sites fail to be delivered at the
rate set out within the housing trajectory. This would ensure the consistent delivery of homes
throughout the Plan period.
Policy HOM1: Housing Allocations
BDW objects to a number of proposed allocations owing to concerns in relation to their suitability and
deliverability. The previous Deposit Plan response in relation to HOM1 has been set out below:
PrC2/h4
No progress of effort has been made to bring the site forward for a prolonged period. The site is not
considered to be deliverable within the Plan period.
PrC2/h10
BDW objects to the proposed allocation of this site. We have serious concerns regarding its
deliverability. The site is a former quarry and is covered by dense vegetation with complicated access
arrangements which are affected by Flood Risk Zone C2 constraints. It has not been demonstrated
that this site can be accessed without unacceptable flood risk consequences. The site is also
brownfield in nature, and it should be demonstrated that appropriate ground investigation work has
been undertaken to demonstrate that the site is viable and deliverable. The site should be removed
as a draft allocation from the Deposit Revised LDP.
PrC2/h22
BDW objects to the allocation of this site. It comprises an existing allocation within the adopted LDP
which is proposed to be ‘rolled’ forward by CCC. There is no evidenced justification for the continued
allocation of this site, given that no progress has been made since its first allocation in 2014. The
delivery of this site has been pushed back a year in every JHLAS since at least 201, which confirms
the lack of progress and deliverability of this site. This site should be removed as a draft allocation
from the Deposit Revised LDP.
PrC2/h23
The site is not deliverable during the plan period. It has a number of constraints, is not sustainable in
terms of its location and it is not supported by a robust masterplan.
Sec5/h2
The site is constrained, is not viable and is not deliverable within the plan period.
Page 5 of 7
PrC3/h4
This is an historic allocation and there has been little progress in bringing the site forward for
development despite extensive marketing. The site is not deliverable within the Plan period.
PrC1/MU2
BDW is concerned that whilst this is a major urban extension to the south of Carmarthen, there is no
confirmation that an end user is in place in the form of a residential developer to deliver the quantum
of development proposed within the Plan period. The deliverability of this site is therefore questionable.
Phosphate Sensitive Catchment Areas
In addition to the above, BDW Homes wholly object to a number of additional housing allocations
which fall within Phosphate Sensitive Catchment Areas. A detailed list of these housing allocations
have been provided in Table 1: List of Housing Allocations in Phosphates areas, as well as our detailed
response to each of the proposed housing allocation. A number of the sites have been included as
housing allocations as they have gained planning permission. We do not agree with the inclusion of
these sites as they should be listed as commitments. Similarly, those allocations included as they have
a planning application submitted and pending should not be automatically included as an allocation.
This is contrary to the tests of soundness, as those allocations being rolled forward within phosphate
sensitive areas are currently not suitable nor deliverable owing to NRW phosphorous guidance.
With regards to CCC’s efforts to solve the phosphate issue within the County, investigative work has
been undertaken which forms part of the LDP evidence base. From reviewing this work, it is evident
that CCC have no agreed mitigation measure to tackle the phosphate issue. A nutrient budget
calculator has been constructed which calculates the phosphate levels that a proposed residential
development in Carmarthenshire could produce. This is not a mitigation measure and so
Carmarthenshire are yet to find a suitable phosphate solution.
In addition, a Nutrient Mitigation Options Technical Review (2022) has been prepared by Ricardo
Energy & Environmental, outlining guidance on phosphorous mitigation options for use in
Carmarthenshire. Although the report provides a short list and review of possible mitigation options no
set option has been agreed upon. The report concludes ‘it is likely that all schemes will require
engagement with/by CCC, Natural Resources Wales, the Nutrient Management Board and
developers. Other stakeholders like landowners/land managers, Dwr Cymru Welsh Water and
environmental NGOs are likely to also have a role in delivery of specific solutions.’
To this end, BDW Homes wholly object to the allocation of sites within Phosphate Catchment areas
owing to the County having no established mitigation solution for development in phosphate areas. As
such, all housing allocations which fall within phosphate sensitive areas should be discounted from
the LDP, as these suits are not suitable nor deliverable. Additional more suitable sites should be
sought which are located outside of the phosphate sensitive areas. Land off Heol-y-Mynydd, Bryn is
a suitable location for development, being located adjacent to the settlement of Bryn/Llanelli and
located outside a phosphate sensitive area.
Page 6 of 7
Candidate Site Assessment - Land off Heol-y-Mynydd, Bryn (SR/086/053)
From reviewing the Candidate Site Assessment Table 2023 it appears Candidate Site (SR/086/053),
Land off Heol-y-Mynydd, has been filtered out during the stage 2 assessment process, owing to
concerns at the over intensification of residential development within the immediate area and that the
site will remain outside of the development limits. We wholly object to this decision and perceive the
assessment of the site as contrasting information in relation to the site’s constraints. Owing to the
allocation of two other sites within the settlement of Bryn, Maes Y Bryn (PrC2/h21) and Harddfan
(PrC2/h20), CCC have confirmed Bryn is a suitable location for development. Both housing allocations
will total 40 dwellings combined. Given Maes y Bryn benefits from planning permission for 34 dwellings
and planning conditions are currently being discharged, this site should not count towards the housing
provision of Bryn. On this basis, the proposed allocation of Land off Heol-y-Mynydd would not cause
an over intensification of the settlement of Bryn.
The candidate site presents an opportunity for a logical continuation of existing residential
development in Bryn. The Candidate Site is located within a sustainable location close to a number of
facilities and good transport links. This is evidenced in the accompanying Technical Note prepared by
Lime Transport confirms that desirable walking distances for commuting and school journeys is 500m,
while the acceptable walking distance is 1km and 2km comprises the preferred maximum. The majority
of roads in the vicinity of the Site (including Heol-y-Mynydd) accommodate pedestrian facilities,
thereby linking the Site to all local services and facilities.
In terms of local services and facilities, the Site is situated approximately 400m from Bryn Community
Primary School and 3km from Bryngwyn School. The Site is also situated 1.6km from Llwynhendy
Health Centre, 600m from Bryn Post Office and 600m from Bryn Village Hall. The Site is also situated
approximately 1.5km from Llwynhendy, which provides a wide range of services including a library,
convenience store, public house and various takeaway restaurants, beauty salons and other retail
stores. Llanelli Town Centre is situated 4km from the Site and Parc Trostre Retail Park is situated 3km
from the Site, both of which provide a variety of services and employment opportunities.
With regards to public transport, Table 2.1 of the Technical Note by Lime Transport confirms that the
Site is situated in close proximity (ranging from 450m to 1km) to a number of bus stops which provide
regular services to Llanelli, Pontarddulais and Swansea among other destinations. Llanelli train station
is also situated approximately 4km to the south-west of the Site, which is served by bus routes 110
and 111 which operate within the acceptable walking distance of the Site.
The submitted LVA states that due to recent and ongoing housing developments in the area, the
development of Land off Heol-y-Mynydd would now represent a logical rounding off of the settlement
boundary. Accordingly, we consider that Llanelli / Bryn is capable of accommodating a significant
proportion of the County’s growth over the next Plan period, and this Site is capable of making a
significant contribution to this growth.
A concept masterplan has been prepared by Roberts Limbrick Ltd illustrating the site can
accommodate up to 160 dwellings, open space, landscaping and associated infrastructure. This
proposed scale of development would accord with the Deposit Plan in terms of the scale of strategic
Page 7 of 7
site required to deliver the housing requirement. Additionally, it is considered to be an appropriate
extension to the settlement in this location.
The site falls within Cluster 2: Llanelli and Southern Gwendraeth Area which has been identified as a
‘national growth area’ within Future Wales. To this end, with the potential for up to 160 dwellings to be
delivered, this site is genuinely deliverable and can contribute to the identified housing need within the
locality.
Final Remarks
Overall, BDW Homes raise a number of concerns regarding the current Preferred Strategy, including:
• We do not support the Council’s Strategic Policy SP4 housing requirement of 8,822 homes for
the plan period (2018-2033). We consider the Plan Period should be rolled forward by a further
two years, to 2021-2036, to take into account the time lost owing to the NRW intervention and
COVID-19 pandemic, and is contrary to Tests of Soundness 2 & 3.
• Significant objections are raised in relation to Policy HOM1 which includes a number of
housing allocations located within Phosphate Sensitive Catchment Areas. The Council should
reconsider their spatial distribution of housing allocations to include additional allocations
outside of phosphate areas.
Consequently, support is provided for Land off Heol-y-Mynydd, Bryn, which is deliverable and
developer lead, it has a developer on board and ready to take the site forward. Accordingly,
Bryn/Llanelli can accommodate future growth requirements, and the land off Heol-y-Mynydd, Bryn
should be included as an allocation.
We would be grateful if we could be kept informed on the further progress of the plan and further
opportunities for engagement.
Yours sincerely,
Katherine Dowdall
Principal Planner

Comments made on allocations within the Phosphate Sensitive Catchment areas are highlighted in the supporting documents

Amend Plan to consider their allocation or removal

Barratt David Wilson Homes South Wales Ltd (“BDW Homes”) does not consider that the Deposit Revised Carmarthenshire LDP is sound as the Plan will not deliver the required number and mix of housing over the Plan period, for the reasons we have stated on the online consultation form, in relation to the deliverability of the proposed site allocations.
BDW has prepared a site-specific representation in support of the proposed allocation of Land off Heol-y-Mynydd, Bryn for residential use within the Second Deposit Revised Carmarthenshire Local Development Plan. This was previously submitted at the Candidate Sites stage of the LDP's preparation together with a Candidate Site Assessment Questionnaire. It is supported by the following documentation, which confirm the site’s suitability for residential development:
- Site Boundary Plan by Roberts Limbrick Ltd (ref: 9047 PL01);
- Concept Masterplan by Roberts Limbrick Ltd (ref: 9047 SK01A);
- Issues & Opportunities Plan by Roberts Limbrick Ltd (ref: 9047 SK02);
- Drainage Technical Note by BDW Homes (August 2018);
- Extended Phase I Habitat Survey by TerrAqua Ecological Services Ltd (July 2018);
- Initial Landscape and Visual Appraisal by Anthony Jellard Associates (28th July 2018); and
- Technical Note by Lime Transport (ref: 18130, 11th June 2018).
The above documentation is enclosed with this representation.
It is respectfully requested that Land off Heol-y-Mynydd, Bryn is included within the Deposit Revised LDP as a residential allocation for up to 160 homes.

Covering letter:

Dear Sir /Madam,
Carmarthenshire Second Deposit Revised Local Development Plan
Representation on behalf of Barratt David Wilson Homes South Wales Ltd regarding Land off
Heol-y-Mynydd, Bryn (SR/086/053)
We are pleased to submit this representation on behalf of Barratt David Wilson Homes South Wales
Ltd (‘BDW Homes’) in response to the current consultation on the Carmarthenshire Second Deposit
Revised Local Development Plan Consultation for the site Land off Heol-y-Mynydd, Bryn. The site is
recorded in the 2023 Site Assessment Table under reference SR/086/053 (Land off Heol-y-Mynydd,
Bryn).
Barratt Homes has an option agreement for the site, which has been promoted in part for residential
development through the previous LDP process. This submission is also made alongside the recent
representations in response to the Carmarthenshire Revised Local Development Plan 2018-2033.
Candidate Site and Preferred Strategy consultations.
Executive Summary
• We do not support the Council’s Strategic Policy SP4 housing requirement of 8,822 homes for
the plan period (2018-2033). We consider the Plan Period should be rolled forward by a further
two years, to 2021-2036, to take into account the time lost owing to the NRW intervention and
COVID-19 pandemic.
• We do not support Policy HOM1 which includes a number of housing allocations located within
Phosphate Sensitive Catchment Areas. The Council should reconsider their spatial distribution
of housing allocations to include additional allocations outside of phosphate areas.
• Accordingly, Bryn can accommodate future growth requirements, and the land off Heol-y-
Mynydd, Bryn should be included as an allocation.
Page 2 of 7
We have set out our full response to the 2nd Deposit Revised Plan below as well as our response
which was submitted as part of the previous Deposit Plan.
Paragraph 5.6 – A Carmarthenshire of Cohesive Communities
BDW Homes welcomes the recognition of the impact of the lack of delivery of new housing upon the
creation of Cohesive Communities. The delivery of new homes and the maintenance of a five year
supply of housing is essential to ensure that Cohesive Communities are created in line with the Well
Being of Future Generations Act. It is therefore crucial that proposed site allocations within the Plan
are deliverable. This is essential to ensure that the Plan accords with Test of Soundness 3. As
identified in later sections BDW Homes raise a number of concerns regarding proposed Allocations
and their impact upon the Council’s proposed Trajectory and lack of deliverability which has effects
Cohesive Communities.
Paragraph 6.4
BDW Homes is supportive of the proposed Vision for ‘One Carmarthenshire’ as it seeks to achieve an
appropriate balance between environmental, economic, social and cultural objectives. The proposed
Vision therefore complies with the holistic ‘Placemaking’ approach advocated by Planning Policy
Wales (Edition 10, p.16). The Vision also accurately reflects the Well-being Goals set out within the
WBFGA. BDW Homes particularly welcomes direct references within the Vision to securing
prosperous, cohesive and sustainable communities and the economic aspirations associated with the
Swansea Bay City Region.
Paragraph 7.6: Strong Connections - Strongly connected people, places and organisations that
are able to adapt to change.
BDW Homes is supportive of the wording of Strategic Objective SO6, which seeks to ensure that ‘The
principles of spatial sustainability are upheld by directing development to sustainable locations with
access to services and facilities..’. This Strategic Objective is therefore consistent with the ‘Key
Planning Principles’ set out within Planning Policy Wales (Edition 10, p.18) which seeks to ensure that
the planning system contributes to the long-term economic well-being of Wales, by making use of
existing infrastructure and facilities.
Paragraph 7.6: Prosperous People and Places - To maximise opportunities for people and
places in both urban and rural parts of our county.
BDW Homes supports Strategic Objective SO10, which refers to the delivery of an appropriate number
and mix of new housing meet society’s needs. The need to ensure that “there is sufficient housing
land available to meet the need for new private market and affordable housing” is one of the key issues
within the ‘Active & Social Places’ theme within Planning Policy Wales.
Paragraph 8.2
BDW Homes agrees that the use of the WG 2018-based subnational projections (4,359 homes) would
impact upon the historic growth of the County and would not deliver the quantity of homes required.
To this end, BDW broadly Homes supports the Council’s Preferred Strategic Growth Option, the tenyear
trend-based projection which would allow for 8,822 homes, on the basis that it seeks an ambitious
Page 3 of 7
but achievable level of growth to support the aspirations of the Strategic Regeneration Plan for
Carmarthenshire. However, BDW feels that a higher level of growth should be sought on the basis of
the National Development Framework’s aspirations for the South West National Growth Area, with its
focus on the Llanelli Area and secondary town of Carmarthen.
Preferred Option – Balanced Community and Sustainable Growth Strategy
BDW Homes is broadly supportive of the ‘Balanced Community and Sustainable Growth Strategy’ and
note that the strategy considers the role and function of settlements in seeking to assign growth. This
should ensure that new housing is directed to those areas that are likely to attract higher levels of
employment generation. In this regard, it is considered that more growth could be accommodated
within the Llanelli and South Gwendraeth Area.
Paragraph 9.11
BDW Homes supports the strategy of building in flexibility to ensure the delivery of sustainable growth
and to overcome any potential unforeseen deliverability issues, in line with national guidance.
However, the Council should ensure that sites are viable and deliverable before they are taken forward
as firm allocations in the LDP. There are concerns about several sites and their ability to contribute to
delivering the housing growth projected over the Plan period. Paragraph 4.2.10 of PPW (Edition 10)
states that, “The supply of land to meet the housing requirement proposed in a development plan must
be deliverable.”
Paragraph 11.79
It is acknowledged that windfalls can make an important contribution to the overall housing
requirement for the County. However, in order to ensure the deliverability of the housing requirement
then sufficient sites should be identified and allocated to meet this requirement. Windfall sites are
unidentified by definition and therefore should form part of the flexibility allowance only.
Strategic Policy SP4: A Sustainable Approach to Providing New Homes
Draft Strategic Policy SP4 sets out the Council’s overall housing requirement of 8,822 homes for the
plan period (2018-2033) and so provision has been made for 9,704 new homes. Owing to the delays
caused by COVID-19, which has resulted in a second Deposit Plan consultation, we consider it
necessary for the plan period, currently set at 2018-2033 to be rolled forward to 2021-2036.
Consequently, the Authority should consider the need for a higher provision of housing to
accommodate the additional two years for the plan period. Carmarthenshire County Council (CCC)
have noted that they consider that the Deposit Plan meets the ‘Tests of Soundness’ and so is in
general conformity with Future Wales 2040. According to the Planning and Compulsory Purchase Act
2004 and set out within National Planning Policy, there is a fundamental requirement for any Local
Development Plan to be found sound. To ensure that this policy meets the tests of soundness and is
justified, and effective, those allocations located within phosphate sensitive areas should be removed
and replaced with sites located outside of these areas.
To this end, BDW consider the inclusion of housing allocations within phosphate sensitive areas in the
2nd Deposit Revised Plan to be unsound as it fails the Council’s own Test of Soundness in respect of:
Page 4 of 7
• Test 2 the housing allocations located within phosphate areas are not sufficiently robust or
flexible to ensure compliance with national policy as set out in Planning Policy Wales (PPW),
and;
• Test 3 in allowing the inclusion of phosphate sensitive housing allocations the plan will not be
implemented owing to the lack of an agreed mitigation measure for phosphorous sites. To this
end, the projected housing figure will not be met.
To ensure the consistent delivery of dwellings, it is considered that additional sites should be allocated
within the Draft LDP to provide a contingency, should some allocated sites fail to be delivered at the
rate set out within the housing trajectory. This would ensure the consistent delivery of homes
throughout the Plan period.
Policy HOM1: Housing Allocations
BDW objects to a number of proposed allocations owing to concerns in relation to their suitability and
deliverability. The previous Deposit Plan response in relation to HOM1 has been set out below:
PrC2/h4
No progress of effort has been made to bring the site forward for a prolonged period. The site is not
considered to be deliverable within the Plan period.
PrC2/h10
BDW objects to the proposed allocation of this site. We have serious concerns regarding its
deliverability. The site is a former quarry and is covered by dense vegetation with complicated access
arrangements which are affected by Flood Risk Zone C2 constraints. It has not been demonstrated
that this site can be accessed without unacceptable flood risk consequences. The site is also
brownfield in nature, and it should be demonstrated that appropriate ground investigation work has
been undertaken to demonstrate that the site is viable and deliverable. The site should be removed
as a draft allocation from the Deposit Revised LDP.
PrC2/h22
BDW objects to the allocation of this site. It comprises an existing allocation within the adopted LDP
which is proposed to be ‘rolled’ forward by CCC. There is no evidenced justification for the continued
allocation of this site, given that no progress has been made since its first allocation in 2014. The
delivery of this site has been pushed back a year in every JHLAS since at least 201, which confirms
the lack of progress and deliverability of this site. This site should be removed as a draft allocation
from the Deposit Revised LDP.
PrC2/h23
The site is not deliverable during the plan period. It has a number of constraints, is not sustainable in
terms of its location and it is not supported by a robust masterplan.
Sec5/h2
The site is constrained, is not viable and is not deliverable within the plan period.
Page 5 of 7
PrC3/h4
This is an historic allocation and there has been little progress in bringing the site forward for
development despite extensive marketing. The site is not deliverable within the Plan period.
PrC1/MU2
BDW is concerned that whilst this is a major urban extension to the south of Carmarthen, there is no
confirmation that an end user is in place in the form of a residential developer to deliver the quantum
of development proposed within the Plan period. The deliverability of this site is therefore questionable.
Phosphate Sensitive Catchment Areas
In addition to the above, BDW Homes wholly object to a number of additional housing allocations
which fall within Phosphate Sensitive Catchment Areas. A detailed list of these housing allocations
have been provided in Table 1: List of Housing Allocations in Phosphates areas, as well as our detailed
response to each of the proposed housing allocation. A number of the sites have been included as
housing allocations as they have gained planning permission. We do not agree with the inclusion of
these sites as they should be listed as commitments. Similarly, those allocations included as they have
a planning application submitted and pending should not be automatically included as an allocation.
This is contrary to the tests of soundness, as those allocations being rolled forward within phosphate
sensitive areas are currently not suitable nor deliverable owing to NRW phosphorous guidance.
With regards to CCC’s efforts to solve the phosphate issue within the County, investigative work has
been undertaken which forms part of the LDP evidence base. From reviewing this work, it is evident
that CCC have no agreed mitigation measure to tackle the phosphate issue. A nutrient budget
calculator has been constructed which calculates the phosphate levels that a proposed residential
development in Carmarthenshire could produce. This is not a mitigation measure and so
Carmarthenshire are yet to find a suitable phosphate solution.
In addition, a Nutrient Mitigation Options Technical Review (2022) has been prepared by Ricardo
Energy & Environmental, outlining guidance on phosphorous mitigation options for use in
Carmarthenshire. Although the report provides a short list and review of possible mitigation options no
set option has been agreed upon. The report concludes ‘it is likely that all schemes will require
engagement with/by CCC, Natural Resources Wales, the Nutrient Management Board and
developers. Other stakeholders like landowners/land managers, Dwr Cymru Welsh Water and
environmental NGOs are likely to also have a role in delivery of specific solutions.’
To this end, BDW Homes wholly object to the allocation of sites within Phosphate Catchment areas
owing to the County having no established mitigation solution for development in phosphate areas. As
such, all housing allocations which fall within phosphate sensitive areas should be discounted from
the LDP, as these suits are not suitable nor deliverable. Additional more suitable sites should be
sought which are located outside of the phosphate sensitive areas. Land off Heol-y-Mynydd, Bryn is
a suitable location for development, being located adjacent to the settlement of Bryn/Llanelli and
located outside a phosphate sensitive area.
Page 6 of 7
Candidate Site Assessment - Land off Heol-y-Mynydd, Bryn (SR/086/053)
From reviewing the Candidate Site Assessment Table 2023 it appears Candidate Site (SR/086/053),
Land off Heol-y-Mynydd, has been filtered out during the stage 2 assessment process, owing to
concerns at the over intensification of residential development within the immediate area and that the
site will remain outside of the development limits. We wholly object to this decision and perceive the
assessment of the site as contrasting information in relation to the site’s constraints. Owing to the
allocation of two other sites within the settlement of Bryn, Maes Y Bryn (PrC2/h21) and Harddfan
(PrC2/h20), CCC have confirmed Bryn is a suitable location for development. Both housing allocations
will total 40 dwellings combined. Given Maes y Bryn benefits from planning permission for 34 dwellings
and planning conditions are currently being discharged, this site should not count towards the housing
provision of Bryn. On this basis, the proposed allocation of Land off Heol-y-Mynydd would not cause
an over intensification of the settlement of Bryn.
The candidate site presents an opportunity for a logical continuation of existing residential
development in Bryn. The Candidate Site is located within a sustainable location close to a number of
facilities and good transport links. This is evidenced in the accompanying Technical Note prepared by
Lime Transport confirms that desirable walking distances for commuting and school journeys is 500m,
while the acceptable walking distance is 1km and 2km comprises the preferred maximum. The majority
of roads in the vicinity of the Site (including Heol-y-Mynydd) accommodate pedestrian facilities,
thereby linking the Site to all local services and facilities.
In terms of local services and facilities, the Site is situated approximately 400m from Bryn Community
Primary School and 3km from Bryngwyn School. The Site is also situated 1.6km from Llwynhendy
Health Centre, 600m from Bryn Post Office and 600m from Bryn Village Hall. The Site is also situated
approximately 1.5km from Llwynhendy, which provides a wide range of services including a library,
convenience store, public house and various takeaway restaurants, beauty salons and other retail
stores. Llanelli Town Centre is situated 4km from the Site and Parc Trostre Retail Park is situated 3km
from the Site, both of which provide a variety of services and employment opportunities.
With regards to public transport, Table 2.1 of the Technical Note by Lime Transport confirms that the
Site is situated in close proximity (ranging from 450m to 1km) to a number of bus stops which provide
regular services to Llanelli, Pontarddulais and Swansea among other destinations. Llanelli train station
is also situated approximately 4km to the south-west of the Site, which is served by bus routes 110
and 111 which operate within the acceptable walking distance of the Site.
The submitted LVA states that due to recent and ongoing housing developments in the area, the
development of Land off Heol-y-Mynydd would now represent a logical rounding off of the settlement
boundary. Accordingly, we consider that Llanelli / Bryn is capable of accommodating a significant
proportion of the County’s growth over the next Plan period, and this Site is capable of making a
significant contribution to this growth.
A concept masterplan has been prepared by Roberts Limbrick Ltd illustrating the site can
accommodate up to 160 dwellings, open space, landscaping and associated infrastructure. This
proposed scale of development would accord with the Deposit Plan in terms of the scale of strategic
Page 7 of 7
site required to deliver the housing requirement. Additionally, it is considered to be an appropriate
extension to the settlement in this location.
The site falls within Cluster 2: Llanelli and Southern Gwendraeth Area which has been identified as a
‘national growth area’ within Future Wales. To this end, with the potential for up to 160 dwellings to be
delivered, this site is genuinely deliverable and can contribute to the identified housing need within the
locality.
Final Remarks
Overall, BDW Homes raise a number of concerns regarding the current Preferred Strategy, including:
• We do not support the Council’s Strategic Policy SP4 housing requirement of 8,822 homes for
the plan period (2018-2033). We consider the Plan Period should be rolled forward by a further
two years, to 2021-2036, to take into account the time lost owing to the NRW intervention and
COVID-19 pandemic, and is contrary to Tests of Soundness 2 & 3.
• Significant objections are raised in relation to Policy HOM1 which includes a number of
housing allocations located within Phosphate Sensitive Catchment Areas. The Council should
reconsider their spatial distribution of housing allocations to include additional allocations
outside of phosphate areas.
Consequently, support is provided for Land off Heol-y-Mynydd, Bryn, which is deliverable and
developer lead, it has a developer on board and ready to take the site forward. Accordingly,
Bryn/Llanelli can accommodate future growth requirements, and the land off Heol-y-Mynydd, Bryn
should be included as an allocation.
We would be grateful if we could be kept informed on the further progress of the plan and further
opportunities for engagement.
Yours sincerely,
Katherine Dowdall
Principal Planner

