HOM1: Dyraniadau Tai

Include site within the Plan

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

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2.0.0 SSITE ITE CCONTEXTONTEXT
2.1 THE SITE
2.1.1 The Alternative Site relates to part of a gently sloping semi-improved grazing enclosure which lies off Dolau Fan in Burry Port. The land extends to several acres of pasture which rise in ground profile in a northerly direction. The southern perimeter of the site is linear in form and forms the common boundary with the town’s public cemetery, which is also accessed via Dolau Fan.
2.1.2 The entire western boundary of the site lies parallel with the rear boundaries of bungalows and houses at Dolau Fan, which forms a series of cul-de-sacs set upon the mid-hillslopes overlooking the northern extent of the town. Properties tend to date from the late 1960s / 70s, and be a mix of semi-detached bungalows and houses, and are conspicuously set in modest plots with side driveways and pockets of front curtilages.
2.1.3 The eastern perimeter of the site falls against a post and rail fence with adjoining grazing pasture, which also falls in ground level down to the large open cemetery. The Alternative Site exhibits pockets of individual trees, and swathes of gorse, together with bramble and common scrub.
2.1.4 The Alternative Site relates to some 2.1 hectares (2.4 acres) of unmanaged pasture. The site extends across a common boundary length with Dolau Fan properties of some 250 metres, and a shared southern boundary with the cemetery of 190 metres. The site is open and exposed to that cemetery, but the western perimeter with Dolau fan is marked with high, domestic fencing and garden hedgerows.
2.1.5 This part of Burry Port is characterised by modern housing, set over several hectares of sloping land, with cul-de-sacs branching out to terminate at open pasture such as the Alternative Site. There is no formal turning head off the eastern extremity of the estate road which provides access to the site, where the road stops abruptly at a shallow embankment.
Dolau Fan extends north off a road junction with the A484 Colby Road, being the main arterial highway running east to west through Burry Port from Pwll and Pembrey. The road is wide, easily allowing continued passage for two-way traffic. Public footways are to be found off both flanks, with street lighting at consistent intervals.
2.1.6 The Site field parcel is identified by being edged in red on the plans below. Plan A illustrates their wider position with the settlement of Burry Port. Plan B provides a detailed Ordnance Survey map extract with the site perimeters identified.
Alternative Site Supporting Statement March 2023
Land off Dolau Fan, Burry Port Mr. G. Edwards
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Plan A – wider view of Dolau Fan setting in Burry Port
Plan B – detailed Ordnance Survey location plan of site
2.1.7 The Alternative Site development will form a mirrored extension to Dolau Fan properties, appearing as an extension of the cul-de-sac arrangement, set back to provide an abundance of habitable spatial relief to the rear elevations and gardens of those established properties, whilst also allowing for each new dwelling to be afforded off-road car parking and traditional rear garden space.
Plan C below provides a Google Earth image of the site and its surroundings, in which the above physical features are readily apparent.
Plan C – Google Earth – April 2021
2.1.8 The Candidate Site’s well-defined perimeters and immediate proximity to the adjacent established residential properties off the Dolau Fan highway, are shown within the photographs below. The photos also depict the existing boundary fences separating the subject field and Dolau Fan properties’ rear gardens with the Alternative Site.
Site
Photograph 1 – view of Alternative Site with existing dwelling set in backdrop at Dolau Fan at higher level
Photograph 2 – view from within site entrance looking at Dolau Fan properties across overgrown scrub
Photograph 3 – view of properties at Dolau Fan and two-way width of estate road with footways
Photograph 4 – view of site from lower ground at southern perimeter with cemetery
Photograph 5 – view at cemetery entrance of site gently ascending hillslope and adjoining Dolau Fan properties
2.2 SETTLEMENT SUSTAINABILITY AND SITE SETTING WITHIN CURRENT LOCAL DEVELOPMENT PLAN
2.2.1 Under the provisions of the current Carmarthenshire Local Development Plan, the site off Dolau Fan falls adjoining the Development Limits for the settlement of Burry Port. The Alternative site is edged in red on the map extract.
Plan D – Extract from Adopted LDP Proposals Map of Burry Port (2014)
2.2.2 As can be seen, the Candidate Site adjoins and is well related to the existing defined Development Limits for Burry Port, and also within walking distance of the town centre.
Within the Second Draft of the Deposit LDP for the Plan Period 2018-2033, the settlement limits of this part of Burry Port remain unchanged, as shown in Plan E below.
Plan E – Second Draft of Proposals Map (2023) at Dolau Fan
2.2.3 A notable change in the adopted and emerging LDP Plans is that land to the east at “Bay View, The Graig” allocated in the 2014 adopted plan as T2/1/h4 is no longer allocated in the new Replacement LDP. The site did not come forward for development in the last 8 years, and therefore it has been decided to remove the allocation BUT retain the land within defined settlement limits. It nevertheless demonstrates that the Council will consider development upon the mid-hillslopes, adjoining established residential properties set at an elevated higher level at Dolau Fan.
2.2.4 Housing Land Availability in Burry Port
It is clear that proposed residential land opportunities in Burry Port have been rationalised since the current LDP was adopted in 2014. The Second Deposit Draft itemises at Policy HOM1 that only three sites are allocated for residential development, and two of those are substantially if not totally complete.
The site at Goodig for 105 units is complete, apart from 8 units off its eastern perimeter, which are in process of being finalised. At Glanmor Terrace, a total of 32 affordable units have been largely completed adjacent to the main railway line.
In terms of the remaining allocation at Harbourside, the site is allocated for 364 units, yet despite being granted outline planning permission, which has since expired and been renewed, there remains no active housebuilder interested in acquiring the site, and it must be accordingly questioned as to the deliverability of tis brownfield site. Being
brownfield the site is susceptible to the need for wholesale remediation which will inevitably lead to increased build costs, undermining its progress.
2.2.5 Conversely, the Alternative Site’s position and proposed use therefore continues to represent a natural and logical location for the settlement’s expansion in the context of adjoining established and proposed residential development.
As detailed above, the Candidate Site adjoins and in effect lies within the existing settlement and form of Burry Port. The existing built form and pattern of the settlement follows key access routes, such as the A484 Gwscwm Road and Lando Road, to the north and Ashburnham Road. The established town centre at Station Road extends off Ashburnham Road, with multiple cul-de-sac modern developments concentrated to the mid-hillslopes to the north of the A484 road, or south to the main railway line extending west to east from Burry Port to Kidwelly.
Burry Port is particularly popular to new homeowners due to its coastal position, and short drive to Llanelli, and in particular the A484 link to Carmarthen.
2.2.6 In terms of the Alternative Site is located within easy walking and driving distance of all community facilities and local services present and provided within the settlement of Burry Port. Access to further facilities in the towns of Llanelli and Carmarthen can then be gained by regular bus services, stops for which are located near the Dolau Fan junction with Colby Road.
The sustainable position of Burry Port should therefore be given full consideration when considering potential future growth options.
2.3 Settlement Facilities
2.3.1 The Site at Dolau Fan lies some 10 minutes’ walk from the centre of the town at Station Road.
Public bus stops lie immediately near the Dolau Fan’s junction with the Colby Road carriageway.
Main public bus services call at these bus stops, in particular:
- Service 111 – Kidwelly to Swansea, calling at Pembrey, Burry Port, Llanelli, Trostre, Gorseinon, and Fforestfach
- Service X11 – Carmarthen to Swansea, calling at Ferryside, Burry Port, Llanelli, Trostre and Fforestfach retail parks
2.3.2 The site at Dolau Fan is within 10 minutes’ walk, to the London Paddington to Fishguard / Pembroke Dock rail service at Burry Port station.
2.3.3 The Site lies within a 5-minute walking distance of Burry Port Primary school at Elkington Park. Ysgol Y Strade and Burry Port Secondary Schools are located at Llanelli and Burry Port respectively, with pupil bus transport available to Ysgol-y-Strade. The CCTA campuses at Llanelli and Carmarthen are also available via student bus services.
2.3.4 Burry Port town centre provides a range of small comparison shops, supermarket, petrol filling station, public houses / cafes, offices, rail station and industrial estates.
Plan F below provides an indication of the proximity of the site to Burry Port town centre, with its rail station and strategic road network to Llanelli and Carmarthen.
The red star denotes the position of the Alternative Site.
Plan F – proximity of Alternative Site to Burry Port town centre
Primary School
Suoermarket and town centre
Rail Station
A484 Road to Llanelli and Carmarthen

3.0 TTHE HE PPROPOSALROPOSAL
3.0.1 As part of the requirements for the promotion of sites for residential development, this Statement is accompanied by an indicative layout for a potential residential scheme that could be developed on the site. It should be emphasised that the accompanying layout is for illustrative purposes and that other design solutions for the site could also be reached. Notwithstanding this, the accompanying layout drawing has taken account of all the potential assets and constraints of the site and demonstrates that it is capable of delivering 26 bungalows in a deliverable and sustainable manner. The following information therefore expands on this principle.
3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Candidate Site be allocated in the replacement LDP for the purposes of a total of 26 residential units. As detailed above, the accompanying illustrative layout (reproduced below at Plan G) demonstrates that the site is capable of accommodating this number in a deliverable and sustainable manner.
Site layout plan - Plan G
3.1.2 As illustrated above, the site is capable of accommodating detached and semi-detached, single-storey bungalows to replicate and being reflective of the existing form and density of residential properties adjoining at Dolau Fan.
3.1.3 With regards to access, it is proposed that the Alternative Site would be served by an extension of the Dolau Fan estate road in to the western perimeter of the site. thus, improving the existing access arrangements. This stretch of Dolau Fan experiences very low vehicle speeds, considerably below the 20mph speed limit given the cul-de-sac nature of the estate. Forward visibility splays in excess of 43m can be achieved within this built-up locality. Within the site, a carriageway of 5.5 metres width with 1.8 metres wide footway can be created.
3.1.4 The Alternative Site proposals are able to fully retain all existing boundary treatments, being the established mature hedgerows across the western and eastern sides of the field, which would be retained and managed wherever possible.
3.1.5 Although due to the proximity of existing facilities in Burry Port, the proposal does not include any formal areas of play or open space. It is recognised and supported that an element of the proposed units could be Affordable in nature, or contributions made to support affordable housing elsewhere in the Llanelli locality, which under the provisions of the current LDP would be in the region of 20% of the total number of dwellinghouses.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Development of the Candidate Site for residential units would be served by mains water, gas, public sewer and electricity connections, which either lie within the respective stretch of Dolau Fan carriageway.
3.2.2 The estate road highway itself is equipped with roadside gullies and drainage which aid to discharge run-off from the carriageway. The proposed access to the site could connect to the existing highways drainage.
3.2.3 The Candidate Site comprises of semi-improved grassland. There are no areas of significant marshy grassland or water-logging evident, and therefore at first inspection, it appears that the site benefits from good ground percolation of rainwater.
3.2.4 Soakaways would be the most sustainable means of disposing of surface water from individual properties. If required, attenuation measures can be deployed on site to control surface water run-off during extreme storm events, which could also allow for additional capacity, making allowances for climate change. The field enclosures are served by a series of drainage ditches along the fields boundaries, which eventually combine and inter-connect discharging surface water which eventually discharge to the Estuary. It is considered that as a result of on-site features, there would be a number of options available to a future development of the site in terms of surface water disposal.