The extent of the site allocation as shown on the Deposit Plan Proposals map should be amended as stated in the summary above.

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
PED – Site PrC3/MU1 – Emlyn Brickworks
PED – Representations on Second Deposit Plan 4
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
PED – Site PrC3/MU1 – Emlyn Brickworks
PED – Representations on Second Deposit Plan 6
• 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)
PED – Site PrC3/MU1 – Emlyn Brickworks
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,
PED – Site PrC3/MU1 – Emlyn Brickworks
PED – Representations on Second Deposit Plan 10
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.
PED – Site PrC3/MU1 – Emlyn Brickworks
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
PED – Site PrC3/MU1 – Emlyn Brickworks
PED – Representations on Second Deposit Plan 12
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.

Amend Policy

Carmarthenshire Local Development Plan 2018-2033 – Deposit Draft
Objection on 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 w 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 Strategic Policy SP4 (A
Sustainable Approach to Providing New Homes). As a result, we offer the following for the
Authority’s consideration, and Inspector’s in due course.
Policy SP4 represents the Council’s strategic position with regard to the County’s provision
of new homes during the Plan period. It sets out that within the Plan period (2018-2033) the
document is expected to deliver “9,704 new homes to meet the identified housing
requirement of 8,822.” through a range of housing supply components, which are as follows:

• Housing Allocations (5+ homes)
o Land bank Commitments
o Completed Dwellings
• Windfall Allowance
o Small Site Component (less than 5 homes)
o Windfall Component (5+ Homes)
• Flexibility (+10%)

However, through our own examination and consideration, we have identified that two of the above components give rise for concern and in turn put into question the ability of the Plan to deliver the proposed ‘new homes’ figure cited above. These concerns are summarised as follows.

Housing Allocations (5+ homes)
Having reviewed all proposed housing allocations put forward by the Plan under the provisions of Policy HOM1, we have identified a significant number that are clearly in themselves undeliverable and these are in turn subject of separate individual submissions. Notwithstanding this, the sheer number of such sites is on its own a reason to question the ‘soundness’ of the Plan.

In addition to the above, we have concerns with regards to (a) how the number of units assigned to each allocation has been derived and (b) the ability of allocations in certain geographic areas of the County being capable of reaching those targets.

In its explanatory text of Policy SP4 at Paragraph 11.85, the Council advises that “Site numbers highlighted within the Policy HOM1 are intended to be indicative and been considered on a site by site basis. They will be subject to further consideration at application stage. Regard will also be had to the policies and provisions of this plan and other relevant design principles.”. Whilst it is recognised that such assigned figures are indeed often indicative to provide flexibility, there appears to be no clearly defined consistent process of assessment or assignment of such unit figures to individual sites. In the absence of this evidence and a clear account of how these unit figures have been reached, there is a question over the ‘soundness’ of the Plan in terms of the ability of the proposed housing allocations meeting the aforementioned ‘new homes’ target figure.

In addition to the above, we have concerns with regards to the assigned unit numbers for allocations within the river catchments of the Teifi and Tywi Special Area of Conservation (SAC). The challenges presented to all elements of the planning process as a result of the new regulations published by Natural Resources Wales (NRW) with regards to phosphates generated by proposed developments, particularly housing.
Through our own experience, solutions for overcoming the challenges raised by the aforementioned regulations have now been identified, in both sewered and non-sewered areas. However, in each case, there is a ‘land-take’ requirement, which has in turn significant implications for any proposed housing allocations within the two aforementioned SACs.

In a recent case this practice has been involved with at Cwmman (see accompanying layout), a site capable of physically accommodating 22 units is now only being proposed for 13, due to the on-site apparatus required to provide a satisfactory level of phosphate treatment.
Having examined those allocations being proposed in the two aforementioned SAC, it is clear that this potential 33%+ reduction in unit numbers has not been taken into account in assigning unit numbers as part of their inclusion in Policy HOM1. On this basis, again, there is significant doubt that these allocations will be capable of delivering anywhere near the number of new homes the Council expects. This in turn therefore questions the ‘soundness’ of one of the Plan’s strategic policies and in turn the Plan itself.

The above therefore clearly illustrates that there is significant concerns that the new homes figure quoted by Policy SP4 and the framework that supports its provision is undeliverable. As a result and on this basis, the 2nd Deposit LDP fails the required Tests of Soundness and consequently the Plan is ‘unsound’.

We therefore respectfully request that this Representation be given careful examination, and that the housing need figure be revisited to ensure that the document passes all the relevant tests of soundness.

Amend Plan / background documents as set out in summary.

Thank you for consulting the Welsh Government on the Carmarthenshire County Council Local Development Plan (LDP) 2nd Deposit plan and documents. It is essential the authority is covered by an up-to-date LDP to give certainty to local communities and business.
Without prejudice to the Minster’s powers, the Welsh Government is committed to helping Local Planning Authorities (LPAs) minimise the risk of submitting unsound plans by making comments at the earliest stages of plan preparation. The Welsh Government looks for clear evidence that the plan is in general conformity with Future Wales: The National Development Framework and aligns with Planning Policy Wales (PPW), and that the tests of soundness (as set out in the ‘LDP Manual’) are addressed.
National planning policies are set out in Planning Policy Wales (PPW) Edition 11, which seeks to deliver high quality, sustainable places through a place-making approach. The implementation of the core policy areas in PPW, such as adopting a sustainable spatial strategy, appropriate housing and economic growth levels, infrastructure delivery and place-making, are articulated in more detail in the LDP Manual (Edition 3). We expect the core elements of the Manual, in particular Chapter 5 and the ‘De-risking Checklist(s) to be followed. The development planning system in Wales is evidence led and demonstrating how a plan is shaped by the evidence is a key requirement of the LDP examination.
After considering the key issues and policies in Future Wales, the Welsh Government is of the view that the level and spatial distribution of growth is in general conformity with Future Wales: The National Development Framework. However, the Statement of General Conformity (Annex 1 to this letter) is a ‘caveated response’. Annex 2 of this letter raises fundamental inconsistencies regarding the total housing provision and until these matters have been addressed and their implications understood, it is not possible to give a firm view on matters of general conformity at this time. Annex 2 of this letter also highlights a range of issues that need to be addressed for the plan to align with PPW and DPM. Collectively, our comments highlight a range of issues that need to be addressed for the plan to be considered ‘sound’ as follows:
Annex 1 – General Conformity with Future Wales (Caveated Response)
· Regional Collaboration/Level of growth Further clarity required. Annex 2 – Core matters that need to be addressed (PPW and the DPM)
Our representations are separated into three categories set out by topic area, with further detail in the attached annex.
Category A: Fundamental issues that are considered to present a significant degree of risk for the LPA if not addressed prior to submission stage and may have implications for the plan’s strategy.
None.
Category B: Matters where it appears that the deposit plan has not satisfactorily translated national policy down to the local level and there may be tensions within the plan, namely (not exhaustive):
· Level of Housing Provision
· Delivery and Viability
· Restriction of new homes to Class C3 only
· Gypsy and Traveller Provision
· Best and Most Versatile Land (BMV)
Category C: Whilst not considered to be fundamental to the soundness of the LDP, we consider there to be a lack of certainty or clarity on the following matters:
· Flooding
· Renewable Energy
· Minerals
· Phosphates
I would urge you to seek your own legal advice to ensure you have met all the procedural requirements, including the Sustainability Appraisal (SA), Strategic Environmental Assessment (SEA) and Habitats Regulation Assessment (HRA), as responsibility for these matters rests with your authority. A requirement to undertake a Health Impact Assessment (HIA) arising from the Public Health (Wales) Act 2017, if appropriate, should be carried out to assess the likely effect of the proposed development plan on health, mental well-being and inequality.
It is for your Authority to ensure that the LDP is ‘sound’, and it will be for the Inspector to determine how the examination proceeds if you submit the plan without addressing the concerns we raise. My colleagues and I look forward to meeting you and the team to discuss matters arising from this response.

Amend Plan as set out in summary.

Thank you for consulting the Welsh Government on the Carmarthenshire County Council Local Development Plan (LDP) 2nd Deposit plan and documents. It is essential the authority is covered by an up-to-date LDP to give certainty to local communities and business.
Without prejudice to the Minster’s powers, the Welsh Government is committed to helping Local Planning Authorities (LPAs) minimise the risk of submitting unsound plans by making comments at the earliest stages of plan preparation. The Welsh Government looks for clear evidence that the plan is in general conformity with Future Wales: The National Development Framework and aligns with Planning Policy Wales (PPW), and that the tests of soundness (as set out in the ‘LDP Manual’) are addressed.
National planning policies are set out in Planning Policy Wales (PPW) Edition 11, which seeks to deliver high quality, sustainable places through a place-making approach. The implementation of the core policy areas in PPW, such as adopting a sustainable spatial strategy, appropriate housing and economic growth levels, infrastructure delivery and place-making, are articulated in more detail in the LDP Manual (Edition 3). We expect the core elements of the Manual, in particular Chapter 5 and the ‘De-risking Checklist(s) to be followed. The development planning system in Wales is evidence led and demonstrating how a plan is shaped by the evidence is a key requirement of the LDP examination.
After considering the key issues and policies in Future Wales, the Welsh Government is of the view that the level and spatial distribution of growth is in general conformity with Future Wales: The National Development Framework. However, the Statement of General Conformity (Annex 1 to this letter) is a ‘caveated response’. Annex 2 of this letter raises fundamental inconsistencies regarding the total housing provision and until these matters have been addressed and their implications understood, it is not possible to give a firm view on matters of general conformity at this time. Annex 2 of this letter also highlights a range of issues that need to be addressed for the plan to align with PPW and DPM. Collectively, our comments highlight a range of issues that need to be addressed for the plan to be considered ‘sound’ as follows:
Annex 1 – General Conformity with Future Wales (Caveated Response)
· Regional Collaboration/Level of growth Further clarity required. Annex 2 – Core matters that need to be addressed (PPW and the DPM)
Our representations are separated into three categories set out by topic area, with further detail in the attached annex.
Category A: Fundamental issues that are considered to present a significant degree of risk for the LPA if not addressed prior to submission stage and may have implications for the plan’s strategy.
None.
Category B: Matters where it appears that the deposit plan has not satisfactorily translated national policy down to the local level and there may be tensions within the plan, namely (not exhaustive):
· Level of Housing Provision
· Delivery and Viability
· Restriction of new homes to Class C3 only
· Gypsy and Traveller Provision
· Best and Most Versatile Land (BMV)
Category C: Whilst not considered to be fundamental to the soundness of the LDP, we consider there to be a lack of certainty or clarity on the following matters:
· Flooding
· Renewable Energy
· Minerals
· Phosphates
I would urge you to seek your own legal advice to ensure you have met all the procedural requirements, including the Sustainability Appraisal (SA), Strategic Environmental Assessment (SEA) and Habitats Regulation Assessment (HRA), as responsibility for these matters rests with your authority. A requirement to undertake a Health Impact Assessment (HIA) arising from the Public Health (Wales) Act 2017, if appropriate, should be carried out to assess the likely effect of the proposed development plan on health, mental well-being and inequality.
It is for your Authority to ensure that the LDP is ‘sound’, and it will be for the Inspector to determine how the examination proceeds if you submit the plan without addressing the concerns we raise. My colleagues and I look forward to meeting you and the team to discuss matters arising from this response.