4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 The Site has been assessed against data held on the “Data MAP Wales” website, which details statutory and non-statutory National and Local sites of ecological importance. Plan H below provides an extract of those records as applied to the Burry Port locality. The red star denotes the position of the Alternative Site.
4.1.2 The records reveal that the Site does not include or adjoin any national or local nature conservation designation. The site is some 0.5 kilometres distant from the Special Area of Conservation at Carmarthen Bay.
4.1.3 Any biodiversity assets that may be present at or adjoining the Alternative Site have been given full consideration with regards to exploring its potential for residential development. This has included the proposed retention and management of existing boundary tree and hedgerow features. It is envisaged that the entirety of mature trees off the south-western and eastern boundaries could be retained and managed further for uninterrupted biodiversity gain.
Plan H – Extract from Data Map Wales detailing any known ecological interests
4.1.4 In the wider context, the site does not adjoin or form part of any local or national nature conservation designation. There are a number of areas of established woodland, which are clearly evident on the Google Earth image presented as Plan C above. These will
not be affected by development within the Alternative Site, as the indicative site layout provides for sufficient buffer space to those existing root systems and crown spreads, and can be fully retained in situ, providing continued ecological retention and connectivity.
4.1.5 It is considered that any statutory and non-statutory designations are significantly distant from the site, which will ensure that its development would have no detrimental impact on them.
4.2 HISTORICAL ASSETS
4.2.1 The Alternative Site has been assessed for any proximity to known and designated Historic Assets, using the “Cof Cymru – National Historic Assets of Wales” from CADW’s website. An extract from Cof Cymru Assets map for this part of Burry Port is reproduced below as Plan I The red star denotes the position of the Alternative Site.
4.2.2 The Alternative Site does not include or form part of any Listed Buildings or proximity to a Conservation Area. There are no Conservation Areas located near the Alternative Site. The proposed development of the Site would be located off the northern side of the Y Gaer Scheduled Monument, separated by the public cemetery. It is considered that being uphill of the historic monument would render any development unlikely to encounter historic remains / interests.
Plan I – Extract from Cof Cymru Historic Assets website
4.3 ENVIRONMENTAL CONSTRAINTS
4.3.1 Potential for Risk from Flooding
The Alternative Site has been assessed against the Development Advice Maps, prepared by Natural Resources Wales, and “Flood Map for Flooding.” An extract from the FPfP map is reproduced below as Plan J, with the site denoted by a red star.
Plan J – Extract from NRW’s Flood Map for Planning
4.3.2 The above plan extract reveals that the field enclosure lies just outside any designated flood zone. An examination has also been made of the NRW records relating to potential surface water flooding. Plan J also indicates areas of land in the locality susceptible to such surface water flooding risk, which are denoted by purple tone.
4.3.3 Any development of the Candidate Site would involve engineering works to ensure that there sufficient on-site attenuation of surface water and that the existing boundary drainage ditches are improved and have sufficient capacity to receive surface water from existing and proposed developments.
4.3.4 Past & Present Potential for Ground Contamination and Coal Mining Activity
The Candidate Site comprises agricultural pasture. Due to its greenfield nature and domestic use, the rear field of the Alternative Site has no history of known past ground contamination related constraints. Whilst the locality has historically been the subject of coal mining, the records of The Coal Authority have been examined to ascertain any precise mine entries, addits or seams of shallow coal and mine workings. An extract
from The Coal Authority interactive mapping base is reproduced as Plan K, with the site identified by a red star.
Plan K – Extract from Coal Authority’s records map for locality
4.3.5 The Coal Authority records reveal that coal seams underlay Dolau Fan, with historic mine shafts dotted about this hillslope, The presence of coal seams did not deter the construction of several hundred houses at Dolau Fan some fifty years ago and is unlikely through modern building techniques to deter or prohibit construction upon the Alternative Site.

5.0 VIABILITY
5.0.1 As part of the preparation of any development plan, it is vital to ensure that allocations within it are both viable and deliverable. To not make efforts to explore both these aspects inherently poses risks that the Plan may be unsound and so in turn fails to meet its own targets or objectives.
5.0.2 Although detailed viability appraisals are difficult to prepare at this stage of the Plan’s preparation due to the absence of, for example, such things as full engineering details, it is possible to undertake such appraisals at a strategic or in-principle level. The following therefore represents such a process and is fit-for-purpose in providing confidence with regards to both the viability and deliverability of the Candidate Site at this stage. It should be noted that more detailed analysis at a planning application stage may result in some potential variance.
5.1 VIABILITY APPRAISAL
5.1.1 The following provides an indication of the viability of delivering the proposed 26 units on the Alternative Site in question. It is based very much on its greenfield status and uses values and costings previously accepted by the Local Authority through its determination of planning applications and other works. The following appraisal is therefore based on the assumptions set out below in order to provide a residual land value for the scheme.
Costs
• Dwelling construction costs are based on an absolute minimum of £1300 per metre given that bespoke 3/4 bed detached bungalows (130 sq.m.), with a medium grade of internal finishing, and formation of accesses to the highway are likely to be the preferred house type. Two bedroomed semi-detached bungalows of 80 sq.m. are also proposed
• Estate road carriageway costs of £1200 per linear metre
• Connections for all utilities include water, foul water and electric.
• Developer’s Profit based on minimum RICS guidelines (18%)
• Professional Fees include planning application fee, associated professional fees, estate agency fees (1%) and LABC Warranty fee.
Sales Values
• Sale Prices based on LPAs “Affordable Housing” Supplementary Planning Guidance, market research and Welsh Government “Acceptable Cost Guidance” figures where relevant.
5.1.2 Using the above, the following represents a strategic viability appraisal for the proposed 26 units, based on an affordable housing level of 20% which provides for 3 x three-bed dwellinghouses.
Costs
Cost Per Unit/Metre
No. Units/Metres
Total
Four Bed Bungalows
169,000
14
2,366,000
Two Bed Bungalows
104,000
12
1,248,000
Estate Road
1200
200
240,000
Utility Connections
5000
26
130,000
Professional Fees
-
-
120,000
Sprinklers
3500
26
91,000
Parks Contribution
2464
26
64,000
Education Contribution
1000
17 children
17,000
Total
4,276,000
Sales
3/4 Bed (Open M’kt)
295,000
14
4,130,000
Two Bed (Open M’kt)
185,000
7
1,295,000
Three Bed Affordable
78,000
5
390,000
Total
5,815,000
Developers Profit
Total
1,047,000
Residual Land Value
492,000
Table 2
5.1.3 Based on the above figures, it is considered that in-principle, the development of the site would be financially viable. The residual land value of £492,000 with a net area of 2.2 acres is consistent with evidence gathered over recent years by the District Valuer in examining residential site transactions within Carmarthenshire. The DV discovered land values on completed and on-going sites to be averaging £245,000 per net residential acre of land, based on 2019 values.
5.2 DELIVERABILITY
5.2.1 In terms of deliverability, it should be firstly noted, as illustrated above, that the site is financially and physically viable, with no environmental, geo-physical or technical constraints prohibiting immediate development. Furthermore, there are no ownership or third-party interests preventing the site’s delivery.
5.2.2 In terms of a delivery timescale, with a developer secured, it is envisaged that the site could be capable of being completed within 3 years from the adoption of the replacement Local Development Plan. Burry Port remains an attractive part of the Carmarthen Bay coastline, benefitting from its semi-rural location, but easy access to Carmarthen and Llanelli by road and rail and the nearby schools, shops, services and community facilities.
5.2.3 The presence of modern houses at Goodig and Glanmor Terrace is testament to this market need and the desire for home buyers to seek out such forms of modest residential development.

6.0 NATIONAL PLANNING POLICY CONSIDERATIONS
6.1.1 In the preparation of any development plan, consideration must be given to national planning policy and guidance. At present, this takes the form of Planning Policy Wales (Edition 11) and a series of Technical Advice Notes (TAN) that deal with a range of topic areas.
6.1.2 With regards to residential development, or housing, the overarching requirements and principle guidance set by national policy, which reads as follows:
“Local planning authorities must ensure that sufficient land is genuinely available or will become available to provide a 5-year supply of land for housing judged against the general objectives and the scale and location of development provided for in the development plan. This means that sites must be free, or readily freed, from planning, physical and ownership constraints, and economically feasible for development, so as to create and support sustainable communities where people want to live. There must be sufficient sites suitable for the full range of housing types.”
6.1.3 At present, Carmarthenshire County Council’s housing supply figure is below the required 5-year level and so it is imperative that this is addressed as quickly as possible to avoid further deterioration of communities and the facilities and services they have to offer. The instigation of the formal Review of the LDP will form part of addressing this issue, but only if truly sustainable and deliverable allocations are identified and allocated, to replace many of the failing sites that currently form part of the Authority’s housing and growth strategy for the County, as set out by the current LDP.
6.1.4 Dealing specifically with the Candidate Site subject of this Report, it is evident that its inclusion within the Replacement LDP would adhere to the requirements of PPW in that it is free from any planning, physical or ownership constraint. In addition, as shown at Section 5 of this Statement, the site is also economically viable in deliverability terms.
6.1.5 PPW provides Authorities with more specific guidance in selecting sites for allocation for residential development and in terms of the Candidate Site, it is considered that it satisfies all relevant criteria, including the following:
• The location of the Candidate Site is sustainable in terms of its proximity to a range of community facilities, local services and public transport services.
• The physical and social infrastructure of the settlement is capable of accommodating the proposed development without detriment to any interest.
• The Candidate Site is not subject to any physical constraint such as ground instability, ecological interest, flood risk, historic assets or contamination, that would prevent its delivery.
• The development of the site for residential purposes would be compatible with existing adjoining land uses, and its form contained by firm, defensible perimeters.
6.1.6 In summary therefore, the allocation of the Alternative Site adheres and supports the objective, principles and requirements of national planning policy.

7.0 CONCLUSION
7.1.1 The Alternative Site consists of the lowest section of a semi-improved grazing field, which falls against the rear of the public cemetery, and off the eastern side of residential properties at Dolau Fan. The development of the site would form a parallel development with Dolau Fan as that modern cul-de-sac ascends ground levels north of the town and A484 main arterial road.
7.1.2 The Alternative Site forms a logical extension to the existing settlement, being well related to established residential development off its southern perimeter, and further development to the east upon The Graig. The Site can be found to be capable of being accessed off the existing public road carriageway, with extension of the cul-de-sac arrangement into the Alternative Site.
7.1.3 The precise location is such that the strong defensible boundaries of boundary hedgerows and trees off the south-eastern and eastern perimeters provide a natural and part physical screen from views within the wider landscape. The development of the site would take place against the backdrop of higher ground to the north and residential properties to the immediate foreground. Accordingly, the development of the site would remain more akin in character to the built-up form of Burry Port, than open gorse and shrub to the north and north-east.
7.1.4 In addition to the above, the site lies within close proximity and walking distance of the existing community services and local facilities of Burry Port, particularly convenience shops, supermarket, convenience shops, public houses, rail station and Primary and Secondary Schools, which will ensure it makes a positive contribution to both national and local sustainable development objectives.
7.1.5 With the Alternative Site having no access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints, its delivery if allocated is assured. Combined therefore with its locational characteristics, the Site in question represents a sustainable candidate for future housing development.
7.1.6 In view of the above and information provided in this Statement, it is respectfully requested that the Alternative Site in question be allocated for a modest residential development.

Include Candidate Site reference SR/058/003 as a housing allocation in the Plan.

We are instructed by Mr J.T.J. & Mrs C.W. Davies to a make a formal representation to the
“soundness” of the Deposit Draft of the Carmarthenshire Local Development Plan.
Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/058/003, seeking inclusion of their land for future residential development within the
defined settlement limits of Ferryside within the Replacement Local Development Plan.
The Candidate Site comprises a rectangular-shaped former grazing field set to the
immediate rear of the Parc-y-Ffynnon residential estate, which was completed in 2019.
Provision for future access into the rear field has been left over in two points.
We have noted that approximately half of the Candidate Site is included within the Second
draft settlement limits as Residential Allocation Sec2/h2 capable of accommodating 12
residential units according to the housing schedule listed under Policy HOM1 of the Plan.
However, the eastern half of the field has not been included.
This formal Representation relates solely to the unsuccessful part of the Candidate
Site.

The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our clients’ submission, reasons why all the site was not selected for inclusion within the
Second draft settlement limits of Ferryside, as contained within the Second Deposit Draft.

We note that the submission successfully passed through all three Assessment Stages,
being Stage 1 (site compatible against the location of future growth presented in the
Preferred Strategy), Stage 2A (Initial Detailed Site Assessment), Stage 2b (Further Detailed Site Assessment) and Stage 3 (Sustainability Appraisal and Habitat Regulation Assessment) of the Council’s site assessment. It therefore crucially was adjudged acceptable in all technical aspects of formal assessment but was only partially rejected at the final selection stage, with reasons for non-inclusion reported as follows: “Part of the site is to be allocated with reference SeC2/h2.”

Our clients consider the LDP is “unsound” and should be changed, as it fails to meet the tests for “soundness,” in that the Plan “is not appropriate,” and “will not deliver,” as defined by the Planning Inspectorate’s LDP Examinations Procedural Guidance.
Specifically, our clients consider that the Second Deposit draft settlement limits for Ferryside, as defined under Policy SD1 “Settlement Limits”, should be amended to include the land as edged in red upon the extract of the Proposals Map for Ferryside, as reproduced below in Figure 1. The land should be appropriately allocated for housing under Policy HOM1 “Housing Allocations.”

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

This formal representation letter supplements the following documents which comprise a complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits

1.0 Allocation of only Half of Candidate Site
1.1 The Council have not provided any reasoning whatsoever for the draft allocation of only half the Candidate Site. The new settlement limit, as shown by Google Earth in Figure 2 below, does not follow any defensible boundary, such as a hedgerow, treeline or even dividing fence across the enclosure. Its positioning is therefore physically illogical in the context of adding new housing to this part of Ferryside.