Amend Plan as set out in summary.

Thank you for consulting the Welsh Government on the Carmarthenshire County Council Local Development Plan (LDP) 2nd Deposit plan and documents. It is essential the authority is covered by an up-to-date LDP to give certainty to local communities and business.
Without prejudice to the Minster’s powers, the Welsh Government is committed to helping Local Planning Authorities (LPAs) minimise the risk of submitting unsound plans by making comments at the earliest stages of plan preparation. The Welsh Government looks for clear evidence that the plan is in general conformity with Future Wales: The National Development Framework and aligns with Planning Policy Wales (PPW), and that the tests of soundness (as set out in the ‘LDP Manual’) are addressed.
National planning policies are set out in Planning Policy Wales (PPW) Edition 11, which seeks to deliver high quality, sustainable places through a place-making approach. The implementation of the core policy areas in PPW, such as adopting a sustainable spatial strategy, appropriate housing and economic growth levels, infrastructure delivery and place-making, are articulated in more detail in the LDP Manual (Edition 3). We expect the core elements of the Manual, in particular Chapter 5 and the ‘De-risking Checklist(s) to be followed. The development planning system in Wales is evidence led and demonstrating how a plan is shaped by the evidence is a key requirement of the LDP examination.
After considering the key issues and policies in Future Wales, the Welsh Government is of the view that the level and spatial distribution of growth is in general conformity with Future Wales: The National Development Framework. However, the Statement of General Conformity (Annex 1 to this letter) is a ‘caveated response’. Annex 2 of this letter raises fundamental inconsistencies regarding the total housing provision and until these matters have been addressed and their implications understood, it is not possible to give a firm view on matters of general conformity at this time. Annex 2 of this letter also highlights a range of issues that need to be addressed for the plan to align with PPW and DPM. Collectively, our comments highlight a range of issues that need to be addressed for the plan to be considered ‘sound’ as follows:
Annex 1 – General Conformity with Future Wales (Caveated Response)
· Regional Collaboration/Level of growth Further clarity required. Annex 2 – Core matters that need to be addressed (PPW and the DPM)
Our representations are separated into three categories set out by topic area, with further detail in the attached annex.
Category A: Fundamental issues that are considered to present a significant degree of risk for the LPA if not addressed prior to submission stage and may have implications for the plan’s strategy.
None.
Category B: Matters where it appears that the deposit plan has not satisfactorily translated national policy down to the local level and there may be tensions within the plan, namely (not exhaustive):
· Level of Housing Provision
· Delivery and Viability
· Restriction of new homes to Class C3 only
· Gypsy and Traveller Provision
· Best and Most Versatile Land (BMV)
Category C: Whilst not considered to be fundamental to the soundness of the LDP, we consider there to be a lack of certainty or clarity on the following matters:
· Flooding
· Renewable Energy
· Minerals
· Phosphates
I would urge you to seek your own legal advice to ensure you have met all the procedural requirements, including the Sustainability Appraisal (SA), Strategic Environmental Assessment (SEA) and Habitats Regulation Assessment (HRA), as responsibility for these matters rests with your authority. A requirement to undertake a Health Impact Assessment (HIA) arising from the Public Health (Wales) Act 2017, if appropriate, should be carried out to assess the likely effect of the proposed development plan on health, mental well-being and inequality.
It is for your Authority to ensure that the LDP is ‘sound’, and it will be for the Inspector to determine how the examination proceeds if you submit the plan without addressing the concerns we raise. My colleagues and I look forward to meeting you and the team to discuss matters arising from this response.

Amend Plan as set out in summary.

Thank you for consulting the Welsh Government on the Carmarthenshire County Council Local Development Plan (LDP) 2nd Deposit plan and documents. It is essential the authority is covered by an up-to-date LDP to give certainty to local communities and business.
Without prejudice to the Minster’s powers, the Welsh Government is committed to helping Local Planning Authorities (LPAs) minimise the risk of submitting unsound plans by making comments at the earliest stages of plan preparation. The Welsh Government looks for clear evidence that the plan is in general conformity with Future Wales: The National Development Framework and aligns with Planning Policy Wales (PPW), and that the tests of soundness (as set out in the ‘LDP Manual’) are addressed.
National planning policies are set out in Planning Policy Wales (PPW) Edition 11, which seeks to deliver high quality, sustainable places through a place-making approach. The implementation of the core policy areas in PPW, such as adopting a sustainable spatial strategy, appropriate housing and economic growth levels, infrastructure delivery and place-making, are articulated in more detail in the LDP Manual (Edition 3). We expect the core elements of the Manual, in particular Chapter 5 and the ‘De-risking Checklist(s) to be followed. The development planning system in Wales is evidence led and demonstrating how a plan is shaped by the evidence is a key requirement of the LDP examination.
After considering the key issues and policies in Future Wales, the Welsh Government is of the view that the level and spatial distribution of growth is in general conformity with Future Wales: The National Development Framework. However, the Statement of General Conformity (Annex 1 to this letter) is a ‘caveated response’. Annex 2 of this letter raises fundamental inconsistencies regarding the total housing provision and until these matters have been addressed and their implications understood, it is not possible to give a firm view on matters of general conformity at this time. Annex 2 of this letter also highlights a range of issues that need to be addressed for the plan to align with PPW and DPM. Collectively, our comments highlight a range of issues that need to be addressed for the plan to be considered ‘sound’ as follows:
Annex 1 – General Conformity with Future Wales (Caveated Response)
· Regional Collaboration/Level of growth Further clarity required. Annex 2 – Core matters that need to be addressed (PPW and the DPM)
Our representations are separated into three categories set out by topic area, with further detail in the attached annex.
Category A: Fundamental issues that are considered to present a significant degree of risk for the LPA if not addressed prior to submission stage and may have implications for the plan’s strategy.
None.
Category B: Matters where it appears that the deposit plan has not satisfactorily translated national policy down to the local level and there may be tensions within the plan, namely (not exhaustive):
· Level of Housing Provision
· Delivery and Viability
· Restriction of new homes to Class C3 only
· Gypsy and Traveller Provision
· Best and Most Versatile Land (BMV)
Category C: Whilst not considered to be fundamental to the soundness of the LDP, we consider there to be a lack of certainty or clarity on the following matters:
· Flooding
· Renewable Energy
· Minerals
· Phosphates
I would urge you to seek your own legal advice to ensure you have met all the procedural requirements, including the Sustainability Appraisal (SA), Strategic Environmental Assessment (SEA) and Habitats Regulation Assessment (HRA), as responsibility for these matters rests with your authority. A requirement to undertake a Health Impact Assessment (HIA) arising from the Public Health (Wales) Act 2017, if appropriate, should be carried out to assess the likely effect of the proposed development plan on health, mental well-being and inequality.
It is for your Authority to ensure that the LDP is ‘sound’, and it will be for the Inspector to determine how the examination proceeds if you submit the plan without addressing the concerns we raise. My colleagues and I look forward to meeting you and the team to discuss matters arising from this response.

Amend Plan

Representations to Carmarthenshire County Council 2nd Deposit Revised Local Development Plan
Consultation
Land Adjacent to Culla Road Roundabout (B4317), Carway (Candidate Site ref: SR/023/003)

CarneySweeney is instructed on behalf of our client, Ffos Las Ltd, to submit representations to the
current consultation on Carmarthenshire’s 2nd Deposit LDP. This letter accompanies the following:

 Completed Representation Form;
 Site Location Plan;
 Site Ref: SR/023/003 Reasonable Alternatives Site Assessment Proforma (Carmarthenshire
County Council, February 2023); and
 Candidate Site Submission Supporting Statement (prepared by WYG, first submitted at First
Deposit LDP candidate site consultation).

These representations are made in relation to land adjacent to Culla Road Roundabout (B4317),
Carway; a site which was submitted as a Candidate Site during the 2018 Call for Sites (Candidate Site
ref: SR/023/003). The site successfully passed all three stages of the LPA’s previous assessment
process, scoring highly. The site is in single ownership and is immediately deliverable. Notwithstanding
this, the site is not currently being progressed by the Council as a draft allocation. The LPA’s stated
reason for not currently allocating the site, as stated within its Site Assessment Table (2023), is:
“Whilst there are no adverse impacts to the development of this site, there is more suitable and
appropriate land available within the village to accommodate new development”.
Whilst not currently allocated, the site is included as a ‘Reasonable Alternative’ site by the LPA within
their Site Allocation Assessment - Reasonable Alternatives Report, February 2023. The report
reiterates that the site performed suitably in terms of the RLDP Site Assessment Methodology, including
Integrated Sustainability Appraisal objectives. A copy of the site’s proforma is also enclosed with this
submission and clearly demonstrates how favourably the site scores against the RLDP’s key objectives.

It is our firm view the Council should re-consider its decision not to allocate this site for housing
development, and to this end we wish to make the following representations.
Candidate Site Description and Context
Full details of the site’s characteristics and development potential are provided within the enclosed
Candidate Site Supporting Statement (2018) prepared by WYG. This Statement was previously
submitted to the LPA as part of the Call for Sites process.
In summary, the candidate site (ref: SR/023/003) comprises c. 5.3ha of land which is bound by existing
residential development to the north, comprising the built settlement of Carway, and to the south by the
Persimmon housing development at Ffos Las racecourse. The site’s location is considered highly
sustainable, given its immediate proximity to Carway, Ffos Las racecourse and Trimsaran, and
associated facilities. The allocation and subsequent ongoing delivery for housing of the adjacent
Persimmon sites1 also establishes the sustainability of this location to accommodate new housing.
The site is free from physical constraints, being relatively flat with no existing buildings. The site is not
located within any heritage, ecological or nature conservation designations and lies within Flood Zone
A.
The site can be readily accessed from the existing B4327 Culla Road Roundabout, with a secondary
access point available at Heol Dyffryn Aur to the south.
As outlined above the site is immediately deliverable and as previously concluded by officers there are
no adverse impacts to the development of this site.
Pre-Application Advice (ref: PRE/01319)
Since the previous Candidate Site submission Ffos Las Ltd has sought pre-application advice from
Carmarthenshire County Council in respect of the proposed development of the site for housing. A
written response was received from the LPA in March 2023 (application ref: PRE/01319).
Whilst the current NRW Development Advice Map identifies the site within flood zone A, the preapplication
response notes that based on the emerging draft NRW Flood Map for Planning, part of the
site lies within flood zone 3 (see Fig. 2 below). The pre-application response advises that in accordance
with TAN 15 (which is due to be adopted for decision making in June 2023) vulnerable development
such as housing is generally not permitted in Flood Zone 3.
1 Pursuant to outline planning permission for mixed use development at Ffos Las racecourse and surrounding land (pp ref:
S/11568).
www.carneysweeney.co.uk
Figure 1: NRW Flood Map for Planning extract for Carway
Whist we acknowledge the above, it is important to note only a small proportion of the site is affected
by this Flood Zone 3 designation and, most importantly, it lies partly within Flood Zone 3 for surface
water and small watercourses only and is not deemed at risk of river and sea flooding. The latest
available version of the TAN 15 (January 2023, Consultation Version), is clear that vulnerable
development such as housing is generally not considered acceptable in areas that are flood zone 3 for
Rivers and Sea flooding specifically:
“Where development is proposed in any area facing flood risk from rivers and the sea, the
planning authority will need to be satisfied that its location is justified. It is important that areas
in Zone 3 are used only as a last resort, and not at all for new highly vulnerable development.”
(TAN 15 Consultation Version 2023, pp 10.10) (our emphasis).
Whereas, in terms of surface water flood risk, TAN 15 (Jan 2023) notes:
“Locally appropriate approaches can be incorporated into the Development Plan using local
policies, and in the decision-making process for planning applications.” (pp 4.8).
“The [Flood Map for Planning] shows areas at risk of flooding from surface water and small
watercourses, split into ‘Flood Zone 2’ and ‘Flood Zone 3’. These are considerations for
planning authorities and must be integrated into plan-making processes and decision-making.
For some developments it will be possible and appropriate to include management and
mitigation measures (refer to section 8).” (pp 5.2) (our emphasis added).
“A Flood Consequences Assessment will be required for any new development proposal
located fully or partly in Flood Zones 2 and 3 - Surface Water and Small Watercourses.” (pp
8.7).
The emerging TAN15 does not preclude housing development within surface water Flood Zone 3; such
development will generally be acceptable, subject to detailed design and appropriate management and
mitigation.
Accordingly, any future development proposals at the site would be supported by a Flood
Consequences Assessment and Drainage Strategy and would be subject to the separate SAB approval
process to secure sustainable surface water drainage measures. This is eminently achievable at the
detailed design stage and, therefore, should not be considered a barrier to the allocation of the site.
Additionally, it should be noted that significant drainage infrastructure has already been implemented
at this location as part of the delivery of, firstly, Ffos Las racecourse and latterly the housing allocation
being delivered by Persimmon immediately to the south (site allocation ref. SeC8/h1).
In respect to other potential site-specific requirements, namely, further ecological investigation, we
envisage this being carried out to help inform detailed development proposals and ensure Biodiversity
Net Gain (BNG) is delivered by on site delivery and/or by offsetting.
Housing Need and Supply
The Council’s pre-application advice concludes that while development of the site would be considered
contrary to the development plan (given the site’s current status outside the existing settlement
boundary), there is noted potential for small areas of local needs housing adjacent to the development
limits (in Carway) provided there is an established genuine local need.
We note the 2nd Deposit Plan Strategic Policy – SP4 ‘A Sustainable Approach to Delivering Homes’
states that:
“In order to ensure the overall housing requirement of 8,822 homes for the plan period is met,
provision is made for 9,704 new homes in accordance with the settlement framework in order
to promote the creation and enhancement of sustainable communities.”
Various population and household growth projections were assessed to reach the above requirement
figure. The ten-year based projection from Turley’s Housing and Economic Growth Report was chosen
to be taken forward for the RLDP, which projects a total population increase of 14,468 and a
requirement for 588 new homes per year.
We understand this annual housing requirement reflects build rates since 2007, which are
approximately 501 homes per year (paragraph 4 of the Housing and Economic Growth Report, Turley,
November 2022). However, this figure is less than half that of the 2014 LDP housing target, which was
1,013 dwellings per annum. Carmarthenshire Council has failed to deliver sufficient homes to meet local
demand for a longstanding period; basing future delivery on inadequate past build rates merely
compounds the longstanding issue of undersupply going forward into the new plan period.
The supporting Housing and Economic Growth report importantly notes that:
“Undersupply may though have contributed towards residents of Carmarthenshire living in
larger households than was previously anticipated, some potentially being left with no choice
but to stay in the family home or share with other adults due to a shortage of available housing.”
(pp 5).
There is clear, genuine local need. The strong market interest and swift and ongoing delivery of the
existing allocation in Carway directly adjacent to the site is a strong demonstration, itself, of local need.
We consider the housing targets proposed within the 2nd Deposit are insufficient to address previous
undersupply and meet the demands of the growing local population across the new plan period. We
consider housing targets should be lifted accordingly.
In order to achieve the RLDP’s goals to “promote the creation and enhancement of sustainable
communities” (RLDP Policy SP4), additional housing should be directed towards sustainable
settlements such as Carway. Carway is an identified Service Centre within the settlement hierarchy and
is accordingly appropriate for additional housing allocations (as per RLDP Strategic Policy SP3).
The subject site adjacent to Culla Road Roundabout (ref: SR/023/003) represents a sustainably located
site, as established in principle by the neighbouring allocated sites (refs: SeC8/h1, which has been built
out and SeC8/h3, which benefits from outline planning consent). Furthermore, the site is immediately
deliverable and by the Council’s own measure scored highly in the LPA’s candidate site assessment
process. Based on the Council’s Site Assessment Table (2023), the only reason for rejecting the site
www.carneysweeney.co.uk
as an allocation is a perceived lack of need. However, we encourage the Council to revisit its previous
conclusion on this in the context of the Council’s persistent undersupply of housing and added
uncertainty regarding the deliverability of the Council’s proposed housing allocations. Paragraph 4.2.10
of Planning Policy Wales 11 (PPW) stresses the importance that “The supply of land to meet the
housing requirement proposed in a development plan must be deliverable.”
Phosphates and SAC
We understand one of the principal reasons for the Council’s current consultation on a 2nd Deposit Plan
was to evaluate NRW’s guidance on riverine phosphate levels. Within the County, there are two riverine
Special Areas of Conservation (SAC) that are affected by this guidance: the Afon Teifi and Afon Tywi.
Planning applications for development that may increase phosphate levels in these rivers need to
demonstrate nutrient neutrality for development to proceed.
The 2nd Deposit Plan’s evidence base includes a Nutrient Mitigation Options Technical Review report
prepared by Ricardo (June 2022). The report notes that the Pencader Sewage Treatment Works and
Llandovery Waste Water Treatment works have the highest number of planning applications
constrained by phosphorus (page iv of the report). Therefore, it is apparent that future housing
development in Pencader and Llandovery is particularly constrained by the need for nutrient neutrality.
There is now, in our view, significant doubts as to the deliverability of the housing sites allocated within
the 2nd Deposit in these two settlements in particular, namely:
 Ref: SeC14/h2 Land adjoining Maescader, Pencader for 24 dwellings;
 Ref: SeC14/h1 Blossom Garage, Pencader, for 30 dwellings;
 Ref: SeC15/h1 Land to north of Dan y Crug, Llandovery, for 61 dwellings;
 Ref: SeC15/h2 Land adjacent to Bryndeilog, Tywi Avenue, Llandovery, for 8 dwellings.
In particular, we question the deliverability of site allocation ref: SeC14/h2 Blossom Garage. This site
has been subject to a recent planning application refusal (ref: W/39283). One of the principal reasons
for refusal was the site being located within the catchment of Afon Tywi SAC and not demonstrating
phosphate neutrality or betterment.
We note allocation ref: SeC15/h1 in Llandovery listed above has been allocated for many years and
remains undeveloped. The LPA’s supporting Site Assessment Table (2023) indeed notes concerns
over the deliverability of this site, and therefore reduces the size of the allocation within the 2nd Draft
Deposit RLDP. The riverine SAC phosphates constraint makes this site even less deliverable.
Other settlements in the County that have housing allocations near to riverine SACs are Newcastle
Emlyn (which is also largely constrained by SSSI and Conservation Area designations) (allocations for
51 units); Pont-Tyweli (14 units); Cwmifor (8 units); Carmarthen (1,283 units); Burry Port (501 units);
Llanelli (1,516 units); and Llangennech (94 units).
It is highly likely that proposed housing allocations in locations affected by riverine SACs phosphate
constraints will not be deliverable, either in part or in full. Indeed, site ref SeC14/h2 above has already
failed to achieve planning permission. Combined, we understand the above affected settlements are
allocated to provide an estimated 3,590 homes. On an assumption that just c.25% of these allocations
failed to be delivered due to the riverine SAC phosphate constraint, this would lead to a significant
shortfall of c.897 homes throughout the Plan period.
Notwithstanding sites affected by the SAC phosphates constraint, there are other sites throughout the
County exhibiting deliverability issues. For instance, existing allocation Ref: SeC16/h1 - Llandeilo
Northern Quarter has been reduced in size due to deliverability concerns. We understand this site has
been allocated for a longstanding period without being delivered. Similarly, we note the below existing
allocations, totalling 115 units, have been reduced in size due to concerns over deliverability:
 Opposite Village Hall in Cwmifor for 16 units (ref: SC30/h1);
 Land at Maesarddafen, Llanelli for 94 units (ref: PrC2/h15);
www.carneysweeney.co.uk
 Heol Y Graig, Llwynhendy for 5 units (ref: PrC2/h28).
The 2nd Deposit Plan’s current reliance on riverine SAC phosphate affected housing allocations, and
other failed/constrained allocations gives rise to significant uncertainty as to the Plan’s effectiveness,
and, indeed, soundness.
Meanwhile, the subject land adjacent to Culla Road Roundabout (candidate site ref: SR/023/003) has
been excluded, on the seemingly sole basis that there is no need for the allocation. In regard to the
riverine SAC phosphate constraint, land at Culla Road is entirely unconstrained. As outlined previously
and acknowledged by officers there remain “…no adverse impacts to the development of this site…”.
We stress the site should be reconsidered for allocation.
Figure 3: Aerial view of Carway, overlaid with the existing settlement limit boundaries (shown in blue) and the
indicative site boundary (outlined in red)
Figure 3 clearly demonstrates the potential for development of the site as a logical “completion” or
“rounding” of the settlement of Carway, which is currently in two parts and physically divorced by the
subject site. Infilling the land between both parts of the settlement presents an opportunity to cohesively
develop the Service Centre settlement, without extending the built limits of the settlement or incurring
any further into the surrounding countryside. There has been significant market interest in the site from
housing developers, which indicates strong demand for the delivery of the site to meet local housing
need in Carway. The accompanying Supporting Statement sets out the merits to delivering the site for
much needed housing.