Figure 2 – Google Earth (April 2021) – illustrating the cultivated form of the Candidate Site

1.2 We therefore consider that the Council has adopted this rather inconsistent approach on the basis that it only considers that Ferryside should grow by very minor proportions over the Plan Period to 2033.
However, the village is significant in scale, containing several hundred dwellinghouses, primary school, convenience shops, public houses, education centre and railway station. It also possesses good public bus service connections to Carmarthen and Llanelli, with the X11 service calling en-route to Swansea City Centre. In other words, it is highly sustainable as a place to live, work and also continue to accommodate holidaymakers. The village contains several guest houses, caravan and chalet parks serving the tourist sector.
Candidate Site
Draft Housing Allocation Sec2/h2
1.3 The Representation Site indicative site layout plan is reproduced below as Figure 3.
It illustrates for cul-de-sac form of development with a total of 23 detached and semi-detached dwellinghouses set fronting an internal estate road, which can access the site via two independent access points from the Parc-y-Ffynnon estate. Thus the proposed form of layout and development is complementary in form to adjacent established form of residential layout at Parc-y-Ffynnon, with frontage parking, and traditional rear garden space.
1.4 The draft Allocation for only 12 units indicates that one access would be used, being the western access, and thus it would require amendments to the site layout to ensure all vehicles access and egress through that single access.
1.5 We submit that the Candidate Site encompasses the entire rear, south-eastern boundary of Parc-y-Ffynnon properties and thus complemented that entire development in width and form. The proposed draft allocation in only proposing half that area fails to respect that character, and in commiting to allocate land beyond the previous LDP settlement limits, our clients cannot understand the physical logic in not extending the draft allocation over the entire field. The Candidate Site field exhibits a consistent gradient and form across its entire length, and therefore the excluded eastern half bears no difference in profile and physical form to the western draft allocated half.
1.6 Google Earth provides such graphic evidence that the allocation of the whole field will not pose any detriment to the visual amenities of the locality. The eastern perimeter stands as a tall and proud hedgerow, with mature, tall trees to the rear extent. Coupled with the lower ground being dominated by adjoining modern houses, any viewer from public viewpoints on ground east, west and north of Parc-y-Ffynnon will have no ready appreciation that the Candidate Site is wholly developed as opposed to only half developed as suggested by the Council. There is no public access to land to the south given it is significantly higher in contour level, steep and impassable with dense woodland vegetation. It nevertheless presents a “green blanklet” or backdrop to the modest expansion southwards of Parc-y-Ffynnon.

Figure 3 – Indicative site layout plan of proposed Representation Site

2.0 Overall Housing Supply at Ferryside & Carmarthen Cluster
2.1 The proposals under this Representation merely seek the addition of a further 11
residential units to the overall housing supply of Ferryside, to add to the 12 units
already allocated within the draft Plan. Ferryside is defined as a Tier 2 Service
Centre, and lends to the principal service centre centring upon the Carmarthen
Cluster as defined within the draft LDP.
The Carmarthen Cluster aims to provide an additional 1646 residential units over the
Plan period to 2033, and thus the addition of a larger allocated site at Ferryside of 23,
rather than the current draft of 12 units will not lead to an over-supply of
dwellinghouses within the Cluster. The LDP village classification as a Tier 2 Service
Centre implies that it possesses far more community facilities and public
transport links than a typical Carmarthenshire village. Accordingly, it should be
afforded a reasonable level of future housing growth for the next 10 years.
2.2 Ferryside is quite unique in terms of its positioning and setting being part of the
Carmarthen Cluster. It is placed at the south-eastern extremity of the defined area,
bordering the Llanelli Cluster, and its extremity settlements such as Kidwelly.
Ferryside serves a rural hinderland and is the principal settlement off the eastern
banks of the Towy Estuary, and consequently, there are few other defined settlements in this part of the County which contain specific residential allocations.
2.3 Policy HOM1 provides details of the two allocations in Ferryside as shown below.

Figure 4 – Policy HOM1 Residential Allocations at Ferryside

Only one other site is allocated in Ferryside that relates to 12 residential units at “Caradog Court”. It benefits from an extant planning permission dating from 2011, and has been mostly completed, albeit a range of modest, two-bedroomed linked units form the bulk of the remaining allocation of 12 units as defined in the draft Allocation. That site is “carried over” in allocation from the previous 2008-21 LDP.
2.4 We have therefore examined and researched sites which have been brought forward as Residential Allocations with the Second Deposit Draft in the Carmarthen Cluster. The Cluster extends in geographic area to Bronwydd, Cynwyl Elfed, Peniel, Rhydargaeau, Alltwalis and Llanpumsaint to the north of the town. It stretches south-west to Llansteffan and Llangain, and east along the River Towy to include Nantgaredig, Pontargothi, Llanarthney and Capel Dewi. It extends along the A48 road as far as Llanddarog and Porthyrhyd. Finally, it stretches south-east along the Towy Estuary to include Cwmffrwd and Ferryside and partly along the Gwendraeth Valley to Pontyates. The following allocations are noted for their inactivity and undeliverability over the last 8-9 years.
2.5 West Carmarthen (PrC1/MU1) – 700 UNITS
In Carmarthen, great emphasis within the Draft Plan has been placed upon the continued allocation of a large, proposed housing site at West Carmarthen. The site is allocated for 700 residential units as Site PrC1/MU1.
This allocation forms the bulk of a Residential Allocation carried over from the current LDP (2014-21) where the allocation was for 1100 units.
We have calculated that of that 1100 units only a total of 141 were constructed between the Plan Adoption date of December 2014 and start of this Replacement LDP Plan Period of 2018. Since 2018, a further 90 units have been constructed, and we note from Land Registry records that the last completed unit was sold at Maes Macsen in September 2021 (18 months ago).
Therefore, since adoption of the 2014 LDP, only a total of 231 units have been completed, equating to a build rate over that 7-year period of only 33 units per annum. This build rate is considerably lower than the anticipated and much promised
delivery of 1100 units in the Plan Period of 2014 to 2021, which would have expected an annual build rate of 157 units. An actual return of 33 units per annum equates to only a 21% build rate return on that anticipated for delivery in the 2014-21 Plan.
Only 39 of those units were built in 2017-18 accordingly to the Joint Housing Land Availability Study 2018. The 2019 Study reveals that only a further 5 units were constructed in 2018-19. The August 2019 Study reports that none were under-construction at that time. During 2020 and 2021 when Covid-19 restrictions were at their peak, more units were constructed than at any other time in that LDP plan period, and therefore we would submit at this point in our formal objection that low build rates cannot be held to be reduced as a consequence of Covid-19 restrictions.
It is equally noteworthy that at a time when the housing market was at its most buoyant in 2022, that the only housebuilder with a track record on the site had ceased construction and sold their last completion (September 2021). We submit that this is testament to the weak marketability of the West Carmarthen Site.
Only 231 units out of 1100 units of the Strategic Site have therefore been completed in the 2014-21 LDP period, which equates to only 21% of that allocated total.
The Replacement LDP seeks to delivery 700 units over a Plan Period from 2018 to 2033. The extract from the Proposals Map for Carmarthen reveals that the figure includes for 90 units constructed between 2018 and 2021, leaving a balance of 610 units envisaged in the remainder of the Plan Period to 2033. That would equate to a build rate of 61 units per annum over a 10-year period. Based upon previous build rates at this site, such a predicted build rate can be described as overly optimistic, being nearly double that actually achieved on the site to date.
The West Carmarthen draft allocation includes parcels of residential allocations off the flanks of the A40 that were previously allocated within the Carmarthen District Local Plan (1997), and subsequent Carmarthenshire Unitary Development Plan (2003). No progress was made in bringing the sites at Llysonnen Road and Old St. Clears Road forward, and yet it was allocated within the Local Development Plan in 2014. Consequently, twenty-seven years of Development Plan allocations have elapsed without any signs of delivery of the majority of this site.
Clearly, there is no historic demand for a site of this scale in this part of Carmarthen. More physically challenging sites, such as the Roman Park site in Llangunnor by Redrow Homes, and the Mount Pleasant site, also in Llangunnor, by Lovell Homes have come forward, and been fully completed, long before West Carmarthen. Yet still the Council is prepared to allocate the site once again for hundreds of residential units in a new Development Plan.
2.6 Pibwrlwyd (Site PrC1/MU2) – ALLOCATION OF 247 UNITS
We would also question the allocation of land at Pibwrlwyd in Carmarthen, being partly for a residential development of 247 units on the Parc Pibwrlwyd development. The Council published and subsequently adopted Supplementary Planning Guidance on “Pibwrlwyd” in 2014.
Paragraph 3.2 was quite specific in that “The LDP describes the acceptable uses on the site as follows: “The proposed use for the site is for a business park centred around employment uses (Use Classes B1, B2 and B8), with uses associated with, and ancillary to the existing Coleg Sir Gâr.”
A development brief in the form of SPG has been prepared and adopted. This in setting out appropriate uses under Use Classes B1, B2 and B8 for the employment element of the site also explores other compatible uses. Residential use on this site is not considered appropriate.” (self-emphasis)
The Council has seen fit to re-examine the Development Plan status of this Mixed-Use Site and concluded that residential uses should now be brought forward, with a residential capacity of 247 units. No explanation has been provided within the supporting text to LDP policies to warrant a dramatic departure from the adopted SPG.
The site is completely and physically divorced from established housing at Pensarn and Llangunnor. It is physically separated by foot from local schools, community facilities and play facilities by the A40 / A48 trunk road network, with only a dark and insecure pedestrian underpass linking it to the Pensarn Commercial Area.
New housing at this location would accordingly be quite alien in form to the long-established business and education uses at Pibwrlwyd.
2.7 Land off Parc-y-Delyn (PrC1/h4) – ALLOCATED FOR 17 UNITS
This new allocation suffers from including Tree Preservation Orders imposed upon specimens at the proposed vehicle access onto Parc-y-Delyn. The site also appears covered in rich flora and fauna and could harbour biodiversity interests.
2.8 As referenced at the outset of this Section, there are several satellite settlements about Carmarthen contributing housing allocations to the Cluster Total of 1690 dwellings. However, we have discovered that many allocations have simply and conveniently been “rolled over” from the 2014 adopted LDP, or in some cases even earlier from the 2008 Unitary Development Plan. No explanation, evidence or demonstration of viability or deliverability has been provided within the Site Assessment Table (January 2023) to demonstrate such a widespread practice.
The following sites are examples of such dormant sites:
Cae Camfas, Heol Llanelli, Pontyates (SeC1/h4) – ALLOCATED FOR 8 UNITS
This site in Pontyates was allocated in 2014 in the Local Development Plan, and yet no applications for planning permission have been submitted in the entire 8 years of the Plan Period.
2.9 Gwyn Villa, Llanpumsaint (SuV12/h1) – ALLOCATED FOR 20 UNITS
This site in Llanpumsaint was allocated in 2014 in the Local Development Plan, and yet no applications for planning permission have been submitted in the entire 8 years of the Plan Period.
2.10 Fronheulog, Cynwyl Elfed (SuV1/h1) – ALLOCATED FOR 8 UNITS
This site in Cynwyl Elfed was allocated in 2014 in the Local Development Plan, and also the 2008 UDP, and applications for planning permission have been submitted for only two individual houses in the entire 15 years of the above combined Plan Periods have been commenced.
2.11 We submit that the above draft allocations at West Carmarthen be significantly reduced in scale, and in the case of Pibwrlwyd and above-named satellite allocations be omitted from the Plan and that housing allocation be redistributed to modest Candidate Sites, of up to 20-30 units such as that proposed at Parc-y-Ffynnon. There is clear evidence in the rapid completion of the adjoining Parc-y-Ffynnon development that such modest sites are far more likely to be brought forward and developed in full by regional and small housebuilders given that construction and development costs are more likely to be viable in relation to house sales and the general housing market in this part of Carmarthenshire.
2.13 In the case of Parc-y-Ffynnon, there are little signs within the immediate locality of properties for second sale, and no evidence of undeveloped land available within this part of the settlement limits, which is a strong indicator of a healthy property market at Ferryside. Consequently, it is a location where housing proposals are deliverable, assisting to meet housing needs in this part of the Carmarthen Cluster.

CONCLUSION
In conclusion, this Representation to the Second Deposit Draft of the Revised LDP has sought to examine the Council’s reasons for non-inclusion of all the Candidate Site.
Our clients have illustrated that their indicative proposals to construct a total of 23 dwellinghouses will not appear at odds to the prevailing spatial pattern of development in Ferryside. The locality has numerous examples of modern cul-de-sac development being completed at backland / edge of settlement locations, which in turn, advocates that the form of development proposed at Parc-y-Ffynnon is no different, resulting in it being respectful to the character and setting of the locality. The Council have already acknowledged that a backland site is suitable at this location in Ferryside, our clients merely suggest that it be enlarged to encompass all the level field to a parallel position with the constructed Parc-y-Ffynnon development.

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

Allocate the site for housing in the Revised LDP.

Our comments on the First Deposit Plan are set out below and remain relvant. There has been some updating of the evidence base for the Plan since March 2020, this does not fundamenlty alter the case that we presented in March 2020. Then as now, the housing requirement for 2018-2033 is 8,825 which we said was too low. Of note is that the First Deposit Plan enabled 10,160 homes whereas the Seocnd Deposit Plan enables 9,704 homes. There is therefore a reduction in embedded flexibility and contingency, for a plan requirement that is already not representative a a positive socio-economic vison.

First Deposit Stage
At First Depsoit Stage we made the following comments
Section 8 of the Deposit LDP sets out the range of growth options that have been prepared to inform the Plan.
The PG 10-year scenario from the 2019 Edge Analytics Report has been selected which generates a requirement for 8,835 homes for 2018-2033 (589 per annum) and 354 jobs per year.
The general thrust of Section 8 is that the housing requirement should at least reflect the rate of housing delivery that has been experienced since 2015 (545 homes per annum).
Lower growth options are rejected for negative socio-economic impacts and non-adherence to the Plans Vision and Strategic Objectives. We agree.
Higher growth options are presented positively, notably the output for ’Population Growth Long Term (2018 Report) for 9,887 homes (659 per annum) and 353 jobs per year and 10,065 homes and 439 jobs per year (PG Long Term (2019 Addendum Report). The later now essentially forms the proposed supply figure.
The proposed housing supply of the Deposit LDP is said be capable of delivering 10,160 homes (a 15% uplift to ensure that the base requirement is met).
We conclude that the proposed requirement is far too low. At the very least it should be 10,065 homes (baseline), With a 15% uplift for flexibility generating a supply figure of 11,575 homes. This generates a need for another 1,415 homes.
A scenario of 14,090 homes and 632 jobs per year derived from pre-recession trends is said to be commensurate with the adopted LDP. This is said to be economically ambitious but ‘undeliverable’ and ‘unsustainable’. We note that the Council do not say that 632 jobs per year is unrealistic as forecast, and rightly so. The Council’s own Employment Sectoral Report (WSP, 2017) generates a forecast for 2017-2032 of 18,681 jobs (1,245 per annum,or 1,182 after ‘double-jobbing’.
We are not convinced that a baseline requirement of 14,090 homes and 632 jobs per annum is ‘undeliverable’; in terms of housing or employment growth. It is not unsustainable socio-economically. We see no evidence that it would be environmentally unsustainable to attempt to meet these figures, wholly or in part.
The spatial strategy should seek to meet these higher figures, subject to land suitbality and availability.
Policy SG1 should be amended to seek to meet as far as possible a previously achvieved set of development outputs for the area
We agree with the selection of spatial strategy Option 4 in order have a strategy in place for the 6 sub-areas (clusters) of the County that have been identified.

Second Deposit Plan
Section 8 now optioneers the First Deposit Stategy against the Welsh Governemnt’s 2018 based population projections. Both the principal projection and higher variant are rejected as a being unrepresentative of a sustainable future for the area. Instead, the Council generally prefers 10-15 year trend based population projections (which present simalar outputs) as presenting a more positive vison. They are also more in tune with the strategy and housing requirement of the First Deposit Plan.
The final two scenarios generate higher housing requirements of around 10,000 -10,500 homes. Although yet higher still than previous completion rates these are still some way below pre-recession growth rates.
We question why the final two secarios would not deliver the Vision and Strategic Objectives for the area and the confidence with which the Council states that this level of growth would tip into being undeliverable. Quoting percentages masks a realtive modest uptick in actual delivery rates. It is the not case that the higher ambition within the final two scnearios would cross a threshold in terms of thier environmental effects.
We maintain our comments, expressed at First Deposit Stage, that, at the very least the Plans housing requirement should be 10,065 homes (baseline), With a 15% uplift for flexibility. This generates a supply figure of around 11,575 homes, as opposed to the 9,700 enabled by the Plan.
The pre-recession trend scenrio no longer appears in the Second Deposit Plan, so presumably the Council no longer considers it to be a reasonble alternative?

Site Submission
Against this background additional land at Penygroes should be allocated within Settlement Cluster 3. The Plan already allocates land for 290 homes across 5 sites and these all have planning permission. Emlyn Brickworks (PrC3/MU1) (177) and land adj Pant y Blodau (PrC3/h22) (79 homes) account for 88% of proposed new homes.
Land west of Waterloo Road and south of Maesglas (previously submitted at First Deposit Stage) should be allocated for 44 homes.
A site location plan and testing layout is attached to this representation showing an indicative layout for 44 homes. The site is already contained on 3 sides, including the relatively recent development at Clos Ael-Y-Bryn to the south and Cwrt Y-Fynnon to the north east. The surrounding settlement and a strong hedgerow to the east provide a high degree of enclosure and the land is within the general envelope of the village.
We assess that the ISA of this site is identical to that prepared by the Council for the allocated site known as ‘ land adj Pant y Blodau’ (PrC3/h22) in respect of significant effects. This concludes that "This site does not utilise previously developed land, however it otherwise performs well against the sustainability framework".
We also refer the inspector to the proceedual issues rasied under section of 4 of this represertation.

Include the site in Plan.

INTRODUCTION
1.1 Evans Banks Planning has been instructed by Mr C. Hurley (the Landowner) to prepare and submit a Representation for an Alternative Site to the Second Deposit Draft for the allocation of land at “Oaklands,” Furnace Road, Burry Port for the purposes of residential development in the Replacement Carmarthenshire Local Development Plan.
1.2 This Statement has been prepared in line with the Authority’s published documents entitled Revised Carmarthenshire Local Development Plan: Guidance Note and Revised Carmarthenshire Local Development Plan: Candidate Site Assessment Methodology. The contents of this Statement therefore address the set criteria, determining issues and each qualifying point raised within these documents
Consideration has also been given to ensuring that this formal submission complies with the guidance and requirements of Planning Policy Wales (Edition 11), in relation to the preparation of development plans and the allocation of land for residential purposes as part of that preparation process.
1.3 The contents of this Statement therefore provide a comprehensive case for the allocation of the land for residential development purposes and it should also be read in conjunction with the accompanying supporting information and indicative site layout plan.

2
2.0.0 SITE CONTEXT
2.1 THE SITE
2.1.1 The Alternative Site relates to part of a generally level, but large domestic curtilage associated with a detached dwellinghouse known as “Oaklands.” It is set immediately off the western flank of Furnace Road to the western side of the settlement of Burry Port. The Alternative Site is an irregularly shaped enclosure with the house set within the southern half of the site, and lawned garden area stretching north to an embankment with a former railway cutting.
2.1.2 The southern boundary of the site lies parallel with the boundary of the Ashburnham Hotel grounds and a similarly level enclosure at that site and the junction of Furnace Road with Ashburnham Road. That southern boundary is tree-lined, with the frontage with Furnace Road marked by an intermittent hedgerow for its 95 metres length.
2.1.3 The western perimeters of the site fall onto scrub which is also gently level to undulating and is set to separate Burry Port from Pembrey, but that undeveloped gap is only some 175 metres from the domestic curtilage of Oaklands to the eastern fringes of established houses at Pembrey.
2.1.4 The Site relates to some 0.99 hectares (2.45 acres) of well-maintained lawns with established, two-storey dwellinghouse. It has an independent vehicular driveway off Furnace Road set directly opposite established residential properties off the eastern flank of that road, where two-storey semi-detached local authority-built houses are concentrated as part of the “Bryniltyd Estate”.
This part of Burry Port is characterised by modern housing, mostly of 1960s and 70s origin and local-authority-built. The Brynilltyd estate also includes Brynymor, which extends over several access and off one access on to Furnace Road, directly opposite the access to Oaklands.
2.1.5 The Site field parcel is identified by being edged in red on the plans below. Plan A illustrates their wider position with the settlement of Burry Port. Plan B provides a detailed Ordnance Survey map extract with the site perimeters identified.
Plan A – setting of Oaklands at Burry Port
Detailed OS Plan - Plan B
2.1.6 The Site consists of a large, domesticated curtilage which already contains a sizeable residential property. The development of the site which will form a mirrored extension to the Brynilltyd estate, appearing as a continuation of the existing row of semi-detached properties and single detached house off the opposite flank of the Furnace Road carriageway. It is therefore well defined by those existing natural and man-made perimeters.
Plan C below provides a Google Earth image of the site and its surroundings, in which the above physical features are readily apparent.
Plan C – Google Earth image of Site
2.1.7 The Site’s well-defined perimeters and immediate proximity to the adjacent established residential properties off the Furnace Road highway, are shown within the photographs below. The photos also depict the existing boundary fence separating grazing fields and access road of the Candidate Site.
Photograph 1 – view of Site with existing dwelling set centrally with large curtilage
Site
Adjacent residential estate of Brynlltyd
Photograph 2 – view from existing Furnace Road carriageway looking over Site with Oaklands dwelling in background
Photograph 3 – view of properties off opposite, eastern flank of Furnace Road
Photograph 4 – view of southern tree-lined boundary with Ashburnham Hotel enclosure
Photograph 5 – view from bridged crossing of former railway line (now cycle path) looking at vegetated northern boundary of site
2.2 SETTLEMENT SUSTAINABILITY AND SITE SETTING WITHIN DRAFT LOCAL DEVELOPMENT PLAN
2.2.1 Under the Second Deposit Draft of the Carmarthenshire Local Development Plan, Oaklands falls adjoining the Settlement Limits for the settlement of Burry Port. The large domestic curtilage lies immediately adjoining established estate properties off the eastern flank of Furnace Road. The site is edged in red on the map extract.
Plan D – Extract from Second Deposit draft LDP Proposals Map of Burry Port
2.2.2 As can be seen, the Site adjoins and is well related to the Second Draft LDP Development Limits for Burry Port, and also within walking distance of the village centre
at Gwscwm Road to the north-east via the existing surfaced pavement of Furnace Road and east along Ashburnham Road.
2.2.3 Access to the Site could be achieved with a new junction onto Furnace Road, with the existing house driveway and access retained. The proposed access road would lead into a proposed cul-de-sac development, with conventional hammerhead turning area.
2.2.4 The Site’s position and proposed use therefore represents a natural and logical location for the settlement’s expansion in the context of adjoining established and proposed residential development.
As detailed above, the Site adjoins and in effect lies within the existing settlement and form of Burry Port. The existing built form and pattern of the settlement follows key access routes, such as the A484 Gwscwm Road and Lando Road, to the north and Ashburnham Road. The established town centre at Station Road extends off Ashburnham Road, with multiple cul-de-sac modern developments concentrated to the mid-hillslopes to the north of the A484 road, or south to the main railway line extending west to east from Burry Port to Kidwelly.
Burry Port is particularly popular to new homeowners due to its coastal position, and short drive to Llanelli, and in particular the A484 link to Carmarthen.
2.2.5 In terms of the Site is located within easy walking and driving distance of all community facilities and local services present and provided within the settlement of Burry Port. Access to further facilities in the towns of Llanelli and Carmarthen can then be gained by regular bus services, stops for which are located some 90 metres from the Alternative site at the junction of Ashburnham Road with Furnace Road.
The sustainable position of Burry Port should therefore be given full consideration when considering potential future growth options.
2.2.6 Housing Land Availability within Second LDP Draft
We have examined and researched sites which have been brought forward as Residential Allocations with the Deposit Draft. Burry Port falls under the Llanelli Cluster which extends along the Burry Estuary coast from Kidwelly in the west to Bynea in the east, and north to Llangennech and Hendy about the M4 corridor.
Great emphasis within the Draft Plan has been placed upon the continued allocation of proposed housing sites still left allocated from the 2014-21 Local Development Plan. Figure 1 below provides an extract from the Deposit Draft Schedule of Housing Sites from Policy HOM1, relating first to Burry Port, and accordingly across the remainder of the Llanelli Cluster.
Extract from Policy HOM1 – Burry Port
Figure 1 – Selection of Deposit Draft Housing Schedule in Llanelli Cluster
We note that within the Proposals Map for Burry Port, it included for three sites, two of which have been completed at Goodig and Glanmor Terrace leaving just one proposed site, which being the Harbourside site for 364 dwellings. The site has been marketed by the County Council for many years, and despite its coastal position, has failed to receive firm interest and any form of detailed planning application. Ground conditions require extensive remediation of former historic uses.
2.2.7 The Llanelli suburbs of Llwynhendy / Cefncaeau and Dafen, where four of the above allocations are identified, has not altered since the 2014 adopted LDP and remain undeveloped but re-allocated in the Deposit Draft.
Cwm-y-Nant (PrC2/h22) and Dafen East Gateway (h/23) were both sites allocated within the Carmarthenshire Unitary Development Plan (2006) and as mentioned above, within the Local Development Plan (2014) as sites GA2/h27 and h/30 & h/31. They
have a combined total of 352 dwellings, although neither site has been the subject of any detailed planning application, let alone market interest.
The locality is riddled with historic coal mining activity, with low lying coal seams, together with multiple mine entries across all Dafen sites. Clearly, any residential development upon either site will have to overcome ground remediation to stabilise the ground for residential foundations. The abnormal costs of which are likely to be significant, and hence present the development costs as leading to unviable and undeliverable sites.
2.2.8 Beech Grove at Pwll (PrC2/h1 has remained allocated for 10 units for the last 20 years in Development Plans. No application for planning permission has even been lodged at the site.
2.2.9 Cae Linda in Trimsaran (SeC8/h2) for 20 units has been in Development Plans stretching back to the Llanelli Borough Local Plan in 1995. It has only been developed with 5 houses, and thus its continued allocation for twenty more units in the draft LDP must surely come under question?
2.2.10 Consequently, at least twenty years of Development Plan allocations have elapsed without any signs of wholesale delivery of these sites. Clearly, there is no historic demand for sites of these scales in parts of the Llanelli, Trimsaran and Burry Port / Pembrey areas. All are certainly physically challenging sites, many of which have historic industrial or coal mining legacy issues, which may require significant abnormal costs to achieve developable areas for residential use.
We submit that the above draft allocations be omitted from the Plan, and that housing allocation be redistributed to Alternative Sites, of circa 20-25 units such as that proposed at “Oaklands” at Burry Port. There is clear evidence that such moderately sized sites are far more likely to be brought forward and developed in full by regional housebuilders given that construction and development costs are more likely to be viable in relation to house sales and the general housing market in this part of Carmarthenshire.
2.3 Settlement Facilities
2.3.1 The Site at Furnace Road lies some 10 minutes’ walk from the centre of the town at Station Road.
Public bus stops lie immediately off the junction of Furnace Road with the Ashburnham Road carriageway.
Main public bus services call at these bus stops, and further stops are available at Stockwell Lane in particular:
- Service 111 – Kidwelly to Swansea, calling at Pembrey, Burry Port, Llanelli, Trostre, Gorseinon, and Fforestfach
- Service X11 – Carmarthen to Swansea, calling at Ferryside, Burry Port, Llanelli, Trostre and Fforestfach retail parks
2.3.2 The site is within 10 minutes’ walk, to the London Paddington to Fishguard / Pembroke Dock rail service at Burry Port station.
2.3.3 The Site lies within a 5-minute walking distance of Pembrey Primary school at Ashburham Road.
Ysgol Y Strade and Burry Port Secondary Schools are located at Llanelli and Burry Port respectively, with pupil bus transport available to Ysgol-y-Strade.
The CCTA campuses at Llanelli and Carmarthen are also available via student bus services.
2.3.4 Nearby Pembrey contains a post office, two public houses and community hall along Ashburnham Road.
Burry Port town centre provides a range of small comparison shops, supermarket, petrol filling station, public houses / cafes, offices, rail station and industrial estates.
Plan E below provides an indication of the proximity of the site to Burry Port town centre, with its rail station and strategic road network to Llanelli and Carmarthen.
The red star denotes the position of the Site.
Plan E – proximity of Site to Burry Port town centre
Primary School
Suoermarket and town centre
Rail Station
A484 Road to Llanelli and Carmarthen