Summary
To summarise the above:
 Candidate site ref: SR/023/003 ‘Land adj. Culla Road Roundabout (B4317), Carway’ was
submitted as part of the 2018 Call for Sites. It scores highly across all stages of the LPA’s
assessment process;
www.carneysweeney.co.uk
 Pre-application advice (ref: PRE/01319) notes the site lies within Flood Zone 3 in the emerging
TAN15. The site lies within Zone 3 for surface water and small watercourses flooding only (i.e.
not river or sea flooding), whereby development for housing is generally acceptable; in
accordance with TAN 15 (Jan 2023);
 Site specific assessments such as ecological surveys etc. can be provided as part of any future
proposals at the site, to ensure Biodiversity Net Gain is achieved. There are no insurmountable
site constraints identified at this stage. The site is readily deliverable;
 The proposed provision for 9,704 homes within the RLDP to meet an identified requirement for
8,822 homes at c.500 homes per year is considered insufficient and will compound
longstanding undersupply. The County should be targeting an increase in annual build rates,
in order to provide for the future population growth and meet local need;
 Based on current draft allocations the riverine SAC phosphate constraint will likely significantly
constrain the delivery of housing across the County over the emerging plan period, particularly
in Pencader and Llandovery. The Council’s previous conclusions on need should be thoroughly
reassessed. The proposed site at land adjacent to Culla Road Roundabout (ref: SR/023/003)
is unconstrained and immediately deliverable.
 The sustainability of this site location is established and confirmed by the Council’s own site
assessment process. Delivery of the site for housing will logically complete the Carway
settlement and meet clear and genuine local need. There has already been significant market
interest in the site by developers. The site should be allocated for housing within the RLDP.
We trust that the above/ enclosed representations will be taken into consideration as part of the future
progression of Carmarthenshire’s RLDP.
We look forward to being kept informed of the RDP’s progress and hearing from you in due course.
Should you require any further information or wish to discuss further please do not hesitate to contact
us.

Newid fel y nodir
___
Change as set out

Ymateb aelodau Dyfodol i’r Iaith yn Sir Gaerfyrddin i’r 2il fersiwn Adneuo Cynllun Lleol Diwygiedig Sir Gaerfyrddin 2018 - 2033

Cynllunio a “Datblygwyr” Cyfnewid Poblogaeth

Peth rhyfedd yw iaith, fel y gwyddom. Pwy yn ei iawn bwyll sydd yn gwrthwynebu datblygiad?
Ond pe byddem yn holi nifer o bobl sydd wedi ymwneud â’r gyfundrefn gynllunio yn ddiweddar, byddem yn debygol o ddod ar draws sawl un sydd wedi colli eu pwyll.
Methodd cwmni Carillion yn 2018 oherwydd amddiffyn taliadau bonws i’r Cyfarwyddwyr, dulliau cyfrif anaddas a thalu sylw hollol annigonol i’r cynllun pensiynau. Gadawyd nifer sylweddol o adeiladau gan gynnwys ysbytai yn anorffenedig. Syrthiodd y gost o orffen adeiladuy y Royal Liverpool Hospital ar ysgwyddau’r trethdalwyr.
Adeiladwyd tai niferus ar wlyptiroedd ac ar ben siafftiau glo gan “ddatblygwyr” yng Nghymru a thu hwnt.

Mae cwmni Persimmon wedi adeiladu nifer sylweddol o dai yn y sir. Talwyd £7,000,000 i gyn Brif Weithredwr y cwmni, Jeff Fairburn, mewn bonws dros y blynyddoedd. Dyma’r cyfanswm mae’r un cwmni yn barod i’w dalu i adfer y peryglon ar naw safle lle wnaethant adeiladu tai anniogel.
Nid caenennau/ cladding, yw’r unig elfen beryglus mewn cartrefi yn y DG. Amcangyfrifir bod tua 700,000 o bobl yn byw mewn fflatiau anniogel a hyd at 3 miliwn arall mewn cartrefi nad oes modd sicrhau morgais arnynt am eu bod yn anniogel. Y “datblygwyr” a rheolau’r Llywodraeth sydd yn gyfrifol am y sefyllfa annerbyniol yma.

Cyflwynodd Llywodraeth San Steffan becyn o arian i gynorthwyo tua 200,000 o fflatiau sydd yn y tyrau uchaf. Gwnaethant hyn dan bwysau cyhoeddus. Cyndyn iawn oedd y “datblygwyr” i dderbyn cyfrifoldeb a chynnig iawndal i’r tenantiaid. Rhoddwyd degawd i’r diwydiant adeiladu dalu y £2biliwn o dreth caenen.Dim ond yn ddiweddar oherwydd bygythiadau y Gweinidog yn San Steffan i’w tynnu oddi ar rhestr y cwmniau cymeradwy, mae’r cwmniau wedi bwrw ati o ddifrif i ddatrys y problemau grewyd ganddynt. Ond ers trychineb Grenfell, pan losgwyd 72 o bobl i farwolaeth, ym Mehefin 2017, gwnaeth y pum cwmni adeiladu mwyaf £10 biliwn o elw. Rhywle yn swyddfeydd cyngor Kensington and Chelsea mae cais i “ddatblygu” Grenfell Towers.
Mae’n hen bryd bod yn llawer mwy amheus o “ddatblygwyr” a’u honiadau gwag ac ymddiried mewn cwmniau lleol i ateb gofynion lleol.

Oes angen cymaint o dai?
Nac oes.
Mae ymchwil gan Ian Mulheirn yn dangos bod y cyflenwad tai fel cyfanswm, yn ddigonol. Mae Mulheirn yn gyn economegydd yn y Trysorlys, a Chyfarwyddwr Ymgynghori gyda Oxford Economics. Bellach, mae’n Gyfarwyddwr Gweithredol a Phrif Economegydd gyda “Renewing the Centre” Sefydliad a grewyd gan y cyn Brif Weinidog, Tony Blair.
Yn 2019 cyhoeddodd “Tackling the UK Housing Crisis – is supply the answer?”. Mae’n canolbwyntio ar Loegr ond mae'n cyfeirio at Gymru. Rhag i mi gam gyfieithu, dyma graidd ei ddadl:

“ It is commonly claimed that we have failed to build enough houses to meet the demand for places to live.. But official data suggests this is not the case since the 1996 nadir of house prices, the English housing stock has grown by 168,000 units per year on average, while the growth in the number of households has averaged 147,000 per year. As a result, while there were 660,000 more dwellings than households in England in 1996, the surplus has since grown to over 1.1million in 2018.
Similar trends are apparent in Scotland where a surplus of 74,000 in 1996 had more than doubled to 169,000 by 2017.
And in Wales the surplus increased from 56,000 to 92,000.”

Mae dogfen “Dwelling Stock Estimates, Llywodraeth Cymru” Tachwedd 2019 yn ategu dadansoddiad Mulheirn:
“The figures seem to suggest that in 2019 there may have been a sufficient number of dwellings for the overall number of households in Wales” [tudalen 4]

Mae’r Adran Blaengynllunio yn honni ei fod yn craffu’n ofalus ar rhagamcanestyniadau’r Llywodraeth sydd yn ymwneud â phoblogaeth. Nid yw’n ymddangos bod digon o sylw wedi ei roi i’r dadansoddiad arbennig yma.

Mae Mulheirn yn priodoli’r sefyllfa gwbl gamarweiniol hyn i amcanestyniadau gwallus gan y Swyddfa Ystadegau Gwladol a’r Llywodraeth, sef yr asiantaethau y mae’r adrannau Blaengynllunio yn seilio ffigurau arnynt. Am ddegawdau, bu gor amcangyfrif y twf yn niferoedd yr aelwydydd. Canlyniad hyn oedd gor amcangyfrif cyfanswm y tai oedd eu hangen. Er fod y Swyddfa Ystadegau Gwladol wedi cydnabod y gwendid yn ddiweddar ac addasu’r ffigurau, mae Mulheirn o’r farn bod yr amcangyfrif yn dal i fod tua 15,000 y flwyddyn yn ormodol.
Nid yw’n gwadu nad oes problemau penodol megis di-gartrefedd, yr angen am dai cymdeithasol a thai fforddiadwy ond yn gyffredinol nid oes angen adeiladu miloedd o dai yn y DG ac yn sicr ddim yn y sir yma. Yn y cyfarfod ddiwedd 2020 mi wnaeth Adran Tai y Cyngor ateb y cwestiynau am ddarparu tai sydd yn ateb gofynion penodol y sir.
A yw’n amser i ystyried cyfuno’r Adran Tai a’r Adran Blaengynllunio gan ddeall mae anghenion pobl y sir ac nid “datblygwyr” sydd i hawlio blaenoriaeth bellach?

Y sefyllfa yn Sir Gaerfyrddin:
Pe bai poblogaeth y sir yn cynyddu oherwydd twf naturiol y boblogaeth gynhenid a swyddi niferus i gynnal pobl y sir, byddai angen mwy o dai, a gydag amser ac ymdrech byddai modd troi’r trai ieithyddol yn llanw, a gweld cynnydd yn nifer y siaradwyr Cymraeg. Ond nid fel yna mae.
Ers 2001 mae graddfa marwolaethau y sir wedi bod yn uwch na’r raddfa genedigaethau.
Mae’r un pwynt yn cael ei wneud yn yr Asesiad Iaith, ddiwedd 2019, dogfen mae’r Adran Blaengynllunio yn honni ei fod wedi talu sylw i’w chynnwys. Dyma ddyfyniad o’r Asesiad Iaith:

“ Yng nghyfnod 2017/18 cofrestrwyd y nifer fwyaf o farwolaethau ers 2001 [Atodiad 2.4, pwynt 9].
Os yw raddfa marwolaethau yn gyson uwch na’r raddfa genedigaethau, ac o gofio am yr allfudo sylweddol, byddai disgwyl i boblogaeth y sir syrthio. Nid dyna ddigwyddodd. Mae dogfen drafft cyntaf y CDLl yn egluro:
“Y prif ffactor sydd wedi dylanwadu ar newid i boblogaeth Sir Gaerfyrddin ers 2001/2 yw mewnfudo, lle mae mwy o bobl wedi symud i’r sir nag sydd wedi gadael”

Mae’r adroddiad Asesiad Iaith yn cadarnhau’r patrwm:
“mudo mewnol net yw sbardun mwyaf yn newid yn y boblogaeth o hyd. Gwelwyd cynnydd sydyn yn lefel y mewnlif net, a gyrhaeddodd tua +1,600 yn 2017/18, a gwelwyd cynnydd sylweddol o fwy na 700 o gymharu â’r flwyddyn flaenorol”

Mae dogfen drafft CDLL ddiweddaraf y Cyngor Sir yn tanlinellu parhad y patrwm
“Ers 2011, mae poblogaeth y sir wedi tyfu o ganlyniad i 4,100 o bobl ychwanegol, sef cynnydd o 2.2% mewn 10 mlynedd. Y prif ffactor sydd wedi dylanwadu ar y newid i boblogaeth Sir Gaerfyrddin ers 2001/2 yw mewnfudo.....Mae gan Sir Gaerfyrddin boblogaeth sydd yn heneiddio gyda nifer y marwolaethau yn fwy na genedigaethau bob blwyddyn ers 2001/2.
Cafwyd cynnydd mewn pobl yn symud i mewn i’r sir o fewn y grŵp oedran teulu ifanc 30-44 a grŵp oedran 0-14. Cafwyd cynnydd hefyd yn y grŵp oedran dros 65, stdd wedi cyfrannu at broffil poblogaeth sy’n heneiddio”

Tystiolaeth bellach o boblogaeth yn heneiddio yw ffigurau y plant sydd yn mynychu ysgolion cynradd y sir sydd yn disgyn dros y blynyddoedd:
2016 = 2120 ; 2017 =2065 ; 2018= 1995; 2019 + 1950; 2020+ 1965 a 2021 +1915

**Mae’r dystiolaeth yma, gomisiynwyd gan y Cyngor Sir, yn dangos y perygl i’r Gymraeg o or adeiladu. Nid yw’r Cynllun Datblygu drafft yn un credadwy , yn wyneb tystiolaeth yr Asesiad Iaith na thystiolaeth y Cyngor Sir**

Digwyddodd y Cyfrifiad ym mis Chwefror 2021 adeg y pandemig. Er nad oes gennym ffigurau swyddogol mae’n amlwg bod nifer ychwanegol o fewnfudwyr wedi dod i’r sir, fel siroedd eraill y gorllewin, yn chwilio am gartrefi mewn ardal llai poblog ac anheddau â gardd neu dir.

Heblaw am yr Asesiad Iaith, mae’r Adran Blaengynllunio yn honni talu sylw i farn a chanllawiau Llywodraeth Cymru. Wrth edrych ar y Strategaeth a Ffefrir gan yr Adran Blaengynllunio [ystyriwyd a gwrthodwyd strategaethau amgenach ..gweler isod] mi wnaeth Cyfarwyddiaeth Cynllunio Llywodraeth Cymru sylwadau i’w hystyried.
“mae angen i ganlyniad lefel/dosbarthiad y twf a gynigir ar gyfer y Gymraeg gael ei egluro yn enwedig gan fod lefelau uchel o fewnlifiad ac ymfudo rhyngwladol yn y gorffennol yn cael eu defnyddio i gyfiawnhau’r gofyniad am dai” [Methodoleg Asesu’r Effaith ar y Gymraeg –tud. 23/4]
Dyna’r gwirionedd. Adeiladu tai ar gyfer mewnfudwyr yn bennaf sydd wedi digwydd yn y sir, a hynny pan fo cyflenwad cyffredinol digonol o dai yn sir Gaerfyrddin. Mae ffigurau diweddaraf y Cyngor Sir yn nodi bod ychydig llai na 2,000 o dai gwag yn Sir Gaerfyrddin. Mae’r Adran Tai yn gwneud cynnydd wrth osod nifer o’r tai gwag ar gyfer trigolion y sir. Ond o ystyried y tai ar werth hefyd, sydd ar gael ar gyfer unrhyw dwf economaidd, pa mor debygol neu annhebygol fo hynny, mae stoc tai sylweddol yn y sir ar gyfer pobl sydd yn gweithio yma..

Byddai rhywun yn disgwyl i Adran Blaengynllunio mewn Cyngor Sir ystyried yn ofalus ac ategu i raddau, sylwadau gan Gyfarwyddiaeth Cynllunio y Llywodraeth ganolog. Nid yw’r bwriad i adeiladu 8,822 o dai rhwng 2018 -2033 yn gwneud hynny. Parhau i hybu mewnfudo pobl di- Gymraeg fydd canlyniad adeiladu’r nifer afresymol o uchel. Mae angen amser i weithredu polisiau blaengar y sir o ran Cymreigio ysgolion, gweithluoedd, prentisiaethau a sawl maes arall.

Mae gwaith y Mentrau yn ddigon heriol fel ag y mae, heb barhau i hybu y cyfnewid poblogaeth sydd mor niweidiol i’n hiaith gynhenid.
Mae’r gofid am ddiffyg dealltwriaeth yr Adran Blaengynllunio o flaenoriaethau ieithyddol y Cyngor Sir yn dwysau wrth edrych ar gymalau 11.173 Polisi Strategol SP8 yn honni:
“Trwy amcanu at dwf cynaliadwy bydd y cynllun hefyd yn cynyddu i’r eithaf y cyfleoeddi siaradwyr di-Gymraeg sy’n symud i mewn i’r sir gael ei hintigreiddio i fywyd cymunedol ar raddfa a chyflymder na fydd yn tanseilio bywiogrwydd a hyfywedd y Gymraeg a diwylliant Cymru”
Nid oes unrhyw esboniad sut mae hyn fod digwydd.