3.0 THE PROPOSAL
3.0.1 As part of the requirements for the promotion of sites for residential development, this Statement is accompanied by an indicative layout for a potential residential scheme that could be developed on the site. It should be emphasised that the accompanying layout is for illustrative purposes and that other design solutions for the site could also be reached. Notwithstanding this, the accompanying layout drawing has taken account of all the potential assets and constraints of the site and demonstrates that it is capable of delivering 18 houses in a deliverable and sustainable manner. The following information therefore expands on this principle.
3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Site be allocated in the replacement LDP for the purposes of a total of 18 residential units. As detailed above, the accompanying illustrative layout (reproduced below at Plan F) demonstrates that the site is capable of accommodating this number in a deliverable and sustainable manner.
Site layout plan - Plan F
3.1.2 As illustrated above, the site is capable of accommodating detached and semi-detached, two-storey houses to replicate and being reflective of the existing form and density of residential development in the immediate locality.
3.1.3 With regards to access, it is proposed that the Candidate Site would be served by a 6.0 metres wide radii junction onto Furnace Road. This stretch of Furnace Road experiences vehicle speeds which are respectful of the 20mph speed limit, given the presence of speed humps. Visibility splays of 2.4m x 43m can be achieved within this built-up locality.
3.1.4 The Site proposals can fully retain all existing boundary treatments, being the established mature hedgerows across the southern and northern sides of the field, which would be retained and managed wherever possible.
3.1.5 Although due to the proximity of existing facilities in Burry Port, the proposal does not include any formal areas of play or open space. It is recognised and supported that an element of the proposed units could be Affordable in nature, or contributions made to support affordable housing elsewhere in the Llanelli locality, which under the provisions of the current LDP would be in the region of 20% of the total number of dwellinghouses.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Development of the Site for residential units would be served by mains water, gas, public sewer and electricity connections, which either lie within the respective stretch of Furnace Road carriageway.
3.2.2 The estate road highway itself is equipped with roadside gullies and drainage which aid to discharge run-off from the carriageway. The proposed access to the site could connect to the existing highways drainage.
3.2.3 The Site comprises of domesticated lawns. There are no areas of significant marshy grassland or water-logging evident, and therefore at first inspection, it appears that the site benefits from good ground percolation of rainwater.
3.2.4 Soakaways would be the most sustainable means of disposing of surface water from individual properties. If required, attenuation measures can be deployed on site to control surface water run-off during extreme storm events, which could also allow for additional capacity, making allowances for climate change. Such features can be hard engineered in the form of small to modestly-sized subterranean storage crates or tanks. The field enclosures are served by a series of drainage ditches along the fields boundaries, which eventually combine and inter-connect discharging surface water which eventually discharge to the Estuary. It is considered that as a result of on-site features, there would be a number of options available to a future development of the site in terms of surface water disposal.

4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 The Site has been assessed against data held on the “Data Map Wales” website, which details statutory and non-statutory National and Local sites of ecological importance. Plan G below provides an extract of those records as applied to the Burry ;Port & Pembrey locality. The red star denotes the position of the Alternative Site.
4.1.2 The records reveal that the Site does not include or adjoin any national or local nature conservation designation. The site is some 0.5 kilometres distant from the Special Area of Conservation at Carmarthen Bay.
4.1.3 Any biodiversity assets that may be present at or adjoining the Site have been given full consideration with regards to exploring its potential for residential development. This has included the proposed retention and management of existing boundary tree and hedgerow features. It is envisaged that the entirety of mature trees off the northern and southern boundaries could be retained and managed further for uninterrupted biodiversity gain.
Plan G – Extract from Data Map Wales detailing any known ecological interests
4.1.4 In the wider context, the site does not adjoin or form part of any local or national nature conservation designation. There are a number of areas of established woodland, which are clearly evident on the Google Earth image presented as Plan C above. These will not be affected by development within the Site, as the indicative site layout provides
for enough buffer space to those existing root systems and crown spreads, and can be fully retained in situ, providing continued ecological retention and connectivity.
4.1.5 It is considered that any statutory and non-statutory designations are significantly distant from the site, which will ensure that its development would have no detrimental impact on them.
4.2 HISTORICAL ASSETS
4.2.1 The Site has been assessed for any proximity to known and designated Historic Assets, using the “Cof Cymru – National Historic Assets of Wales” from CADW’s website. An extract from Cof Cymru Assets map for this part of Burry Port is reproduced below as Plan H The red star denotes the position of the Candidate Site.
4.2.2 The Site does not include or form part of any Listed Buildings or proximity to a Conservation Area. There are no Conservation Areas located near the Candidate Site. The proposed development of the Site would not have any detrimental impact on the setting or interest of any nearby historical asset.
Plan H – Extract from Cof Cymru Historic Assets website
4.3 ENVIRONMENTAL CONSTRAINTS
4.3.1 Potential for Risk from Flooding
The Site has been assessed against the Flood Map for Planning, prepared by Natural Resources Wales. An extract from the FMfP map is reproduced below as Plan I, with the site denoted by a red star.
Plan I – Extract from NRW’s Flood Map for Planning
4.3.2 The above plan extract reveals that the field enclosure lies just outside a designated Flood Zone 2, which is located along the former railway line, and to its north.
4.3.3 An examination has also been made of the NRW records relating to potential surface water flooding. Plan I above reveals areas of land in the locality susceptible to such surface water flooding risk. The purple tone denotes the positioning of the Alternative Site and reveals that the site is free from any such constraint.
4.3.4 Any development of the Site would involve engineering works to ensure that their sufficient on-site attenuation of surface water and that the existing boundary drainage ditches are improved and have sufficient capacity to receive surface water from existing and proposed developments.
4.3.5 Past & Present Potential for Ground Contamination and Coal Mining Activity
The Site comprises a large domestic garden. Due to its greenfield nature and domestic use, the rear field of the Candidate Site has no history of known past ground contamination related constraints. Whilst the locality has historically been the subject of coal mining, the records of The Coal Authority have been examined to ascertain any precise mine entries, addits or seams of shallow coal and mine workings. An extract from The Coal Authority interactive mapping base is reproduced as Plan L, with the site identified by a red star.
Plan L – Extract from Coal Authority’s records map for locality
4.3.5 The Coal Authority records reveal that the site is not directly affected by any coal mining legacy, which is concentrated to a seam to the north at the crest of the hillside descending south-eastwards towards Burry Port.

5.0 VVIABILITY IABILITY
5.0.1 As part of the preparation of any development plan, it is vital to ensure that allocations within it are both viable and deliverable. To not make efforts to explore both these aspects inherently poses risks that the Plan may be unsound and so in turn fails to meet its own targets or objectives.
5.0.2 Although detailed viability appraisals are difficult to prepare at this stage of the Plan’s preparation due to the absence of, for example, such things as full engineering details, it is possible to undertake such appraisals at a strategic or in-principle level. The following therefore represents such a process and is fit-for-purpose in providing confidence with regards to both the viability and deliverability of the Candidate Site at this stage. It should be noted that more detailed analysis at a planning application stage may result in some potential variance.
5.1 VIABILITY APPRAISAL
5.1.1 The following provides an indication of the viability of delivering the proposed 18 units on the Site in question. It is based very much on its greenfield status and uses values and costings previously accepted by the Local Authority through its determination of planning applications and other works. The following appraisal is therefore based on the assumptions set out below in order to provide a residual land value for the scheme.
Costs
• Dwelling construction costs are based on an absolute minimum of £1300 per metre given that bespoke four bed detached houses (140 sq.m.), with a medium grade of internal finishing, and formation of accesses to the highway are likely to be the preferred house type. Three bedroomed semi-detached housing of 85 sq.m. is also proposed
• Estate road carriageway costs of £1200 per linear metre
• Connections for all utilities include water, foul water and electric.
• Developer’s Profit based on minimum RICS guidelines (18%)
• Professional Fees include planning application fee, associated professional fees, estate agency fees (1%) and LABC Warranty fee.
Sales Values
• Sale Prices based on LPAs “Affordable Housing” Supplementary Planning Guidance, market research and Welsh Government “Acceptable Cost Guidance” figures where relevant.
5.1.2 Using the above, the following represents a strategic viability appraisal for the proposed 18 units, based on an affordable housing level of 20% which provides for 3 x three-bed dwellinghouses.
Costs
Cost Per Unit/Metre
No. Units/Metres
Total
Four Bed Houses
182,000
8
1,456,000
Three Bed Houses
110,500
10
1,105,000
Estate Road
1200
130
156,000
Utility Connections
5000
18
90,000
Professional Fees
-
-
90,000
Sprinklers
3500
18
63,000
Parks Contribution
2464
18
44,000
Education Contribution
1000
12 children
12,000
Total
3,016,000
Sales
Four Bed (Open M’kt)
295,000
8
2,360,000
Three Bed (Open M’kt)
245,000
7
1,715,000
Three Bed Affordable
91,000
3
273,000
Total
4,348,000
Developers Profit
Total
783,000
Residual Land Value
549,000
Table 2
5.1.3 Based on the above figures, it is considered that in-principle, the development of the site would be financially viable. The residual land value of £549,000 with a net area of 2.2 acres is consistent with evidence gathered over recent years by the District Valuer in examining residential site transactions within Carmarthenshire. The DV discovered land values on completed and on-going sites to be averaging £245,000 per net residential acre of land, based on 2020 values.
5.2 DELIVERABILITY
5.2.1 In terms of deliverability, it should be firstly noted, as illustrated above, that the site is financially and physically viable, with no environmental, geo-physical or technical constraints prohibiting immediate development. Furthermore, there are no ownership or third-party interests preventing the site’s delivery.
5.2.2 In terms of a delivery timescale, with a developer secured, it is envisaged that the site could be capable of being completed within 3 years from the adoption of the replacement Local Development Plan. Burry Port remains an attractive part of the Carmarthen Bay coastline, benefitting from its semi-rural location, but easy access to
Carmarthen and Llanelli by road and rail and the nearby schools, shops, services and community facilities.
5.2.3 The presence of modern, detached houses located near the site at Ashburnham Road is testament to this market need and the desire for home buyers to seek out such forms of modest residential development.