Mae canlyniadau Cyfrifiad 2021 yn dangos bod 26.4% o boblogaeth y sir wedi eu geni ”tu allan i Gymru”. Mae hyn yn gynnydd o 2.4% ers 2011 ac yn fwy na hanner y gostyngiad o 4.1% yn y ganran o siaradwyr Cymraeg yn y sir ers 2011. Nid yw’n ymddangos bod y polisi integreiddio yn un llwyddiannus iawn. Nid oes unrhyw dystiolaeth faint o’r 26.4% o boblogaeth y sir anwyd “tu allan i Gymru” sydd yn rhugl yn y Gymraeg.

Dull yr Adran Blaengynllunio o ateb cwestiynau o’r fath yw trosglwyddo cyfrifoldeb i adrannau eraill o’r Cyngor Sir, megis yr Adran Addysg. Cyfeiriwyd uchod at y lefel uchel o fewnfudo i’r sir yn 2017/18. Dadansoddwyd y garfan hynny gan y cwmni luniodd yr Asesiad Iaith. ‘Roedd 30% o’r bobl ddaeth i’r sir yn 2017/18 yn 45 oed neu’n hŷn. [Atodiad 2.4, tud. 96 a 99/100].
Ydy’r Adran Blaengynllunio yn disgwyl i’r garfan yma fynychu ysgol Gymraeg?
**Mae diffyg tystiolaeth gadarn i gyfiawnhau polisiau yn nodwedd o’r CDLl fel y mae**

Nid yw’r mewnfudo yn syndod o safbwynt economaidd na safon byw. Mae’r sir yn lle dymunol i fyw yn arbennig os yw eich sefyllfa economaidd yn un gysurus. Gyda graddfa llog mor isel, mae gwerthu tŷ a phrynu un arall cyfatebol am bris is yn ddull effeithiol o grynhoi swm sylweddol o arian. Erbyn Chwefror 2021, yn ôl Zoopla, gwerth cyfartalog tŷ yn Lloegr oedd £320,757 tra yng Nghymru y gwerth cyfartalog oedd £199,113. Mae’r bwlch wedi cau rhywfaint ers 2021 ond erys bwlch sylweddol rhwng pris cyfartalog tai yn y ddwy wlad.
Wrth gymharu prisiau tai, eto gan ddefnyddio Zoopla, mi wnaethom weld y gymhariaeth yma rhwng Sir Gaerfyrddin ac ardaloedd o Loegr.

BIrmingham Coventry Guildford Brighton Caerfyrddin Sir Gâr

Tŷ pâr [semi] £268k £273k £552k £578K £188k £178k
Ar wahan £463k £427K £1,047k £786k £321k £334K
Gwnaed yr ymchwil ym mis Mawrth 2023.
Mae tai ar werth yn y sir am £400mil, £500mil a mwy. Nid yw’n debygol bydd pobl leol yn medru prynu rhain.

Ceisiodd Mentrau Iaith y sir ganfod gan arwerthwyr tai, pwy sydd wedi bod yn prynu tai yn yr ardal yn ystod cyfnod y pandemig.. Mae’n siwr bod rhai wedi symud o ddwyrain Cymru a rhai wedi dychwelyd i’r sir. Ond mae’r cymhariaeth prisiau tai yn cynnig tystiolaeth ddigonol o fanteision ariannol symud o Loegr i Sir Gaerfyrddin. I’r Cyngor Sir, mae hyn yn fanteisiol ac mae’n siwr bod manteision i dirfeddianwyr, rhai busnesau a mwy o Dreth y Cyngor hefyd .
Ond rhoi pwysau ychwanegol sylweddol ar ein hetifeddiaeth unigryw wna’r mewnfudo. Er yn cydnabod bod rhai yn sicr o elwa o adeiladu 8,822 o dai rhwng 2018 – 2033, fel mudiad pwyso , mae Dyfodol i’r Iaith yn credu bod angen twf graddol a gofalus tra bod y polisiau i Gymreigio’r sir yn dwyn ffrwyth.

Twf Strategol ac Opsiynau Gofodol
Ystyriaethau a’r Dewis Gorau?
Mae’r teitl yn egluro blaenoriaethau’r adran – y defnydd o ofod neu “defnydd tir”, sef sail y gyfundrefn gynllunio. Nid effaith y defnydd tir ar bobl ond yn hytrach defnyddio’r gofod tir ar gyfer adeiladu gan ddadlau bod hynny yn arwain at welliannau economaidd. Honnir bod yr Adran Blaengynllunio yn “ystyried opsiynau a arweinir gan gyflogaeth.” Mae hyn yn ganmoladwy os yw’n cael ei wireddu ac nad yw’r adran yn syrthio i’r fagl bod adeiladu yn unig yn arwain at ffyniant economaidd.
Mae’r Adran Blaengynllunio hefyd yn ystyried “cyfradd anheddau gwag”. Cyfeiriwyd at hyn eisoes. Mae ychydig llai na 2,000 o dai gwag yn y sir. Felly, pe bai gwelliant cyflogaeth yn y sir a hynny yn lleihau’r allfudo gan bobl ifanc y sir, mae tai gwag yma’n barod ar gyfer y gweithwyr. Mae hefyd nifer sylweddol o adeiladau gwag yn y trefi a chefn gwlad gellir eu haddasu’n gartrefi pwrpasol.

Dadl bellach gan yr Adran Blaengynllunio yw bod angen “cysylltu twf poblogaeth a thwf cyflogaeth amcangyfrifiedig”. Ategir y bwriad trwy ychwanegu “Mae’r opsiynau a nodir yn rhagdybio bod datblygiadau tai heb gyfleoedd cyflogaeth yn yr un lleoliad eang, ac fel arall, yn llai cynaliadwy ac y dylid eu hosgoi” Mae’r ddadl yn gywir, mae angen tai ar gyfer gweithwyr. Felly mae angen ystyried y rhagolygon economaidd a chyflogaeth yn ofalus. [gweler isod]

Digon bregus oedd y rhagolygon cyflogaeth wrth i’r Adran Blaengynllunio ystyried yr opsiynau ar gyfer Cynllun Datblygu Lleol 2018 – 2033. Rhoddwyd ystyriaeth i 6 opsiwn. Yr un â’r amcanestyniad lleiaf o ran twf y boblogaeth a’r newid poblogaeth oedd Amcanestyniad Llywodraeth Cymru yn seiliedig ar 2018. Yn ôl y dadansoddiad hwn 4,359 o dai byddai eu hangen dros gyfnod y CDLl i ateb gofyniad o dwf yn y boblogaeth o 6,197. Gwrthodwyd yr opsiwn hwn ac eraill, hyd yn oed yr un oedd yn amcangyfrif bod angen 5,670 o dai i ateb galw twf amcanestynedig o 9,460 o bobl dros gyfnod y CDLl. Hwn oedd “Amrywiolyn “Poblogaeth Uchel” Llywodraeth Cymru yn seiliedig ar 2018.
**Nid yw CDLl y Cyngor Sir yn talu sylw digonol i amcanestyniadau Llywodraeth Cymru**

Mae pob un o’r opsiynau yn honni medru cysylltu’r adeiladu gyda “creu swyddi”. Yn amlwg bydd swyddi yn y maes adeiladu ac yn cynnig budd economaidd mewn rhai meysydd eraill. Ond eglurwyd eisoes bod nifer o bobl yn y sir yn chwilio am waith ac yn byw yn y sir. Hefyd, pa dystiolaeth sydd gan yr Adran Blaengynllunio mai swyddi lleol fydd yn cael eu creu gan “ddatblygwyr” mawr fel Persimmon? Mae’n bur debygol byddai nifer o’r gweithwyr yn dod o’r tu hwnt i’r sir, er mwyn ateb galw’r “datblygwyr” am weithwyr.
Nid oes pwrpas adeiladu tai os nad oes gwaith priodol i’r bobl fydd yn byw ynddynt, fel mae dyfyniadau’r adran yn ei gydnabod. Fel arall, y bobl ddaw i’r tai fydd pobl wedi ymddeol o’r tu hwnt i’r sir gan roi pwysau ychwanegol ar wasanaethau cyhoeddus lleol.

Ar ba sail gwrthodwyd yr opsiynau hyn?
Dyma eglurhad yr Adran Blaengynllunio am wrthod yr opsiynau eraill:
“O ystyried yr effeithiau negyddol posibl amlygir uchod, nid ystyrir ei bod yn ddoeth defnyddio prif amcanestyniad Llywodraeth Cymru sy’n seiliedig ar 2018 ar gyfer y CDLl Diwygiedig. Ni fyddai’n cyflawni Gweledigaeth ac Amcanion Strategol y Cynllun.”

Gan nad yw’r Cyngor Sir yn barod i dderbyn dadansoddiadau Llywodraeth Cymru, mae angen ystyried pwy sydd fwyaf realistig [isod].
Cawn eto yn sylwadau’r adran y cysylltiad hollol aneglur rhwng adeiladu a chadw pobl ifanc yn y sir. Mae ymateb Cymdeithas yr Iaith i’r honiadau annelwig yn llygad ei le:
“Nid yw gobaith ac uchelgais yr un peth â tystiolaeth”. Yn union.

Fwy nag unwaith, mae’r Adran Blaengynllunio yn nodi bod sylw wedi ei roi i’r Asesiad Effaith ar y Gymraeg wnaeth y Cyngor Sir yn 2019. ‘Roedd hyn i’w groesawu. Prin yw’r cynghorau sydd yn rhoi’r fath ystyriaeth i effaith cynllunio ar ein hiaith genedlaethol. Ond mae angen ystyried a chofio mai trafod y Strategaeth a Ffefrir blaenorol, sef adeiladu 8,835 o dai wnaeth yr Asesiad. Mae’r Opsiwn a Ffefrir newydd yr un mor debygol o achosi niwed mawr i’r Gymraeg a gwneud gwaith yr asiantaethau ar y Fforwm Iaith, a mudiadau eraill yn fwy heriol fyth. Anwybyddwyd yr opsiynau oedd yn cynnig twf graddol a fyddai’n cynnig cyfle i’r holl waith adfer y Gymraeg ddwyn ffrwyth dros gyfnod y Cynllun Datblygu.

Y Rhagolygon Economaidd:
Uchod, fe gawsom awgrym fod yr Adran Blaengynllunio yn cyplysu adeiladu tai gyda anghenion cyflogaeth y sir. Felly, beth yw’r rhagolygon economaidd erbyn hyn?
Mae’r CDLl diweddaraf yn rhoi pwyslais trwm ar Fargen Ddinesig Bae Abertawe i greu swyddi a ffyniant. Y ddau brosiect pwysicaf yn y sir yw’r Egin lle mae canolfan S4C a Pentre’r Awel ger Llanelli. Yn y CDLl diwethaf, ceisiwyd ein perswadio byddai Canolfan yr Egin yn diogelu ac , o bosib, yn hybu’r Gymraeg yn yr ardal. Tua 50 o swyddi yn uniongyrchol gysylltiedig â S4C sydd yno. Gerllaw bwriadwyd adeiladu 1,200 o dai. Ar gyfer pwy oedd y rhain?
Piler arall yn twf economaidd arfaethedig y sir yw Pentre Awel ar gyrion Llanelli. Y targed dros y 15 mlynedd nesaf yw “creu hyd at 2,000 o swyddi” a rhoi “hwb o £467 miliwn i’r economi”. Yn yr union ardal, collwyd mwy na 200 o swyddi yn ffatri Schaeffler a 90 arall o ffatri Calsonic yn gymharol ddiweddar. Yn ystod cyfnod Covid cauodd ffatri AIM Altitude yn Dafen a cholli 100 o swyddi da ychwanegol. Dyma tua 400 o weithwyr lleol a fyddai ar gael, gyda’r hyfforddiant priodol, i weithio yn Pentre Awel , ac sydd yn byw mewn tai yn yr ardal eisoes. Mae Llanelli yn ne ddwyrain y sir ac yn gyfleus i Abertawe a Chastell Nedd Port Talbot, ychydig i’r dwyrain, all ddiwallu anghenion Pentre Awel, heb fynd ati i adeiladu miloedd yn rhagor o a dai yn yr ardal.

Cyflymodd y pandemig y tueddiad oedd eisoes yn bodoli i siopa arlein.Yn anffodus, bydd llawer rhagor o weithwyr yn colli eu swyddi oherwydd hyn. Mae Debenhams wedi cau yng Nghaerfyrddin a siopau eraill eisoes wedi diflannu o ganol y dref. Bydd yr un patrwm yn digwydd mewn trefi fel Llanelli a Rhydaman. Digon trist yw canol tref Llanelli ar hyn o bryd ac mae’n gysur deall bod trafodaethau wedi digwydd i newid cymeriad ac adfywio’r ardal. Mae’n dda gweld nifer o siopau llai yn agor, ond go brin gallant gynnig y nifer o swyddi oedd yn y siopau cadwyn mawr. Yng nghefn gwlad, ‘rydym wedi gweld cau nifer o ganghennau y banciau mawr a cholli swyddi yn sgîl hynny. Dyma rhagor o weithwyr sydd eisoes yn byw mewn tai yn y sir ac yn barod i weithio.

Dylai cynllunio adferiad canol trefi’r sir fod yn flaenoriaeth i’r Adran Blaengynllunio. Eisoes, mae nifer o gynghorau yn paratoi i addasu natur canol trefi, gan gynnwys adnoddau hamdden a throi siopau gwag yn aneddiadau pwrpasol i drigolion lleol. Nid adeiladu miloedd o dai yw’r flaenoriaeth, ond sicrhau gwaith sydd yn gweddu i’r sir ar gyfer pobl sydd, ar y cyfan, eisoes yn byw yma.

Mae dogfen “Plans for Carmarthenshire’s economic recovery and growth” yn gwneud y pwynt
“It sets out the authority’s aims to help businesses replace more than 3,000 jobs that have already been lost during the pandemic and safeguarding and replacing up to 10,000 jobs that may have been, or are at high risk of being lost when furlough ends”
Mae diogelu swyddi a chreu swyddi i ateb gofynion poblogaeth bresennol y sir yn ddigon o her. Go brin fod angen 8,800 o dai ychwanegol allai ddenu pobl a fyddai’n ennill y blaen ar y trigolion lleol o ran cael y swyddi a gollwyd.

Mae “uchelgeisiau economaidd y sir” yn ddelfryd digon canmoladwy ond mae’n ymddangos mor bell o realiti â rheinosoros yn dawnsio bale! Twf graddol a gwella’r isadeiledd yw’r uchelgais realistig ac mae’r adran ar ddatblygu gwledig yn cynnig arweiniad deallus i’r cyfeiriad yma. Enghraifft o’r hyn gellir ei wneud yn realistig yw’r defnydd o’r £36.8 miliwn o Gronfa Rhannu Cyfoeth y DU ar gyfer cymdeithasau a busnesau cymunedol a phrosiect Llwybrau Cerdded a Seiclo Dyffryn Tywi.

Dogfennau Poblogaeth a Thai:
Mae adrannau Blaengynllunio yn astudio dogfennau sydd yn ceisio rhagweld tueddiadau poblogaeth ac aneddiadau. Nid yw’r rhain yn ragolygon pendant o’r hyn fydd yn digwydd ond yn amcanestyniadau yn seiliedig ar dueddiadau, Mae nifer ohonynt yn cadarnhau yr hyn sydd yn gynyddol amlwg i ni.
Ystadegau cryno ar gyfer rhanbarth De-orllewin Cymru: 2020 [Llywodraeth Cymru , Mai 20 2020]
“Gan edrych ar awdurdodau lleol, yn Sir Gaerfyrddin y cafwyd y newid net mwyaf yn y boblogaeth oherwydd mudo a newidiadau eraill yn ystod y cyfnod 2017/18. Gwelwyd newid naturiol negyddol yn y pedwar awdurdod lleol yn ystod y cyfnod hwn, sy’n golygu bod nifer y marwolaethau yn uwch na nifer y genedigaethau. Roedd y newid naturiol negyddol uchaf yn Sir Gaerfyrddin”
Mewn geiriau eraill, mae mwy wedi marw na cael eu geni yn y sir a hynny ar raddfa uwch na’r dair sir arall. Ond oherwydd mudo, ‘roedd “ y newid yn y boblogaeth oherwydd mudo net a newidiadau eraill yn gadarnhaol”. Ystyr “cadarnhaol” yw cynnydd i’r ystadegydd, ond i garedigion y Gymraeg, golyga her ychwanegol o geisio cymathu mwy fyth o bobl di-Gymraeg.
Mae Stats Cymru yn cynnig cyfansymiau ar gyfer 2016/7.
2016/7 - Mewnlif mewnol [o fewn y DU] 6,702 All-lif mewnol 6,080
Yn 2018/19 - Mewnlif mewnol [o fewn y DU] 6,900 All –lif mewnol 5,900
[Amcanestyniadau poblogaeth awdurdodau lleol ar 2018/19]

Pa fath o bobl sydd yn mudo? Gwyddom bod nifer sylweddol o bobl ifanc yn gadael y sir yn flynyddol. Pwy sydd yn cymryd eu lle? Ai pobl ifanc fydd yn dychwelyd i’r sir neu fewnfudo gan bobl oed gwaith fel y mae’r Adran Blaengynllunio yn darogan wrth adeiladu gymaint o dai?