6.0 NATIONAL PLANNING POLICY CONSIDERATIONS
6.1.1 In the preparation of any development plan, consideration must be given to national planning policy and guidance. At present, this takes the form of Planning Policy Wales (Edition 11) and a series of Technical Advice Notes (TAN) that deal with a range of topic areas.
6.1.2 With regards to residential development, or housing, the overarching requirements and principle guidance set by national policy can be found in the PPW, which reads as follows:
“Local planning authorities must ensure that sufficient land is genuinely available or will become available to provide a 5-year supply of land for housing judged against the general objectives and the scale and location of development provided for in the development plan. This means that sites must be free, or readily freed, from planning, physical and ownership constraints, and economically feasible for development, so as to create and support sustainable communities where people want to live. There must be sufficient sites suitable for the full range of housing types.”
6.1.3 At present, Carmarthenshire County Council’s housing supply figure is below the required 5-year level and so it is imperative that this is addressed as quickly as possible to avoid further deterioration of communities and the facilities and services they have to offer. The instigation of the formal Review of the LDP will form part of addressing this issue, but only if truly sustainable and deliverable allocations are identified and allocated, to replace many of the failing sites that currently form part of the Authority’s housing and growth strategy for the County, as set out by the current LDP.
6.1.4 Dealing specifically with the Site subject of this Report, it is evident that its inclusion within the Replacement LDP would adhere to the requirements of PPW in that it is free from any planning, physical or ownership constraint. In addition, as shown at Section 5 of this Statement, the site is also economically viable in deliverability terms.
6.1.5 PPW provides Authorities with more specific guidance in selecting sites for allocation for residential development and in terms of the Candidate Site, it is considered that it satisfies all relevant criteria, including the following:
• The location of the Site is sustainable in terms of its proximity to a range of community facilities, local services and public transport services.
• The physical and social infrastructure of the settlement is capable of accommodating the proposed development without detriment to any interest.
• The Site is not subject to any physical constraint such as ground instability, ecological interest, flood risk, historic assets or contamination, that would prevent its delivery.
• The development of the site for residential purposes would be compatible with existing adjoining land uses, and its form contained by firm, defensible perimeters.
6.1.6 In summary therefore, the allocation of the Site adheres and supports the objective, principles and requirements of national planning policy.

7.0 CONCLUSION
7.1.1 The Site consists of a large, domesticated garden area to a detached house, but lying immediately adjoining an estate of local-authority-built houses, and along Furnace Road which links Gwscwm Road (A484) with Ashburnham Road. The development of the site would mirror development of the eastern flank of the road without the site spilling into the surrounding undeveloped gorse set between Pembrey and Burry Port.
7.1.2 The Site forms a logical extension to the existing settlement, being well related to established residential development off its eastern perimeter; and further development at Bryniltyd. The Site can be found to be capable of being accessed off the existing public road carriageway, via a new junction which benefits from good visibility onto the Furnace Road. The development of the Candidate Site will mirror the existing modern housing arrangement off Bryniltyd.
7.1.3 The precise location is such that the strong defensible boundaries of boundary hedgerows and trees, coupled with adjoining former railway cutting, provide a natural and part physical screen from views within the wider landscape. The development of the site would take place against the backdrop of higher ground to the north and a residential estate to the immediate east. Accordingly, the development of the site would remain more akin in character to the built-up form of Burry Port, than open gorse and shrub to the north and west.
7.1.4 In addition to the above, the site lies within close proximity and walking distance of the existing community services and local facilities of Pembrey and Burry Port, particularly the post office, public houses and Primary School at Ashburnham Road, which will ensure it makes a positive contribution to both national and local sustainable development objectives.
7.1.5 From a wider sense, the Site will also benefit from well served excellent public transport links to the nearby settlements, specifically the towns of Llanelli and Carmarthen, together with other locations within and adjoining the County. In tandem to this, the development of the Site will in turn ensure a deliverable source of future housing for the Local Service Centre in which it lies, which has seen less than half allocated sites being part or fully developed leading to an under supply since the adoption of the current LDP. The development of the Site will help to redress this imbalance and it is strongly suggested that the Authority closely scrutinises those sites currently allocated in the draft LDP in terms of their suitability and deliverability if it is to continue to allocate them. National planning policy however would suggest that in view of the uncertainty in relation to their delivery, such sites should not form part of the replacement LDP. make to the housing land supply.
7.1.6 With the Site having no access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints, its delivery if allocated is assured. Combined therefore with its locational characteristics, the Site in question represents a sustainable Alternative Site for future housing development.
7.1.7 In view of the above and information provided in this Statement, it is respectfully requested that the Alternative Site in question be allocated for a modest residential development.

Include the site within the Plan.

We are instructed by Sauro Homes Limited to a make a formal representation to the
“soundness” of the Second Deposit Draft of the Carmarthenshire Local Development Plan.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/138/023, seeking inclusion of their land for future residential development within the
defined settlement limits of Bancffosfelen within the Replacement Local Development Plan.
The Site off Bro Mebyd comprises an undulating former grazing field which is set south-west
of a recently completed housing development. That site of Bro Mebyd comprises a total of
19 houses and bungalows which benefitted from a full planning permission, referenced
S/32841.

The Candidate Site submission in August 2018 sought to include this first phase of
completed development together with a second phase field within the draft settlement limits
of the Local Development Plan, with an estate road branching off the first phase into the
adjoining field.
We have noted that the first phase of Bro Mebyd as completed continues to be included
within the draft settlement limits of the Second Draft of the LDP as Site SeC11/h2. This
formal Representation relates solely to the unsuccessful part of the Candidate Site.

The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our clients’ submission, reasons why the site was not selected for inclusion within the draft
settlement limits of Bancffosfelen, as contained within the Second Deposit Draft. We note
that the submission successfully passed through Stage 1 (site compatible against the
location of future growth presented in the Preferred Strategy) and Stage 2A (Initial Detailed Site Assessment) of the Council’s site assessment.
It proceeded through a detailed assessment at Stage 2B (further detailed site assessment) and Stage 3 being a Sustainability Appraisal and Habitat Assessment. The reasons for non-inclusion of the south-western field / phase 2 are not given within the Site Assessment merely stating as follows:
“Part of the site to be allocated for residential development. Site reference is SeC11/h2.”

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

Specifically, our clients consider that the draft settlement limits for Bancffosfelen, as defined under Policy SD1 “Settlement Limits”, should be amended to include the land as edged in red upon the extract of the Proposals Map for Bancffosfelen, as reproduced below in Figure 1. The land should be appropriately allocated for housing under Policy HOM1 “Housing Allocations.”

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

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

- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
- Location plan and indicative site layout plan
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits

1.0 Physical Connection to Recently Completed Residential Site

1.1 The Candidate Site relates to part of the former farm holding of Ffynnon Fach. That former farmhouse and associated former farm outbuildings lie to the eastern side of the Candidate Site field. The south-western field lies directly off Bro Mebyd, with the estate road of that new development site able to be extended to allow a new cul-de-sac formation to be formulated.

1.2 The south-western field is undulating and occupies a land area of 1.2 hectares (4.5 acres) and is bounded by a continuous series of linear hedgerows, with occasional trees within that perimeter. It consists of semi-improved grassland, which has been grazed for generations and offers little in terms of biodiversity given its well-manage agricultural status.

1.3 The Candidate Site sought inclusion of the entire holding at Ffynnon Fach, with three additional field enclosures set south of the current south-western field, and south of Ffynnon Fach yard and outbuildings. Those southern fields are no longer sought for inclusion in the Local Development Plan, and the Applicants merely seek the inclusion of one former grazing field as presented upon the indicative site layout plan reproduced below. A total of 37 dwellinghouses can be accommodated over a cul-de-sac layout, with each house equipped with side driveways to provide off-road parking, together with traditional rear garden space.

Figure 2 – Site Layout Plan of Second Phase of Bro Mebyd

1.4 The physical features of the Candidate Site are shown by Google Earth, which has captured the setting and physical form of the site in that the “defensible” boundary at the site is the encirclement of mature hedgerows, with the Ffynnon Fach house and associated yard and outbuildings providing a definitive built development off its eastern and south-eastern flank. Figure 3 below illustrates the current physical form.

Figure 3 - Extract from Google Earth (June 2021) illustrating the recent housing development at Bro Mebyg and Ffynnon Fach buildings to the east of the elongated field

1.5 The above site layout plans illustrate that development will appear as one consolidated form off an established access off Heol-y-Banc (B4306 road), which already has been formed to cater for the additional traffic which would be generated by a second phase. In short, the development of the south-western field provides a logical extension to the settlement of Bancffosfelen, and which is bordered on two flanks by established built development.

2 Overall Housing Supply at Ammanford / Cross Hands with Deposit Draft

2.1 The proposals under this Representation seek the addition of circa 37 residential units to the overall housing supply of the Ammanford / Cross Hands Cluster. Bancffosfelen is categorised as a Service Centre SeC11, which forms part of the Ammanford / Cross Hands Cluster as defined within the draft LDP.
The Ammanford / Cross Hands Cluster aims to provide an additional 1257 residential units over the Plan period to 2033, and thus the addition of an allocated site of 37 units will not lead to an over-supply of dwellinghouses within the Cluster.
Policy HOM1 of the Draft Plan indicates that two sites are allocated for residential development in Bancffosfelen (Figure 4 below). Bro Mebyd’s 19 units have already been completed as SeC11/h2. Figure 5 below illustrates those two sites, with the other site being Llannon Road capable of accommodating only 15 units.

Figure 4 - Extract from Proposlas Map indicating only two sites for housing

Figure 4 – HOM1 allocations in Bancffosfelen

2.3 We have examined and researched sites which have been brought forward as Residential Allocations with the Second Deposit Draft. On behalf of clients in this LDP Cluster, we have made formal Representations seeking the omission of the following draft Allocations:
Site PrC3/h14 - Nantydderwen - for 33 Units.
The land was allocated Carmarthenshire Unitary Development Plan (2006). No progress was made in bringing the site forward, and yet it was allocated within the Local Development Plan in 2014. Consequently, twenty years of Development Plan allocations have elapsed without any signs of delivery of this site. Clearly, there is no historic demand for a site of this scale in this part of the Drefach area. More physically challenging sites, such as Cae Coch, Cae Pound at Cross Hands and Heol-y-Parc at Cefneithin have come forward despite topographic issues and previous ground contamination, and yet still the Council is prepared to allocate the site once again in a new Development Plan. The land is relatively level with immediate access onto the local highway network.
The decision to retain Nantydderwen after a period of 20 years within the LDP is shown to be inconsistent, as does not sit with LDP Procedural Guidance which encourages Local Planning Authorities to only re-allocate sites based upon firm evidence of deliverability.

2.4 Site PrC3/h22 Land at Pant-y-Blodau in Penygroes for 79 units.
The land was allocated Carmarthenshire Unitary Development Plan (2006). The site was carried over and allocated as GA3/h35 in the Adopted 2014 LDP for 90 units. Planning Permission was granted in April 2015, and yet some 8 years later, no work has been undertaken on the site, and the land remains undeveloped. No indication is provided within the Site Assessment Report (January 2023) as to why the Council consider this long-standing allocation to remain in the Plan?