Mae Amcanestyniadau poblogaeth awdurdodau lleol sy’n seiliedig ar 2018, Cymru [diwygiedig]
a gyhoeddwyd ym mis Awst 2020, yn ceisio rhagweld yr hyn sydd yn debygol o ddigwydd. Mae’n rhagweld cynnydd o 2.4% ym mhoblogaeth y sir erbyn 2028, fyddai’n dod â chyfanswm poblogaeth Sir Gaerfyrddin i 192,100. Mae hyn 1.7% yn uwch na’r amcanestyniad yn seiliedig ar ffigurau 2014.
Beth fydd yn ysgogi’r cynnydd yn y boblogaeth?
“Amcanestynnir y bydd mudo yn ychwanegu at faint y boblogaeth ar gyfer mwyafrif yr awdurdodau lleol yng Nghymru yn ystod y cyfnod 2018 -2028......Fodd bynnag, ar gyfer y mwyafrif o awdurdodau lleol, bydd mudo net positif yn uwch na’r newid naturiol negatif, gan arwain at gynnydd cyffredinol yn y boblogaeth”
[Cofier ystyr “positif” a “negatif” i’r ystadegwyr}
Gwireddwyd y ddamcaniaeth yng nghyfrifiad 2021. Cynyddodd y ganran anwyd “tu allan i Gymru” o 24% i 26.4%.
Sir Gaerfyrddin - 2021 Geni1,540 Marw 2,592 2020 Geni 1,660 Marw 2,404
2019 Geni 1,744 Marw 2,202 2017 Geni 1,817 Marw 2,230
2016 Geni 1,878 Marw 2,266 .... yr un patrwm ers 2001/2

Lleihad yn nifer y bobl 16 -64 oed fydd yn 17 o’r awdurdodau lleol, gan gynnwys Sir Gaerfyrddin. Dyma’r bobl mae’r Adran Blaengynllunio yn ei honni fydd yn dod i fyw yn y tai sydd i’w hadeiladu. Yn wir, mae’r graff ar dudalen 5 o’r Asesiad Iaith yn dangos mai cynnydd yn yr oed 65+ a 75+ sydd yn debygol rhwng 2018 – 2028. Yn ogystal â chreu heriau i’r gwasanaethau cymdeithasol nid yw’r ystod oedrannau hyn yn debygol o ddysgu Cymraeg. Felly, rhagweld y patrwm o fewnfudo a hynny’n cynnwys canran sylweddol o bobl mewn oed, ac allfudo gyda nifer sylweddol o bobl ifanc a addysgwyd yn y sir wna’r dadansoddiad. Mae hefyd yn rhagweld y patrwm o’r raddfa marwolaethau yn parhau i fod yn uwch na’r raddfa genedigaethau hyd 2028.

Mae dogfennau swyddogol yn dangos symudiad graddol ond clir at rentu ar draul perchnogaeth. Mae’r ddogfen Dwelling Stock Estimates a gyhoeddwyd ym mis Mawrth 2019 yn nodi bod 9,200 o aneddiadu yn y sir yn cael eu rhentu oddi wrth y Cyngor lleol a 3,200 oddi wrth landlordiaid cymdeithasol. Mae’n siwr bod angen cartrefu pobl mewn angen a chynnig aneddiadau addas iddynt. Ond mae rhywfaint o bryder fod nifer o’r cartrefi cymdeithasol yn y sir yn cael eu gosod i bobl o Loegr ac os yw hyn yn digwydd mae’n sicr o wanhau’r iaith ymhellach.

Tuedd arall sydd eisoes wedi cychwyn ac yn debygol o gyflymu yw cartrefi addas i un person. Y disgwyl yw bydd y galw am y math yma o annedd yn cynyddu 27% erbyn 2039. Mae angen i adrannau Blaengynllunio fod yn ymwybodol o’r tueddiadau hyn ac addasu’r amcanestyniadau yng ngoleuni’r datblygiadau a’r dystiolaeth.

Yr Adran Blaengynllunio, Llywodraeth Cymru a’r Gymraeg:
Mae Llywodraeth Cymru yn anelu at sicrhau miliwn o siaradwyr Cymraeg erbyn 2050 ac mae cyfeiriad at le’r Gymraeg mewn nifer o ddogfennau y Llywodraeth. Mae’r CDLL yn cyfeirio at Ddeddf Llesiant Cenedlaethau’r Dyfodol sydd yn cynnwys yr amcan i greu
“Cymru â diwylliant bywiog lle mae’r Gymraeg yn ffynnu”
** Nid yw adeiladu tai fydd yn denu rhagor o fewnfudwyr di- Gymraeg yn gyson â’r amcan hyn**.

Yn wahanol i’r CDLl drafft blaenorol,mae un cyfeiriad y tro hwn at ddogfen Llywodraeth Cymru “Miliwn o Siaradwyr erbyn 2050” . Yna cawn “ I gyrraedd y nod hwn bydd y Cyngor yn cefnogi,hyrwyddo a gwella’r Gymraeg fel iaith gymunedol hyfyw trwy sicrhau bod cyfleoedd cyflogaeth a thai digonol a chymesur i gynnal cymunedau gwledig a threfol y sir a thrwy roi fframwaith monitro effeithiol ar waith”
Gallwn groesawu’r bwriad i gynnig cyflogaeth deilwng a digonol i bobl y sir. Yn ein barn ni, nid oes angen 8,822 o dai i wireddu’r bwriad. Mae angen eglurhad ar y gyfundrefn monitro achos mae ffigurau Cyfrifiad 2021 yn dangod na fu yn effeithiol, os yw’n bodoli o gwbl. Gostyngodd y ganran o siaradwyr Cymraeg y sir o 44.0% i 39.9% Yn rhyfeddol, mae’r ddogfen yn cyfeirio at Gyfrifiad 2011 ac nid un 2021!
** Dyma enghraifft arall o dalu sylw annigonol i bolisi cydnabyddedig Llywodraeth Cymru a hynny mewn sir gyda nifer sylweddol o siaradwyr yr iaith, er gwaethaf y dirywiad pryderus**
Mae dogfen y Llywodraeth Miliwn o Siaradwyr” yn cydnabod allfudiad nifer sylweddol o siaradwyr Cymraeg o’u broydd a mewnlifiad pobl hŷn. Yna, mae’r ddogfen yn gwneud pwynt byddai’n fuddiol i’r Cyngor Sir ei ystyried a gweithredu arno, os yw o ddifrif eisiau cynnal a hybu’r Gymraeg:

Mae hyn yn galw am gryfhau’r berthynas rhwng cynllunio ieithyddol a chynllunio defnydd tir”
Nid oes afflwydd o dystiolaeth yn y Strategaeth a Ffefrir bod y sir yn ymwybodol o’i chyfrifoldeb yn y broses o gynllunio ieithyddol.
** Nid yw’r Cynllun Datblygu Lleol yn ei ffurf bresennol wedi deall oblygiadau gofyniad llywodraeth Cymru**
Mae’n siwr fod yr Adran Blaengynllunio ac felly’r Cyngor Sir yn deall bod trefn hierarchaidd i’r gyfundrefn gynllunio yng Nghymru. Islaw Trefn Gynllunio Cymru daw Cymru’r Dyfodol. Mae’n bolisi allweddol bwysig yn y gyfundrefn gynllunio:
Cymru’r Dyfodol yw’r haen uchaf o gynllun datblygu ac mae’n canolbwyntio ar faterion a heriau ar lefel genedlaethol” a
“Mae’n ofynnol i CDSau a CDLlau gydymffurfio â Cymru’r Dyfodol a rhaid iddynt gael ei diweddaru’n rheolaidd er mwyn sicrhau eu bod nhw’n cydweithio’n effeithiol” [tudalen 6]

Felly, pa mor agos yw’r berthynas rhwng y Strategaeth a Ffefrir gan yr Adran Blaengynllunio a chanllawiau Cymru’r Dyfodol, yn benodol o ran cyfanswm y tai sydd eu hangen? Addaswyd rhanbarth y de Orllewin ar gyfer fersiwn derfynol Cymru’r Dyfodol. Bellach , mae’r rhanbarth yn cynnwys siroedd Penfro, Caerfyrddin, Abertawe, Castell Nedd Port Talbot a Pharc Cenedlaethol Arfordir Penfro.
Amcan gyfrif canolog fersiwn derfynol Cymru’r Dyfodol yw bydd angen 25,600 o dai ychwanegol rhwng 2018/19 a 2038/9. Mae hyn yn ymestyn pum mlynedd tu hwnt i ddiwedd cyfnod Cynllun Datblygu Lleol y sir.
Gan fod cyfnod o 20 mlynedd ar gyfer yr amcan gyfrif canolog rhanbarth de- Orllewin Cymru’r Dyfodol, gallwn rannu’r 25,600 gyda 20 a chael 1,280. Dyma nifer y tai ychwanegol sydd eu hangen yn flynyddol, ar draws y 5 awdurdod i gyrraedd y targed. O rannu’r 1,280 ar draws y 5 awdurdod, , cawn mai dim ond 256 o dai ychwanegol sydd angen i bob awdurdod adeiladu’n flynyddol i gyrraedd at 25,600. Yn olaf, er mwyn gweld faint o dai sydd angen i Sir Gâr adeiladu dros 15 mlynedd y CDLl mae angen lluosi 256 â 15 = 3,940 tŷ ychwanegol.
Hyd yn oed o rannu’r 25,600 rhwng y pump awdurdod cawn y cyfanswm o 5,120 i bob sir ond mae hynny dros gyfnod o ugain ac nid pymtheg mlynedd.
Byddai rhai yn dadlau bod Parc Cenedlaethol Arfordir Sir Benfro mor fach, fel y gellid ei anwybyddu bron wrth geisio darogan cyfansymiau tai yn y siroedd. O wneud hynny a rhannu 25,600 rhwng 4 awdurdod cawn gyfanswm o 6,400, ond eto dros ugain ac nid pymthrg mlynedd y CDLl
Pa bynnag ddansoddiad a ffefrir, mae’n sylweddol llai na’r 8,822 yn y Strategaeth a Ffefrir gan y Cyngor Sir. Mae’r rhain yn dargedau llawer mwy rhesymol o gofio bod tua 2,000 o dai gwag yn y sir yn 2022 heb sôn am adeiladau gwag eraill a’r tai ar werth.

** Dyma enghraifft arall o’ Adran Blaengynllunio/Cyngor Sir yn talu sylw annigonol i ganllawiau clir Llywodraeth Cymru yn nogfen Cynllunio allweddol “Cymru’r Dyfodol”.

Annelwig yw canllawiau’r ddogfen ar sut i sicrhau sefyllfa “sy’n creu’r amodau i’r Gymraeg ffynnu a pharhau i fod yn iaith gymunedol yn y lleoedd niferus lle siaredir Cymraeg bob dydd”.
Mae cyfeiriadau at “y gydberthynas rhwng tai strategol, trafniadaeth a thwf economaidd a’r Gymraeg” cyn gofyn i’r CDLlau gynnwys “hierarchaethau aneddiadau pholisiau dosbarthu twf” ar gyfer creu’r amodau priodol i sicrhau ffyniant y Gymraeg. Penagored ac annelwig yw’r cysyniadau hyn, ond o gadw at y targed canolog dylai fod modd datblygu strategaethau cymathu priodol dros 15 mlynedd cyfnod y CDLL.
Serch hynny mae heriau penodol yn wynebu Mentrau Iaith y sir. “Mae strategaeth ofodol Cymru’r Dyfodol yn nodi dylai ffocws twf yn rhanbarth y De-orllewin fod yn ardal Bae Abertawe a Llanelli”.
O fewn y sir, mae’r ardal yn cynnwys tref Seisnigedig Llanelli, lle mae’r canrannau isaf o siardawyr Cymraeg yn ôl Cyfrifiadau 2011 a 2021, ond drws nesaf yr ardaloedd â’r canrannau uchaf, sef Cwm Gwendraeth a Dyffryn Aman. Bydd “datblygu” sef adeiladu sylweddol pellach yn y dref, ac yn arbennig yng nghymoedd Aman a’r Gwendraeth, yn rhoi pwysau enfawr ar y Gymraeg. Bydd her ychwanegol hefyd yn ardal Caerfyrddin sydd wedi ei ddynodi fel” ardal twf rhanbarthol”. Mae’n bosibl bydd “datblygwyr” a’r Adran Blaengynllunio yn dadlau bod angen tipyn mwy na’r 3,900 neu 5,120 neu hyd yn oed 6,400 o dai os oes datblygu/adeiladu, yn ardal Llanelli a Chaerfyrddin. Ar y llaw arall, mae nifer sylweddol o dai gwag yn y sir ac hefyd nifer o bobl eisoes yn chwilio am waith. Nid yw cyfanswm y tai gwag yn cynnwys y Tai ar Werth. Dyma gronfa ychwanegol o aneddiadau i ddiwallu anghenion gweithwyr yn y sir. Felly, nid oes modd gweld angen am lawer mwy na 5,000 o dai fan pellaf o ystyried y rhagolygon economaidd ansicr. Mae hyn yn arbennig o wir o gofio nad yw’r Cyngor Sir yn gwybod faint o dai sydd Ar Werth yny sir. Mae’r tai yma ar gael ar gyfer unrhyw ddatblygiad cyflogaeth.

Mae’r pwyslais ar dai fforddiadwy a chymdeithasol yn ateb anghenion y sir a chawsom atebion derbyniol gan yr Adran Tai ynglŷn ag ail osod tai gwag yn aneddiadau.Adeiladu tai cymdeithasol a fforddiadwy, gyda fforddiadwy yn ategu cyflogau lleol sydd ei angen, gyda’r lleiafswm angenrheidiol o dai ar y farchnad agored all sicrhau elw i gwmniau lleol. Nid dyma fwriad y Strategaeth a Ffefrir.Yn wahanol i ganllawiau Llywodraeth Lafur Cymru, mae’n agor y drws i fewnfudo pellach a gwneud gwaith heriol asiantaethau’r Fforwm a mudiadau Cymraeg eraill hyd yn oed yn anos.
Mae Ms Meinir Jones, ar ran Comisiynydd Iaith Cymru, yn gwneud yr union bwynt wrth ymateb i’r CDLl blaenorol. Mae’n anodd credu y byddai yn newid ei barn o gofio mai gostyngiad o 13 welwyd yn y cyfanswm tai bwriedir eu hadeiladu nawr yn y CDLl newydd “Mae’r targed newydd o ran tai, sef 8,835, yn llawer uwch na’r angen am dai newydd yn seiliedig ar amcanestyniadau Llywodraeth Cymru” [tud.184 cofnodion y Cyngor Sir, Ionawr 2021]]

Ymateb Llywodraeth Cymru i’r Cynllun Datblygu Lleol:
Ar ran Llywodraeth Cymru mae Mark Newey yn codi cwestiynau perthnasol am y CDLl cyntaf.. Mae’n tynnu sylw at y twf naturiol negyddol ym mhoblogaeth y sir, cyn nodi:
“The authority must fully evidence and explain how the scale of growth relates to the latest projections taking account of housing need and impacts on the Welsh language. The evidence needs to demonstrate where the in-migration will be derived from i.e. neighbouring counties, elsewhere in Wales, the UK or international migration” [tud 182 cofnodion y Cyngor Sir]

Dyma’r math o wybodaeth mae’r Mentrau Iaith wedi ceisio ei ganfod gan yr Arwerthwyr Tai lleol.
Mae tystiolaeth Dylan Phillips ar Gyfrifiad 2011 yn awgrymu’n gryf mai o Loegr daeth nifer i gefn gwlad y sir. Mae fersiwn drafft y CDLl yn cydnabod mai mewnfudo sydd yn gyfrifol am y twf yn y boblogaeth [tud 2] ac mae Cyfarwyddiaeth Cynllunio Llywodraeth Cymru yn dod i’r un casgliad [ tud 2]. Ond pa un ai o Loegr neu ardal Seisnigedig o Gymru daw y mewnfudo mae’n rhwym o arwain at wanhau’r Gymraeg yn y sir.
Mae Mark Newey hefyd yn feirniadol o ddosbarthiad gofodol/spatial distribution y CDLl gan godi amheuaeth am ei effaith ar y Gymraeg.
Mae hyd yn oed yn codi amheuon am effaith y CDLl ar ardaloedd gwledig y sir, er fod y rhan hwnnw o’r cynllun yn dangos ymwybyddiaeth o ddatblygu gofalus a phwysigrwydd y Gymraeg a’n diwylliant cynhenid.
“The Council’s Rural Needs Study” 2019 states that in rural settlements there is a predominant need for affordable homes. ..it is likely that the majority of housing delivered in these settlements will be for market housing. The study also highlights that half of the properties sold in these areas are likely to be for people outside the County Borough. The policy appears at odds with the evidence base.It is unclear how this approach aligns with findings in the SA/SEA, which identifies that growth and inward migration has the potential to dilute the Welsh language”[ tud. 814 cofnodion y Cyngor Sir]

**Fel mae’n sefyll ar hyn o bryd, mae Llywodraeth Cymru yn dangos fwy o ymwybyddiaeth o effaith y CDLl ar y Gymraeg na’r Cyngor Sir. Mae llawer gwell dealltwriaeth ein bod yn sôn am gyfnewid poblogaeth Gymraeg am un Saesneg o ran iaith. Mae targed tai Cymru’r Dyfodol hefyd yn cynnig llawer gwell cyfleon i’r Gymraeg nag amcanestyniad ffuantus yr Adran Blaengynllunio.**

Y Cyngor Sir:
Ateb y Cyngor Sir i’r sylwadau beirniadol oedd y byddai rhagor o ymchwil cyn dod i benderfyniad terfynol. Nid yw’n ymddangos bod fawr ddim wedi newid o ran Strategaeth Twf a’r cyfanswm tai.
Ond cynhaliodd y Cyngor Sir Asesiad Iaith o effaith y CDLl ar y Gymraeg. Prin yw’r awdurdodau sydd wedi ymgymryd â’r fath ymchwil ac mae sir Gaerfyrddin i’w ganmol am wneud. Fel nodwyd eisoes gwendid sylfaenol yr Asesiad oedd ei fod yn asesu effaith y Strategaeth a Ffefrir, oedd yn argymhell adeiladu 8,835 o dai. Ni ystyriwyd yr opsiynau mwy realistig o’r cyfanswm tai sydd eu hangen. Serch hynny, mae’r Asesiad yn dod i gasgliad tebyg i Dylan Phillips a Llywodraeth Cymru:
Mae’r holl senarios yn rhagdybio mai mewnfudo net fydd prif sbardun newid yn y boblogaeth. Er na ddywedir hynny’n benodol, rhagdybir y bydd newid naturiol yn parhau i fod yn negyddol gan leihau’r gronfa neu stoc o siaradwyr Cymraeg presennol dros amser” [atodiad 2.5 pwynt 17, tud 108]
Mae’r sylwadau ar pa mor ddibynadwy yw amcanestyniadau’r Cyngor Sir yn ddamniol. Dyma ddyfyniad o “Methodoleg Asesu’r Effaith ar y Gymraeg” - par 55 “Yn nhermau gwireddu amcanestyniadau poblogaeth, amcanestyniadau aelwydydd a thwf economaidd, nid yw cysondeb gwireddu amcan estyniadau yn arbennig o da” Yn union.