2.5 We submit that the draft allocations at Nantydderwen and Pantyblodau be omitted from the Plan, and that housing allocations be redistributed to modest Candidate Sites, of up to 37 units such as that proposed as a second phase of Bro Mebyd in Bancffosfelen.

2.6 There is clear evidence in the success and roll out of all 19 houses at Bro Mebyd that this site can be delivered and fulfil the housing need in Bancffosfelen. Such modest sites are far more likely to be brought forward and developed in full by regional and small housebuilders given that construction and development costs are more likely to be viable in relation to house sales and the general housing market in this part of Carmarthenshire.

2.7 In the case of Bro Mebyd its completion is a strong indicator of a healthy property market at Bancffosfelen. Consequently, it is a location where housing proposals are deliverable, assisting to meet housing needs in this part of the Ammanford / Cross Hands Cluster.
In conclusion, this Representation to the Deposit Draft of the Revised LDP has sought to examine the Council’s reasons for non-inclusion of a Candidate Site.
Our clients have illustrated that their indicative proposals to construct circa 37 dwellinghouses. The locality has numerous examples of modern cul-de-sac development being completed at backland locations, which in turn, advocates that the form of
development proposed at Bro Mebyd is no different, resulting in it being respectful to the character and setting of the locality.

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

Amend Plan to include site

INTRODUCTION
1.1 Evans Banks Planning has been instructed by Mr. Kevin Green (the Landowner) to prepare and submit a Alternative Site Supporting Statement for the allocation of land off Gwscwm Road, Burry Port for the purposes of residential development in the Replacement Carmarthenshire Local Development Plan.
1.2 This Statement has been prepared in line with the Authority’s published documents entitled Revised Carmarthenshire Local Development Plan: Guidance Note and Revised Carmarthenshire Local Development Plan: Candidate Site Assessment Methodology. The contents of this Statement therefore address the set criteria, determining issues and each qualifying point raised within these documents
Consideration has also been given to ensuring that this formal submission complies with the guidance and requirements of Planning Policy Wales (Edition 11), in relation to the preparation of development plans and the allocation of land for residential purposes as part of that preparation process.
1.3 The contents of this Statement therefore provide a comprehensive case for the allocation of the land for residential development purposes and it should also be read in conjunction with the accompanying supporting information and indicative site layout plan.
1.4 Our client made a Candidate Site submission in August 2018, which the Council referenced as SR/016/005 which proposed a portion of a sloping field set off the northern rear of residential properties fronting Gwscwm Road to be allocated for residential purposes in the Local Development Plan.
We have noted the Council’s response to that submission in their Site Assessment Table (January 2023) which indicated that the which provides details of the Council’s analysis of each received Candidate Site submission, and reasons why the site was not selected for inclusion within the draft settlement limits of Burry Port, as contained within the Second Deposit Draft. We note that the submission successfully passed through Stage 1 (site compatible against the location of future growth presented in the Preferred Strategy) and Stage 2A (Initial Detailed Site Assessment) of the Council’s site assessment.
However, it was rejected at Stage 2B (further detailed site assessment), with reasons for non-inclusion reported as follows:
“Development would lead to an unnecessary encroachment beyond the development limits. The site is elevated and prominent on the landscape. The Site will remain outside the development limits. It is unclear if the site has an available access point with adequate visibility.”
This Report seeks to address the issues raised and provide justification and solutions.

2
2.0.0 SSITE ITE CCONTEXTONTEXT
2.1 THE SITE
2.1.1 The Alternative Site relates to part of a sloping semi-improved grazing enclosure which lies off the rear garden perimeters of individual houses which front the northern flank of Gwscwm Road in Burry Port. The land extends to several acres of pasture which rise in ground profile to The Graig, a single width minor road which lies several hundred metres north at a much-elevated position over the town.
2.1.2 The southern boundary of the site lies parallel with the rear boundaries of a total of 15 bungalows and houses at Gwscwm Road, which are all set at a partially elevated position above the highway carriageway, with vehicle parking to the side curtilages. Traditional garden spaces have been formed to the rear, with the majority of common boundary comprised of post and rail fencing, together with sections of manage hedgerow.
2.1.3 The western perimeters of the site fall against a copse of woodland which is also accessed off an unmade access lane off Gwscwm Road, being set between residential properties. That track runs north-west to access at backland property, known as 71A Gwscwm Road, and onto adjoining farmland, whilst an agricultural gate is found along the track side providing access to the Alternative Site.
2.1.4 The Alternative Site relates to some 0.9 hectares (2.15 acres) of managed pasture, which is subject to a silage crop cut once a year, and occasional grazing. The site extends across a common boundary length of some 250 metres, with the lower field portion extending back, under this submission to a depth of some 45 metres. The northern, majority of grazing field will be allowed to continue in its current form.
2.1.5 This part of Burry Port is characterised by modern housing, mostly of 1960s and 70s origin and individual properties constructed over a variety of different styles and forms.
Gwscwm Road forms part of the A484 road, being the main arterial highway running east to west through Burry Port from Pwll and Pembrey. The road is considerably wide, easily allowing continued passage for two-way traffic. Public footways are to be found off both flanks, with street lighting at consistent intervals.
2.1.6 The Site field parcel is identified by being edged in red on the plans below. Plan A illustrates their wider position with the settlement of Burry Port. Plan B provides a detailed Ordnance Survey map extract with the site perimeters identified.
Plan A – wider view of Gwscwm Road setting
Plan B – detailed Ordnance Survey location plan of site
2.1.7 The Candidate Site development will form a mirrored extension to the Gwscwm Road frontage properties, appearing as a row of new dwellings set back to provide an abundance of habitable spatial relief to the rear elevations and gardens of those established properties, whilst also allowing for each new dwelling to be afforded off-road car parking and traditional rear garden space.
Plan C below provides a Google Earth image of the site and its surroundings, in which the above physical features are readily apparent.
Plan C – Google Earth – April 2021
2.1.8 The Candidate Site’s well-defined perimeters and immediate proximity to the adjacent established residential properties off the Gwscwm Road highway, are shown within the photographs below. The photos also depict the existing boundary fence separating grazing fields and Gwscwm Road properties’ rear gardens with the Candidate Site.
Photograph 1 – view of Candidate Site with existing dwelling set below in ground levels with wooded copse of far side of access track
Site
Photograph 2 – view from Gwscwm Road carriageway looking at existing access track
Photograph 3 – view of properties on northern flank of Gwscwm Road
Photograph 4 – view of site from higher ground at The Graig with adjacent established properties fronting Gwscwm Road
2.2 SETTLEMENT SUSTAINABILITY AND SITE SETTING WITHIN CURRENT LOCAL DEVELOPMENT PLAN
2.2.1 Under the provisions of the current Carmarthenshire Local Development Plan, the site off Gwscwm Road falls adjoining the Development Limits for the settlement of Burry Port. The Alternative site is edged in red on the map extract.
Plan D – Extract from Adopted LDP Proposals Map of Burry Port (2014)
2.2.2 As can be seen, the Candidate Site adjoins and is well related to the existing defined Development Limits for Burry Port, and also within walking distance of the town centre.
Within the Second Draft of the Deposit LDP for the Plan Period 2018-2033, the settlement limits of this part of Burry Port remain unchanged, as shown in Plan E below.
Plan E – Second Draft of Proposals Map (2023) at Gwscwm Road
2.2.3 A notable change in the adopted and emerging LDP Plans is that land to the east at “Bay View, The Graig” allocated in the 2014 adopted plan as T2/1/h4 is no longer allocated in the new Replacement LDP. The site did not come forward for development in the last 8 years, and therefore it has been decided to remove the allocation BUT retain the land within defined settlement limits. It nevertheless demonstrates that the Council will consider development upon the mid-hillslopes between the frontage housing on Gwscwm Road and properties set at an elevated higher level at The Graig.
2.2.4 Housing Land Availability in Burry Port
It is clear that proposed residential land opportunities in Burry Port have been rationalised since the current LDP was adopted in 2014. The Second Deposit Draft itemises at Policy HOM1 that only three sites are allocated for residential development, and two of those are substantially if not totally complete.
The site at Goodig for 105 units is complete, apart from 8 units off its eastern perimeter, which are in process of being finalised. At Glanmor Terrace, a total of 32 affordable units have been largely completed adjacent to the main railway line.
In terms of the remaining allocation at Harbourside, the site is allocated for 364 units, yet despite being granted outline planning permission, which has since expired and been renewed, there remains no active housebuilder interested in acquiring the site, and it must be accordingly questioned as to the deliverability of tis brownfield site. Being brownfield the site is susceptible to the need for wholesale remediation which will inevitably lead to increased build costs, undermining its progress.
2.2.5 Conversely, the Alternative Site’s position and proposed use therefore continues to represent a natural and logical location for the settlement’s expansion in the context of adjoining established and proposed residential development.
As detailed above, the Candidate Site adjoins and in effect lies within the existing settlement and form of Burry Port. The existing built form and pattern of the settlement follows key access routes, such as the A484 Gwscwm Road and Lando Road, to the north and Ashburnham Road. The established town centre at Station Road extends off Ashburnham Road, with multiple cul-de-sac modern developments concentrated to the mid-hillslopes to the north of the A484 road, or south to the main railway line extending west to east from Burry Port to Kidwelly.
Burry Port is particularly popular to new homeowners due to its coastal position, and short drive to Llanelli, and in particular the A484 link to Carmarthen.
2.2.6 In terms of the Candidate Site is located within easy walking and driving distance of all community facilities and local services present and provided within the settlement of Burry Port. Access to further facilities in the towns of Llanelli and Carmarthen can then be gained by regular bus services, stops for which are located near the site access at Gwscwm Road.
The sustainable position of Burry Port should therefore be given full consideration when considering potential future growth options.
2.3 Settlement Facilities
2.3.1 The Site at Gwscwm Road lies some 10 minutes’ walk from the centre of the town at Station Road.
Public bus stops lie immediately near the site’s access with the Gwscwm Road carriageway.
Main public bus services call at these bus stops, in particular:
- Service 111 – Kidwelly to Swansea, calling at Pembrey, Burry Port, Llanelli, Trostre, Gorseinon, and Fforestfach
- Service X11 – Carmarthen to Swansea, calling at Ferryside, Burry Port, Llanelli, Trostre and Fforestfach retail parks
2.3.2 The site at Gwscwm Road is within 10 minutes’ walk, to the London Paddington to Fishguard / Pembroke Dock rail service at Burry Port station.
2.3.3 The Site lies within a 5-minute walking distance of Burry Port Primary school at Elkington Park. Ysgol Y Strade and Burry Port Secondary Schools are located at Llanelli and Burry Port respectively, with pupil bus transport available to Ysgol-y-Strade. The CCTA campuses at Llanelli and Carmarthen are also available via student bus services.
2.3.4 Burry Port town centre provides a range of small comparison shops, supermarket, petrol filling station, public houses / cafes, offices, rail station and industrial estates.
Plan F below provides an indication of the proximity of the site to Burry Port town centre, with its rail station and strategic road network to Llanelli and Carmarthen.
The red star denotes the position of the Alternative Site.
Plan F – proximity of Alternative Site to Burry Port town centre
Primary School
Suoermarket and town centre
Rail Station
A484 Road to Llanelli and Carmarthen

3.0 THE PROPOSAL
3.0.1 As part of the requirements for the promotion of sites for residential development, this Statement is accompanied by an indicative layout for a potential residential scheme that could be developed on the site. It should be emphasised that the accompanying layout is for illustrative purposes and that other design solutions for the site could also be reached. Notwithstanding this, the accompanying layout drawing has taken account of all the potential assets and constraints of the site and demonstrates that it is capable of delivering 15 bungalows in a deliverable and sustainable manner. The following information therefore expands on this principle.
3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Candidate Site be allocated in the replacement LDP for the purposes of a total of 15 residential units. As detailed above, the accompanying illustrative layout (reproduced below at Plan G) demonstrates that the site is capable of accommodating this number in a deliverable and sustainable manner.
Site layout plan - Plan G
3.1.2 As illustrated above, the site is capable of accommodating detached and semi-detached, single-storey bungalows to replicate and being reflective of the existing form and density of residential properties fronting Gwscwm Road.
3.1.3 With regards to access, it is proposed that the Candidate Site would be served by a 6.0 metres wide radii junction onto Gwscwm Road, improving the existing access
arrangements. This stretch of Gwscwm Road experiences vehicle speeds which are respectful of the 30mph speed limit. Visibility splays of 2.4m x 43m can be achieved within this built-up locality by virtue of the wide existing pavement along this northern flank of the highway. A priority system can be developed allowing vehicles entering the site to have priority over vehicles exiting. Within the site, a carriageway of 5.5 metres width with 1.8 metres wide footway can be created.
3.1.4 The Alternative Site proposals are able to fully retain all existing boundary treatments, being the established mature hedgerows across the western and eastern sides of the field, which would be retained and managed wherever possible.
3.1.5 Although due to the proximity of existing facilities in Burry Port, the proposal does not include any formal areas of play or open space. It is recognised and supported that an element of the proposed units could be Affordable in nature, or contributions made to support affordable housing elsewhere in the Llanelli locality, which under the provisions of the current LDP would be in the region of 20% of the total number of dwellinghouses.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Development of the Candidate Site for residential units would be served by mains water, gas, public sewer and electricity connections, which either lie within the respective stretch of Gwscwm Road carriageway.
3.2.2 The estate road highway itself is equipped with roadside gullies and drainage which aid to discharge run-off from the carriageway. The proposed access to the site could connect to the existing highways drainage.
3.2.3 The Candidate Site comprises of semi-improved grassland. There are no areas of significant marshy grassland or water-logging evident, and therefore at first inspection, it appears that the site benefits from good ground percolation of rainwater.
3.2.4 Soakaways would be the most sustainable means of disposing of surface water from individual properties. If required, attenuation measures can be deployed on site to control surface water run-off during extreme storm events, which could also allow for additional capacity, making allowances for climate change. The field enclosures are served by a series of drainage ditches along the fields boundaries, which eventually combine and inter-connect discharging surface water which eventually discharge to the Estuary. It is considered that as a result of on-site features, there would be a number of options available to a future development of the site in terms of surface water disposal.