Y gobaith yw bod penderfyniad y Cyngor Sir a basiwyd ym mis Gorffennaf 2019 yn mynd i’w weithredu’n gyson. Dynodwyd y sir gyfan yn un o “sensitifrwydd ieithyddol” ac ymhellach fod yr iaith “yn ystyriaeth Gynllunio Berthnasol”
- Ym mhob cais i adeiladu 5 tŷ neu fwy yn yr ardaloedd gwledig a
- Ym mhob cais i adeiladu 10 tŷ neu fwy yn yr ardaloedd trefol.
Gall hwn fod yn arf cryf i rwystro adeiladu di-angen yn y sir ac mae’n glod fod y sir gyfan wedi ei ddiffinio fel un o sensitifrwydd ieithyddol. Wrth gwrs, mae’n dibynnu pwy sydd yn ymgymryd â’r Asesiad Effaith ar y Gymraeg. Yn y gorffennol, gadawyd i’r “datblygwyr” fwrw ati! Gan fod y Cyngor yn gweld y sir gyfan fel un o sensitifrwydd ieithyddol, mae’n anodd deall pam fod yr un Cyngor yn gweld yr angen i adeiladu 8,822 o dai dros gyfnod y CDLl, sydd yn ôl nifer o asiantaethau yn debygol o wanhau’r Gymraeg.

Yn y gorffennol ‘roedd cadeirydd y Pwyllgor Cynllunio yn agosach ati:

“mae’n debyg taw tua 6,000 o dai fydd y targed am y cyfnod 2021- 2033” oedd geiriau’r Cadeirydd mewn erthyglau yn y papur lleol yn 2018. Rhaid gobeithio y daw ef a’r Cyngor Sir i sylweddoli fod hwn, er yn darged gormodol, yn agosach ati ac y cawn newid sylweddol yn y cyfanswm tai o 8,822 dros gyfnod y CDLl, sydd yn debygol o fod yn ergyd drom bellach i’r Gymraeg yn y sir dros y ddegawd nesaf.

Fel y mae, nid yw Dyfodol i’r Iaith yn medru cefnogi’r Cynllun Datblygu Lleol.
Nid yw’n briodol i Sir Gaerfyrddin yng ngoleuni’r dystiolaeth yn yr Asesiad Iaith na pholisiau Llywodraeth Cymru. Mae’n talu sylw annigonol i bolisiau cenedlaethol megis Deddf Llesiant Cenedlaethau’r Dyfodol a Miliwn o Siaradwyr, heb sôn am Cymru’r Dyfodol sydd yn ganllaw statudol o bwys yn y gyfundrefn Cynllunio. ‘Rydym o’r farn bod y Cynllun Datblygu Lleol yn ansad a bod angen lleihau’n sylweddol y cyfanswm tai bwriedir eu hadeiladu.

The response of Dyfodol i’r Iaith members in Carmarthenshire to the second deposit version of the 2018 – 2033 Carmarthenshire Revised Local Plan

Language, as we know, is a strange thing. Who in their right mind opposes development?
But if we were to ask a number of people who have been involved with the planning system recently, it is likely that we would encounter a number of people who have lost their sanity.

The Carillion Company failed in 2018 due to the protection of bonus payments for the Directors, inappropriate accounting methods and paying entirely inadequate attention to the pension scheme. A significant number of buildings, including hospitals, were left unfinished. The cost of completing the building of the Royal Liverpool Hospital fell on the shoulders of the taxpayers.

Numerous houses were built on wetlands and on top of coal shafts by "developers" in Wales and beyond.

The Persimmon Company has built a significant number of houses in the county. The former Chief Executive of the company, Jeff Fairburn, was paid £7,000,000 in bonus over the years. This is the total amount the same company is prepared to pay to rectify the dangers on nine sites where they built unsafe housing.

Cladding is not the only dangerous element in homes in the UK. It is estimated that around 700,000 people still live in unsafe flats and up to another 3 million in homes that cannot be mortgaged because they are unsafe. The "developers" and Government rules are responsible for this unacceptable situation.

The Westminster Government presented a package of money to help around 200,000 flats in the highest towers. They did this under public pressure. The "developers" were very reluctant to accept responsibility and offer compensation to the tenants. The construction industry was given a decade to pay the £2billion cladding tax. Only recently, due to threats from the Minister in Westminster to remove them from the list of approved companies, have the companies made the effort in earnest to solve the problems that were created by them. But since the Grenfell disaster, when 72 people were burned to death, in June 2017, the five largest construction companies made £10 billion in profit. Somewhere in the Kensington and Chelsea council offices there is an application to "develop" Grenfell Towers.

It is high time we were more suspicious of "developers" and their empty claims and trusted local companies to meet local requirements.


Is there a need for so many houses?
No.

Research by Ian Mulheirn shows that the housing supply as a whole is sufficient. Mulheirn is a former economist at the Treasury, and Director of Consultancy with Oxford Economics. He is now Executive Director and Chief Economist with "Renewing the Centre", an Organization created by the former Prime Minister, Tony Blair.

In 2019 he published “Tackling the UK Housing Crisis – is supply the answer?” It focuses on England but it refers to Wales. To avoid incorrect translation, here is the crux of his argument:

“It is commonly claimed that we have failed to build enough houses to meet the demand for places to live. But official data suggests this is not the case since the 1996 nadir of house prices, the English housing stock has grown by 168,000 units per year on average, while the growth in the number of households has averaged 147,000 per year. As a result, while there were 660,000 more dwellings than households in England in 1996, the surplus has since grown to over 1.1million in 2018.
Similar trends are apparent in Scotland where a surplus of 74,000 in 1996 had more than doubled to 169,000 by 2017.
And in Wales the surplus increased from 56,000 to 92,000.”

The “Dwelling Stock Estimates, Welsh Government” document November 2019 supports Mulheirn’s analysis:
“The figures seem to suggest that in 2019 there may have been a sufficient number of dwellings for the overall number of households in Wales” [page 4]

The Forward Planning Department claims that it scrutinises carefully the Government’s projections relating to population. It does not appear that sufficient attention was paid to this particular analysis.

Mulheirn attributes this completely misleading situation to erroneous projections from the Office of National Statistics and the Government, which are the agencies on which the Forward Planning departments base figures. For decades, the growth in household numbers has been overestimated. The result of this was an overestimation of the total number of houses needed. Although the Office for National Statistics has recently recognized the weakness and adjusted the figures, Mulheirn is of the opinion that the estimate remains around 15,000 in excess per year.

He does not deny that there are specific problems such as homelessness, the need for social housing and affordable housing but in general there is no need to build thousands of houses in the UK and certainly not in this county. In the meeting at the end of 2020, the Council's Housing Department answered the questions about providing housing that meets the county's specific requirements.

Is it time to consider combining the Housing Department and the Forward Planning Department, on the understanding that it is the needs of the people of the county and not those of "developers" which should now claim priority?


The Situation in Carmarthenshire:
If the population of the county were to increase due to the natural growth of the native population and there were numerous jobs to support the people of the county, more houses would be needed, and with time and effort it would be possible to turn the linguistic ebb into a tide, and see an increase in the number of Welsh speakers. But that is not how it is.

Since 2001 the county's death rate has been higher than the birth rate. The same point is made in the Language Assessment, at the end of 2019, a document that the Forward Planning Department claims to have paid attention to its content. Here is an extract from the Language Assessment:
“The 2017/18 period recorded the highest number of deaths was registered since 2001” [Appendix 2.4, point 9].
If the death rate is consistently higher than the birth rate, and bearing in mind the significant emigration, the county's population would be expected to fall. That is not what happened. The first draft document of the LDP explains:
"The main factor influencing population change in Carmarthenshire since 2001/2 has been through inward migration, where more people have come into the County than have left"

The Language Assessment report confirms the pattern:
“Net internal migration continues to be the dominant driver of population change, with a sharp increase in the level of net inflow, reaching approximately +1600 in 2017/18 and showing a significant increase of over 700 compared to the previous year”

The County Council's latest LDP draft document underlines the continuation of the pattern
“Since 2011, the County has seen its population grow by 4,100 people, a 2.2% increase in 10 years. The main factor influencing population change in Carmarthenshire since 2001/2002 has been through inward migration....Carmarthenshire has an ageing population, with the number of deaths exceeding births each year since 2001/2.

There is an increase of people moving into the County within the 30-44 young family age group and the 0-14 year age group. There is also an increase in the over 65 age group which has contributed to Carmarthenshire’s ageing population profile”

Further evidence of an ageing population are the figures of children attending the county's primary schools which have fallen over the years:
2016 = 2120; 2017 =2065; 2018= 1995; 2019 + 1950; 2020+ 1965 a 2021 +1915

**This evidence, commissioned by the County Council, shows the danger to the Welsh language from over construction. The draft Development Plan is not credible, in the face of the evidence of the Language Assessment or the evidence of the County Council.**

The Census took place in February 2021 at the time of the pandemic. Although we do not have official figures it is clear that an additional number of immigrants have come to the county, like other counties in the west, looking for homes in a less populated area and dwellings with a garden or land.

Besides the Language Assessment, the Forward Planning Department claims to pay attention to the views and guidelines of the Welsh Government. When looking at the Preferred Strategy of the Forward Planning Department [alternative strategies were considered and rejected ... see below] the Planning Directorate of the Welsh Government made comments for consideration.
“The consequence of the level/distribution of housing growth proposed on the Welsh language needs to be clearly articulated especially as past high levels of in migration and international migration are being used to justify the housing requirement." [Impact on the Welsh language Assessment Methodology - paragraphs 23/4]

That is the truth. Building houses mainly for immigrants is what has happened in the county, and that when there was an adequate general supply of housing in Carmarthenshire. The latest figures from the County Council indicate that there are just under 2,000 empty houses in Carmarthenshire. The Housing Department is making progress in letting a number of the empty houses to county residents. But considering the houses for sale as well, which are available for any economic growth, however likely or unlikely that may be, there is a significant housing stock in the county for people who work here.

One would expect a County Council Forward Planning Department to consider carefully and to support to some extent, comments from the Planning Directorate of the Central Government. The intention to build 8,822 houses between 2018-2033 does not do that. The result of building this unreasonably high number will be to continue to promote the immigration of non-Welsh speaking people. Time is needed to implement the county's progressive policies in terms of making schools, workforces, apprenticeships and a number of other areas more Welsh.

The work of the Mentrau is challenging enough as it is, without continuing to promote the population exchange which is so harmful to our native language. The worry about the Forward Planning Department's lack of understanding of the County Council's linguistic priorities intensifies when looking at clause 11.173 of the Strategic Policy SP8 which claims:
“Through aiming for sustainable growth, the Plan will also maximise opportunities for non-Welsh speakers who move to the County to be integrated into community life at a scale and pace that will not undermine the vitality and viability of the Welsh language and culture” There is no explanation how this is meant to happen.

The results of the 2021 Census show that 26.4% of the county's population were born "outside Wales". This is an increase of 2.4% since 2011 and more than half the decrease of 4.1% in the percentage of Welsh speakers in the county since 2011. The integration policy does not appear to be very successful. There is no evidence concerning how many of the 26.4% of the county's population born "outside Wales" are fluent in Welsh.

The Forward Planning Department's approach to answering such questions is to transfer responsibility to other County Council departments, such as the Education Department. Reference was made above to the high level of immigration to the county in 2017/18. That cohort was analysed by the company that produced the Language Assessment. 30% of the people who came to the county in 2017/18 were aged 45 or over. [Appendix 2.4, pages 96 and 99/100]. Does the Forward Planning Department expect this cohort to attend a Welsh language school?
**A lack of solid evidence to justify policies is a feature of the LDP as it stands**

The immigration is not surprising from an economic point of view or the standard of living. The county is a pleasant place to live especially if your economic situation is comfortable. With the interest rate so low, selling a house and buying a similar one at a lower price is an effective way to accumulate a significant amount of money. By February 2021, according to Zoopla, the average value of a house in England was £320,757 while in Wales the average value was £199,113. The gap has closed somewhat since 2021 but a significant gap remains between the average house prices in the two countries.

When comparing house prices, again using Zoopla, we saw this comparison between Carmarthenshire and areas of England.
Birmingham Coventry Guildford Brighton Carmarthen Carmarthenshire

Semi-det £268k £273k £552k £578K £188k £178k
Detached £463k £427K £1,047k £786k £321k £334K

The Research was conducted in March 2023.

There are houses for sale in the county for £400,000, £500,000 and more. It is not likely that local people will be able to purchase these.
The county's Mentrau Iaith endeavoured to find out from house auctioneers, who has been buying houses in the area during the period of the pandemic. It is probable that some have moved from east Wales and some have returned to the county. But the house price comparison offers sufficient evidence of the financial benefits of moving from England to Carmarthenshire. For the County Council, this is advantageous and it is likely that there are advantages for landowners, some businesses and more Council Tax as well.

But what immigration does is place significant additional pressure on our unique heritage. While acknowledging that some will certainly benefit from the construction of 8,822 houses between 2018 and 2033, as a pressure group, Dyfodol i’r Iaith believes that it is gradual and careful growth that is needed, while the policy to make the county more Welsh bears fruit.


Strategic Growth and Spatial Options
Things to Consider and the Best Choice?
The title explains the department's priorities - the use of space or "land use", which is the basis of the planning system. Not the effect of land use on people but rather the use of land space for construction, arguing that this leads to economic improvements. It is claimed that the Department of Forward Planning is "considering employment-led options." This is commendable if it is realized and the department does not fall into the trap of thinking that construction on its own leads to economic prosperity.

The Forward Planning Department also considers the "vacancy rate". Reference has already been made to this. There are just under 2,000 empty houses in the county. Therefore, should there be an improvement in employment in the county and if that were to reduce emigration by the county's young people, there are empty houses here already for those workers. There are also a significant number of empty buildings in the towns and the countryside that can be converted into purpose-built homes.

A further argument from the Forward Planning Department is that it is necessary to "link population growth and estimated employment growth". The intention is supported by adding “The options identified assume that housing development without employment opportunities in the same broad location, and vice versa, is less sustainable and is to be avoided”. The argument is correct, housing is needed for employees. Therefore the economic and employment prospects need to be considered carefully [see below].

The employment prospects were quite fragile when the Forward Planning Department considered the choices for the 2018 – 2033 Local Development Plan. Consideration was given to 6 options. The one with the smallest projection in terms of population growth and population change was the Welsh Government Projection based on 2018. According to this analysis, 4,359 houses would be needed over the period of the LDP to meet the requirement of 6,197 in population growth. This option and others were rejected, even the one which estimated that 5,670 houses were needed to meet the projected growth demand of 9,460 people over the period of the LDP. This was the Welsh Government's “High Population” variable based on 2018.
**The County Council's LDP does not pay sufficient attention to the Welsh Government's projections**

All the options claim to be able to link the construction with "job creation". Evidently there will be jobs in the construction field and this will offer economic benefit in some other areas. But it has already been explained that there are a number of people in the county looking for work and they live in the county. Also, what evidence does the Forward Planning Department have that the jobs created by large "developers" such as Persimmon will be local jobs? It is quite likely that a number of the workers would come from outside the county, in order to meet the demand of the "developers" for workers.

There is no purpose in building houses unless there is appropriate work for the people who will live in them, as the department's citations acknowledge. Otherwise, the people who come into the houses will be retired people from outside the county, placing additional pressure on local public services.

On what basis were these options rejected?
This is the Forward Planning Department's explanation for rejecting the other options:
“Given the potential negative impacts highlighted above, it is not considered prudent to utilise the principal WG 2018-based projection for the Revised LDP. It would not have delivered the Plan’s Vision and Strategic Objectives.”

As the County Council is not willing to accept the Welsh Government's analyses, it is necessary to consider who is being most realistic [below].

We find again in the department's comments the completely unclear connection between building and keeping young people in the county. Cymdeithas yr Iaith's response to the vague allegations is absolutely right:
“Hope and ambition are not the same as evidence”. Exactly.

More than once, the Forward Planning Department notes that attention has been paid to the Impact Assessment on the Welsh language carried out by the County Council in 2019. This was to be welcomed. The councils that give such consideration to the impact of planning on our national language are few. But it is necessary to consider and remember that the Assessment was discussing the previous Preferred Strategy, which was to build 8,835 houses. The new Preferred Option is just as likely to cause great harm to the Welsh language and make the work of the agencies on the Language Forum, and other organizations even more challenging. The options that offered gradual growth, that would offer an opportunity for all the work to restore the Welsh language to bear fruit over the period of the Development Plan, were ignored.


The Economic Outlook:
Above, we saw a suggestion that the Forward Planning Department couples the building of houses with the county's employment needs. So, what are the economic prospects now?

The latest LDP places strong emphasis on the Swansea Bay City Deal to create jobs and prosperity. The two most important projects within the county are Egin where the S4C centre is located and Pentre'r Awel near Llanelli. In the last LDP, an attempt was made to persuade us that Canolfan yr Egin would protect and, possibly, promote the Welsh language in the area. There are around 50 jobs there directly linked to S4C. Nearby it was planned to build 1,200 houses. For whom were these intended?

Another pillar in the county's planned economic growth is Pentre Awel on the outskirts of Llanelli. The target over the next 15 years is to "create up to 2,000 jobs" and give "a £467 million boost to the economy". In that very area, more than 200 jobs were lost at the Schaeffler factory and another 90 from the Calsonic factory relatively recently. During the Covid period the AIM Altitude factory in Dafen closed with the loss of an additional 100 good jobs. This is approximately 400 local workers who would be available, with the appropriate training, to work in Pentre Awel, and who already live in houses in the area. Llanelli is in the south east of the county and convenient for Swansea. Neath Port Talbot, just to the east, can meet the needs of Pentre Awel, without building thousands more houses in the area.

The pandemic accelerated the tendency that already existed to shop online. Unfortunately, many more workers will lose their jobs because of this. Debenhams has closed in Carmarthen and other shops had already disappeared from the town centre. The same pattern will take place in towns such as Llanelli and Ammanford. Llanelli town centre is quite sad at the moment and it is comforting to know that discussions have taken place to change the character and regenerate the area. It is good to see a number of smaller shops opening, but they can hardly offer the number of jobs that existed in the big chain shops. In the countryside, we have seen the closure of many branches of the big banks and the loss of jobs as a result. Here are more workers who already live in houses in the county and are ready to work.

Planning the recovery of the county's town centres should be a priority for the Forward Planning Department. Already, a number of councils are preparing to adapt the nature of town centres, including leisure resources and turning empty shops into purpose-built dwellings for local residents. The priority is not to build thousands of houses, but to secure work that suits the county for people who, on the whole, already live here.

The document “Plans for Carmarthenshire’s economic recovery and growth” makes the point,
“It sets out the authority’s aims to help businesses replace more than 3,000 jobs that have already been lost during the pandemic and safeguarding and replacing up to 10,000 jobs that may have been, or are at high risk of being lost when furlough ends”. Protecting jobs and creating jobs to meet the demands of the county's current population is enough of a challenge. There is hardly a need for 8,800 additional houses that could attract people who would gain a head start on the local residents in terms of getting the lost jobs.

"The county's economic ambitions" is a laudable enough ideal but it seems as far from reality as a rhinoceros ballet-dancing! Gradual growth and improving the infrastructure is the realistic ambition and the department on rural development offers intelligent guidance in this direction. An example of what can realistically be done is the use of the £36.8 million from the UK Wealth Sharing Fund for community associations and businesses and the Tywi Valley Walking and Cycling Paths project.


Population and Housing Documents:
Forward Planning departments study documents that try to predict population and dwelling trends. These are not concrete forecasts of what will happen but projections based on trends. Many of them confirm what is increasingly obvious to us.

Summary statistics for the South West Wales region: 2020 [Welsh Government, May 20 2020]
"Looking at local authorities, Carmarthenshire saw the largest net change in population due to migration and other changes during the 2017-18 period. All 4 local authorities experienced negative natural change during this period, meaning the number of deaths was higher than the number of births. The highest level of negative natural change was in Carmarthenshire”.

In other words, more have died than been born in the county and that at a higher rate than the other three counties. But because of migration, "population change due to net migration and other changes was positive". "Positive" means progress for the statistician, but for those who love the Welsh language, it means an additional challenge of trying to assimilate even more non-Welsh speaking people.

Stats Cymru offers totals for 2016/7.
2016/7 - Inward inflow [within the UK] 6,702 Inward outflow 6,080
In 2018/19 - Inward Inflow [within the UK] 6,900 Inward outflow 5,900
[Local authority population projections for 2018/19]

What kind of people migrate? We know that a significant number of young people leave the county annually. Who is taking their place? Is it young people returning to the county or immigration of working age people as the Forward Planning Department predicts when building so many houses?

Local authority population Projections based on 2018, Wales [revised], that was published in August 2020, attempts to foresee what is likely to happen. It predicts a 2.4% increase in the county's population by 2028, which would bring the total population of Carmarthenshire to 192,100. This is 1.7% higher than the projection based on 2014 figures. What will drive the increase in population?
“Migration is projected to add to the population of all local authorities in Wales…in the period 2018 to 2028. However, for most local authorities, net positive migration will more than offset the negative natural change resulting in overall population increases”
[Remember the meaning of "positive" and "negative" for the statisticians]
The theory was realized in the 2021 census. The percentage born "outside Wales" increased from 24% to 26.4%.
Carmarthenshire - 2021 Births 1,540 Deaths 2,592 2020 Births 1,660 Deaths 2,404
2019 Births 1,744 Deaths 2,202 2017 Births 1,817 Deaths 2,230
2016 Births 1,878 Deaths 2,266 .... the same pattern since 2001/2

In 17 of the local authorities, including Carmarthenshire, a reduction will be seen in the number of people aged 16-64. These are the people that the Forward Planning Department claims will come to live in the houses that are to be built. Indeed, the graph on page 5 of the Language Assessment shows that the increase between 2018 and 2028 is likely to be in the age of 65+ to 75+. As well as creating challenges for social services, people in this age range are not likely to learn Welsh. Therefore what the analysis does is predict the pattern of immigration which will include a significant percentage of older adults, and emigration of a significant number of young people who have been educated in the county. It also predicts that the pattern of the death rate being higher than the birth rate will continue until 2028.

Official documents show a gradual but clear shift towards renting at the expense of ownership. The Dwelling Stock Estimates document, published in March 2019, states that 9,200 dwellings in the county are rented from the local Council and 3,200 from social landlords. It is certain that people in need must be housed and offered suitable dwellings. But there is some concern that many of the social homes in the county are being let to people from England and if this is happening it will surely further dilute the language.

Another trend that has already started and is likely to accelerate is homes suitable for one person. It is expected that the demand for this type of dwelling will increase by 27% by 2039. Forward Planning departments need to be aware of these trends and adjust the projections in the light of the developments and the evidence.

The Forward Planning Department, Welsh Government and the Welsh Language:
The Welsh Government aims to secure one million Welsh speakers by 2050 and there is a reference to the place of the Welsh language in a number of Government documents. The LDP refers to the Well-being of Future Generations Act which includes the objective to create
"A Wales of vibrant culture and thriving Welsh language"
** Building houses that will attract more non-Welsh speaking immigrants is not consistent with this objective**.

Unlike the previous draft LDP, there is just one reference this time to the Welsh Government's document "a Million Welsh Speakers by 2050". Then we have " To deliver on this aim, the Council will support, promote, and enhance the Welsh language as a viable community language by ensuring that there are sufficient and proportionate employment and housing opportunities to sustain both the rural and urban communities the county and by implementing an effective monitoring framework”

We can welcome the intention to offer worthy and adequate employment to the people of the county. In our view, 8,822 houses are not required to realize this intention. The monitoring regime requires clarification because Census 2021 figures show that this has not been effective, if it exists at all. The percentage of the county's Welsh speakers fell from 44.0% to 39.9%. Remarkably, the document refers to the 2011 census and not that of 2021!

** This is another example of paying insufficient attention to the Welsh Government's recognized policy and that in a county with a significant number of speakers of the language, despite the worrying decline **
The government's “a Million Welsh Speakers” document recognizes the emigration of a significant number of Welsh speakers from their areas and the influx of older people. The document then makes a point that it would be beneficial for the County Council to consider and act upon, if it is serious about wishing to maintain and promote the Welsh language:
This calls for the relationship between language planning and land use planning to be strengthened”

There is no evidence whatsoever in the preferred strategy that the county is aware of its responsibility in the process of language planning.
**The Local Development Plan in its current form has not understood the implications of the Welsh Government's requirement**
The Forward Planning Department and therefore the County Council probably understand that there is a hierarchical regime in the planning system in Wales. Below Wales' planning system comes Future Wales. It is a vitally important policy in the planning system:
“Future Wales is the top tier of a development plan and it focuses on issues and challenges at the national level” and
“Strategic and Local Development Plans are required to be in conformity with Future Wales and must be kept up to date to ensure they and Future Wales work together effectively” [Page 6]

So, how close is the relationship between the preferred strategy of the Forward Planning Department and the Future Wales Guidelines, specifically in terms of the total housing needed? The South West region was adapted for the final version of Future Wales. The region now includes the counties of Pembrokeshire, Carmarthen, Swansea, Neath Port Talbot and the Pembrokeshire Coast National Park.

The central estimate of the final version of Future Wales is that 25,600 additional houses will be needed between 2018/19 and 2038/9. This extends five years beyond the end of the county's Local Development Plan period.
As there is a period of 20 years for the central estimate of the South West Future Wales region, we can divide the 25,600 by 20 and get 1,280. This is the number of additional houses needed annually, across the 5 authorities to reach the target. By dividing the 1,280 among the 5 authorities, we find that each authority needs to build only 256 additional houses annually to reach 25,600. Finally, in order to see how many houses Carmarthenshire needs to build over the 15 years of the LDP it is necessary to multiply 256 by 15 = 3,940 additional houses.

Even if we divide the 25,600 between the five authorities we get a total of 5,120 for each county but that is over a period of twenty and not fifteen years.

Some would argue that the Pembrokeshire Coast National Park is so small, that it could almost be ignored when trying to predict housing totals in the counties. If we were to do that and divide 25,600 between 4 authorities we get a total of 6,400, but again over twenty and not the fifteen years of the LDP.

Whichever analysis is preferred, it is significantly less than the 8,822 in the Preferred Strategy by the County Council. These are much more reasonable targets bearing in mind that there are around 2,000 empty houses in the county in 2022 not to mention other empty buildings and the houses for sale.

** This is another example of the Forward Planning Department/County Council paying insufficient attention to the Welsh Government's clear guidelines in the key "Future Wales" planning document.

The document's guidelines are vague on how to ensure a situation "that create(s) the conditions for Welsh to thrive and remain as the community language in the many places where everyday life takes place in Welsh". There are references to "the correlation between strategic housing, transport and economic growth and the Welsh language" before asking the LDPs to include "settlement hierarchies and growth distribution policies" for creating the appropriate conditions to ensure the prosperity of the Welsh language. These concepts are open-ended and vague, but by adhering to the central target it should be possible to develop appropriate assimilation strategies over the 15-year period of the LDP.

Nevertheless there are specific challenges facing the county's Mentrau Iaith. "The Future Wales spatial strategy states that the focus of growth in the South West region should be in the Swansea Bay and Llanelli area".

Within the county, the area includes the Anglicised town of Llanelli, where the lowest percentages of Welsh speakers are according to the 2011 and 2021 Censuses, but next door the areas with the highest percentages, namely Cwm Gwendraeth and Dyffryn Aman. "Development" meaning further significant construction in the town, and particularly in the Amman and Gwendraeth valleys, will place enormous pressure on the Welsh language. There will also be an additional challenge in the Carmarthen area which has been designated as a "regional growth area". It is possible that "developers" and the Forward Planning Department will argue that we need quite a bit more than the 3,900 or 5,120 or even the 6,400 houses if there is development/construction, in the Llanelli and Carmarthen area. On the other hand, there are a significant number of empty houses in the county and also a number of people already looking for work. The total number of empty houses does not include the Houses for Sale. This is an additional pool of dwellings to meet the needs of workers in the county. Therefore, it is not possible to see a need for many more than 5,000 houses at the most, considering the uncertain economic outlook. This is especially true bearing in mind that the County Council does not know how many houses are for sale in the county. These houses are available for any employment development.

The emphasis on affordable and social housing meets the county's needs and we received acceptable answers from the Housing Department concerning re-letting empty houses as dwellings. Building social and affordable housing, with affordable corresponding to local wages, is what is required, with the necessary minimum of houses on the open market that can ensure profit for local companies. This is not the intention of the Preferred Strategy. Unlike the Welsh Labour Government's guidelines, it opens the door to further immigration and makes the challenging work of the Forum agencies and other Welsh organizations even more difficult.

Ms Meinir Jones, on behalf of the Welsh Language Commissioner, makes the exact point when responding to the previous LDP. It is difficult to believe that she would change her opinion, bearing in mind that a reduction of 13 was seen in the total number of houses now planned to be built in the new LDP, "The new housing target of 8,835 is significantly higher than the need for new housing based on Welsh Government projections" [page 184 County Council minutes, January 2021]]

Welsh Government Response to the Local Development Plan:
On behalf of the Welsh Government, Mark Newey raises relevant questions about the first LDP. He highlights the negative natural growth in the county’s population, before making the point:
“The authority must fully evidence and explain how the scale of growth relates to the latest projections, taking account of housing need and impacts on the Welsh language. The evidence needs to demonstrate where the in-migration will be derived from i.e. neighbouring counties, elsewhere in Wales, the UK or international migration” [page 182 County Council minutes]

This is the type of information that Mentrau Iaith have tried to find out from the local Estate Agents.
Dylan Phillips' evidence on the 2011 Census strongly suggests that many came from England to the county's countryside. The draft version of the LDP recognizes that immigration is responsible for the growth in the population [page 2] and the Welsh Government's Planning Directorate comes to the same conclusion [page 2]. But whether the immigration comes from England or an Anglicised part of Wales, it is bound to lead to a weakening of the Welsh language in the county.

Mark Newey is also critical of the spatial distribution of the LDP, raising doubts about its impact on the Welsh language. He even raises doubts about the effect of the LDP on the rural areas of the county, although that part of the plan shows an awareness of careful development and the importance of the Welsh language and our native culture.

“The Council’s Rural Needs Study” 2019 states that in rural settlements there is a predominant need for affordable homes. ..It is likely that the majority of housing delivered in these settlements will be for market housing. The study also highlights that half of the properties sold in these areas are likely to be to people outside the County Borough. The policy appears at odds with the evidence base. It is unclear how this approach aligns with findings in the SA/SEA, which identify that growth and inward migration has the potential to dilute the Welsh language” [page 814 County Council minutes]

**As things stand at the present time, the Welsh Government demonstrates a greater awareness of the effect of the LDP on the Welsh Language than the County Council does. It has a better understanding that we are talking about exchanging a Welsh population for one that is English speaking. The Future Wales housing target also offers far better opportunities to the Welsh language than the false projection of the Forward Planning Department.**

The County Council:
The County Council's answer to the critical comments was that more research would be carried out before reaching a final decision. Little seems to have changed in terms of the Growth Strategy and the total number of houses.

But the County Council carried out a Language Assessment of the impact of the LDP on the Welsh language. Few authorities have undertaken such research and Carmarthenshire is to be commended for doing so. As already stated the basic weakness of the Assessment was that it assessed the impact of the Preferred Strategy, which recommended the construction of 8,835 houses. The more realistic options of the total number of houses required were not considered. Nevertheless, the Assessment reaches a similar conclusion to Dylan Phillips and the Welsh Government:
“All scenarios assume that net internal migration will continue to be the main driver of population change. Although it is not made explicit, it is assumed that natural change will continue to be negative thus reducing the pool or stock of existing Welsh speakers over time” [appendix 2.5 point 17, page 108]

The comments are scathing on how reliable the County Council's projections are. This is a quote from "Methodology for Assessing the Impact on the Welsh Language" - para 55 "In terms of realising population and household projections and economic growth, the consistency of realising projections is not particularly good". Exactly.

It is to be hoped that the decision of the County Council passed in July 2019 will be implemented consistently. The whole county was designated as one of "linguistic sensitivity" and further that the language "is a Material Planning consideration"
- In all applications to build 5 or more houses in the rural areas and
- In all applications to build 10 or more houses in the urban areas.
This can be a strong tool to prevent unnecessary construction in the county and it is a credit that the whole county has been defined as one of linguistic sensitivity. Of course, it depends on who undertakes the Impact Assessment on the Welsh language. In the past, the “developers” were left to get on with it! As the Council sees the whole county as one of linguistic sensitivity, it is difficult to understand why the same Council sees the need to build 8,822 houses over the period of the LDP, which according to a number of agencies is likely to dilute the Welsh language.

In the past the chairman of the Planning Committee was closer to it:

“Approximately 6,000 houses probably will be the target for the period 2021- 2033" were the Chairman's words in articles in the local paper in 2018. One must hope that he and the County Council will come to realize that this, although it is an excessive target, is nearer the mark and we shall have a significant change in the total number of houses from 8,822 over the period of the LDP, which is likely to be a further heavy blow to the Welsh language in the county over the next decade.

As things stand, Dyfodol i’r Iaith is unable to support the Local Development Plan.

It is not appropriate for Carmarthenshire, in the light of the evidence in the Language Assessment or Welsh Government policies. It pays insufficient attention to national policies such as the Well-being of Future Generations Act and a Million Welsh Speakers, not to mention Future Wales which is an important statutory guideline in the Planning system. We are of the opinion that the Local Development Plan is unstable and that the total number of houses intended to be built needs to be significantly reduced.

Dyfodol i’r Iaith Carmarthenshire March 2023

Newid fel y nodir.
___
Change as set out.

RE : Response to WRITTEN STATEMENT IN THE CARMARTHENSHIRE SECOND REVISED LDP CONSULTATION 2016-2033
FOLLOWING ON FROM the response which I am 100% supportive of which was forwarded to the department yesterday & presented by Cllr. Carys Jones on behalf of the 38 strong Plaid Cymru members of Carmarthenshire County Council I myself as the present Chairman of Carmarthenshire County Council’s Planning Committee wish to place on record these particular comments below which I personally am most concerned about within that document.

1) Creu mwy o degwch rhwng ceisiadau anghenion lleol/tai fforddiadwy i gymharu a cheisiadau DUP/OPD e.e. yr angen i greu cynllun busnes ymlaen llaw gyda tai fforddiadwy a thai anghenion lleol yn erbyn creu cynllun busnes 5 mlynedd ar ol derbyn caniatad gyda’r OPD’s.

2) Gyda amcanion Llywodraeth Llafur Cymru i gael miliwn o siaradwyr cymraeg dros y chwartref canrif nesa, amcan sydd i’w groesawi’n fawr : sicrhau trwy ddodi amodau llym ar bob cais yng nghefn gwlad fel ei bod yn mynd at ddibenion pobol ifanc sydd am aros a chodi cartref yn ei cymuned yn hytrach na gweld mwy o fewnlifiad yn enwedig o deuluoedd sydd am ymadael a’r dinasoedd a dod mas i gefn gwlad wrth iddynt baratoi ymddeol a thrwy hynny amddifadu teuluoedd ifanc lleol rhag gallu cystadlu yn y farchnad eiddo agored.

3) Mae dyletswydd arnom fel Adran Gynllunio sicrhau fod gweledigaeth ein aelodau etholedig ar draws Cymru yn derbyn cefnogaeth wrthym er mwyn mynd ati o ddifrif i hybu datblygiad ein iaith dros y genedl gyfan. Dylid ystyried a chofio mae yn y llefydd mwyaf gwledig ag anghysbell mae’n iaith gryfaf ac mae dyletswydd arnom i anog ein ieuenctid i sefyll yn y gymuned lle ei magwyd a thrwy iddynt wneud hynny sicrhau fod bywyd pob dydd y cymunedau gwledig hynny yn ffynnu a bod ysgolion, neuaddau a chapeli cefn gwlad ymysg pethau arall yn gwynebu sicrwydd cadarnhaol i’r dyfodol.

4) Rhoi’r mwy o gyfle i fobol ifanc sydd am sefydlu busnesau bach yn y gymuned lle ei magwyd i ddatblygu busnes o fewn ei cymunedau

5) Gorfodi tirfeddianwyr ac asianteithiau i ofyn am hawl cynllunio i blannu degau o erwau o goed yn arbennig ar dir ffermydd mwyaf ffrwythlon Sir Gar. Derbynir fod yna dir o ansawdd gwael sydd yn addas i blannu coed arno ond dylid gwarchod ein tir mwyaf ffrwythlon er mwyn diogelu tir fydd yn gallu cynhyrchu bwydydd yn y dyfodol.

6) Dod ‘nol ac adfeilion tai byw sydd wedi mynd yn adfael ond gyda’g amodau llym fod y defnydd yn mynd at anghenion pobol lleol a DDIM i’w gwerthu ymlaen a chreu mwy o fewnlifiad

7) Rhoi’r cyfle i greu mwy o pods, shepperd huts, safleoedd carafanau a thebyg yng nghefn gwlad hynny o bosib fel prosiectau arall gyfeirio ?

8) Rhoi hawl i bentrefi sydd bellach heb llinell datblygu ffurfiol i dyfu dipyn mwy na 10%, efallai lan at rhywle tebyg i 25% - 30% o dwf.