4.0 EENVIRONMENTAL NVIRONMENTAL CCONSIDERATIONSONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 The Site has been assessed against data held on the “Data MAP Wales” website, which details statutory and non-statutory National and Local sites of ecological importance. Plan H below provides an extract of those records as applied to the Burry Port locality. The red star denotes the position of the Candidate Site.
4.1.2 The records reveal that the Candidate Site does not include or adjoin any national or local nature conservation designation. The site is some 0.5 kilometres distant from the Special Area of Conservation at Carmarthen Bay.
4.1.3 Any biodiversity assets that may be present at or adjoining the Candidate Site have been given full consideration with regards to exploring its potential for residential development. This has included the proposed retention and management of existing boundary tree and hedgerow features. It is envisaged that the entirety of mature trees off the western and eastern boundaries could be retained and managed further for uninterrupted biodiversity gain.
Plan H – Extract from Data Map Wales detailing any known ecological interests
4.1.4 In the wider context, the site does not adjoin or form part of any local or national nature conservation designation. There are a number of areas of established woodland, which are clearly evident on the Google Earth image presented as Plan C above. These will not be affected by development within the Candidate Site, as the indicative site layout provides for sufficient buffer space to those existing root systems and crown spreads,
and can be fully retained in situ, providing continued ecological retention and connectivity.
4.1.5 It is considered that any statutory and non-statutory designations are significantly distant from the site, which will ensure that its development would have no detrimental impact on them.
4.2 HISTORICAL ASSETS
4.2.1 The Alternative Site has been assessed for any proximity to known and designated Historic Assets, using the “Cof Cymru – National Historic Assets of Wales” from CADW’s website. An extract from Cof Cymru Assets map for this part of Burry Port is reproduced below as Plan I The red star denotes the position of the Candidate Site.
4.2.2 The Candidate Site does not include or form part of any Listed Buildings or proximity to a Conservation Area. There are no Conservation Areas located near the Candidate Site. The proposed development of the Site would not have any detrimental impact on the setting or interest of any nearby historical asset.
Plan I – Extract from Cof Cymru Historic Assets website
4.3 ENVIRONMENTAL CONSTRAINTS
4.3.1 Potential for Risk from Flooding
The Candidate Site has been assessed against the Development Advice Maps, prepared by Natural Resources Wales, and “Flood Map for Flooding.” An extract from the FPfP map is reproduced below as Plan J, with the site denoted by a red star.
Plan J – Extract from NRW’s Flood Map for Planning
4.3.2 The above plan extract reveals that the field enclosure lies just outside any designated flood zone. An examination has also been made of the NRW records relating to potential surface water flooding. Plan J also indicates areas of land in the locality susceptible to such surface water flooding risk, which are denoted by purple tone.
4.3.3 Any development of the Candidate Site would involve engineering works to ensure that there sufficient on-site attenuation of surface water and that the existing boundary drainage ditches are improved and have sufficient capacity to receive surface water from existing and proposed developments.
4.3.4 Past & Present Potential for Ground Contamination and Coal Mining Activity
The Candidate Site comprises agricultural pasture. Due to its greenfield nature and domestic use, the rear field of the Candidate Site has no history of known past ground contamination related constraints. Whilst the locality has historically been the subject of coal mining, the records of The Coal Authority have been examined to ascertain any precise mine entries, addits or seams of shallow coal and mine workings. An extract from The Coal Authority interactive mapping base is reproduced as Plan K, with the site identified by a red star.
Plan K – Extract from Coal Authority’s records map for locality
4.3.5 The Coal Authority records reveal that the site is not directly affected by any coal mining legacy, which is concentrated to a seam skirting Gwscwm Road and extending south. There are no mine entries recorded upon the Alternative Site.

5.0 VVIABILITY IABILITY
5.0.1 As part of the preparation of any development plan, it is vital to ensure that allocations within it are both viable and deliverable. To not make efforts to explore both these aspects inherently poses risks that the Plan may be unsound and so in turn fails to meet its own targets or objectives.
5.0.2 Although detailed viability appraisals are difficult to prepare at this stage of the Plan’s preparation due to the absence of, for example, such things as full engineering details, it is possible to undertake such appraisals at a strategic or in-principle level. The following therefore represents such a process and is fit-for-purpose in providing confidence with regards to both the viability and deliverability of the Candidate Site at this stage. It should be noted that more detailed analysis at a planning application stage may result in some potential variance.
5.1 VIABILITY APPRAISAL
5.1.1 The following provides an indication of the viability of delivering the proposed 18 units on the Candidate Site in question. It is based very much on its greenfield status and uses values and costings previously accepted by the Local Authority through its determination of planning applications and other works. The following appraisal is therefore based on the assumptions set out below in order to provide a residual land value for the scheme.
Costs
• Dwelling construction costs are based on an absolute minimum of £1300 per metre given that bespoke four bed detached bungalows (130 sq.m.), with a medium grade of internal finishing, and formation of accesses to the highway are likely to be the preferred house type. Three bedroomed semi-detached bungalows of 80 sq.m. is also proposed
• Estate road carriageway costs of £1200 per linear metre
• Connections for all utilities include water, foul water and electric.
• Developer’s Profit based on minimum RICS guidelines (18%)
• Professional Fees include planning application fee, associated professional fees, estate agency fees (1%) and LABC Warranty fee.
Sales Values
• Sale Prices based on LPAs “Affordable Housing” Supplementary Planning Guidance, market research and Welsh Government “Acceptable Cost Guidance” figures where relevant.
5.1.2 Using the above, the following represents a strategic viability appraisal for the proposed 18 units, based on an affordable housing level of 20% which provides for 3 x three-bed dwellinghouses.
Costs
Cost Per Unit/Metre
No. Units/Metres
Total
Four Bed Bungalows
169,000
11
1,859,000
Two Bed Bungalows
104,000
4
416,000
Estate Road
1200
230
276,000
Utility Connections
5000
15
75,000
Professional Fees
-
-
90,000
Sprinklers
3500
15
52,000
Parks Contribution
2464
15
37,000
Education Contribution
1000
10 children
10,000
Total
2,815,000
Sales
Four Bed (Open M’kt)
340,000
11
3,740,000
Two Bed (Open M’kt)
195,000
1
195,000
Three Bed Affordable
78,000
3
234,000
Total
4,169,000
Developers Profit
Total
750,000
Residual Land Value
604,000
Table 2
5.1.3 Based on the above figures, it is considered that in-principle, the development of the site would be financially viable. The residual land value of £604,000 with a net area of 2.2 acres is consistent with evidence gathered over recent years by the District Valuer in examining residential site transactions within Carmarthenshire. The DV discovered land values on completed and on-going sites to be averaging £245,000 per net residential acre of land, based on 2019 values.
5.2 DELIVERABILITY
5.2.1 In terms of deliverability, it should be firstly noted, as illustrated above, that the site is financially and physically viable, with no environmental, geo-physical or technical constraints prohibiting immediate development. Furthermore, there are no ownership or third-party interests preventing the site’s delivery.
5.2.2 In terms of a delivery timescale, with a developer secured, it is envisaged that the site could be capable of being completed within 3 years from the adoption of the replacement Local Development Plan. Burry Port remains an attractive part of the Carmarthen Bay coastline, benefitting from its semi-rural location, but easy access to Carmarthen and Llanelli by road and rail and the nearby schools, shops, services and community facilities.
5.2.3 The presence of modern, detached houses located near the site at Ashburnham Road is testament to this market need and the desire for home buyers to seek out such forms of modest residential development.

6.0 NATIONAL PLANNING POLICY CONSIDERATIONS
6.1.1 In the preparation of any development plan, consideration must be given to national planning policy and guidance. At present, this takes the form of Planning Policy Wales (Edition 11) and a series of Technical Advice Notes (TAN) that deal with a range of topic areas.
6.1.2 With regards to residential development, or housing, the overarching requirements and principle guidance set by national policy, which reads as follows:
“Local planning authorities must ensure that sufficient land is genuinely available or will become available to provide a 5-year supply of land for housing judged against the general objectives and the scale and location of development provided for in the development plan. This means that sites must be free, or readily freed, from planning, physical and ownership constraints, and economically feasible for development, so as to create and support sustainable communities where people want to live. There must be sufficient sites suitable for the full range of housing types.”
6.1.3 At present, Carmarthenshire County Council’s housing supply figure is below the required 5-year level and so it is imperative that this is addressed as quickly as possible to avoid further deterioration of communities and the facilities and services they have to offer. The instigation of the formal Review of the LDP will form part of addressing this issue, but only if truly sustainable and deliverable allocations are identified and allocated, to replace many of the failing sites that currently form part of the Authority’s housing and growth strategy for the County, as set out by the current LDP.
6.1.4 Dealing specifically with the Candidate Site subject of this Report, it is evident that its inclusion within the Replacement LDP would adhere to the requirements of PPW in that it is free from any planning, physical or ownership constraint. In addition, as shown at Section 5 of this Statement, the site is also economically viable in deliverability terms.
Alternative Site Supporting Statement March 2023
Land off Gwscwm Road., Burry Port Mr. K. Green
20
6.1.5 PPW provides Authorities with more specific guidance in selecting sites for allocation for residential development and in terms of the Candidate Site, it is considered that it satisfies all relevant criteria, including the following:
• The location of the Candidate Site is sustainable in terms of its proximity to a range of community facilities, local services and public transport services.
• The physical and social infrastructure of the settlement is capable of accommodating the proposed development without detriment to any interest.
• The Candidate Site is not subject to any physical constraint such as ground instability, ecological interest, flood risk, historic assets or contamination, that would prevent its delivery.
• The development of the site for residential purposes would be compatible with existing adjoining land uses, and its form contained by firm, defensible perimeters.
6.1.6 In summary therefore, the allocation of the Candidate Site adheres and supports the objective, principles and requirements of national planning policy.

7.0 CONCLUSION
7.1.1 The Alternative Site consists of the lowest section of a semi-improved grazing field, which falls against the rear of residential properties fronting Gwscwm Road (A484). The development of the site would form a parallel development of the northern flank of that road, with a new cul-de-sac carriageway formed through widening and improvements to an existing access track. That access track already provides access to the land and a residential property at No. 71A Gwscwm Road.
7.1.2 The Alternative Site forms a logical extension to the existing settlement, being well related to established residential development off its southern perimeter; and further development to the east upon The Graig. The Site can be found to be capable of being accessed off the existing public road carriageway, via an improved junction which benefits from good visibility onto the Gwscwm Road.
7.1.3 The precise location is such that the strong defensible boundaries of boundary hedgerows and trees off the western and eastern perimeters provide a natural and part physical screen from views within the wider landscape. The development of the site would take place against the backdrop of higher ground to the north and residential properties to the immediate foreground. Accordingly, the development of the site would remain more akin in character to the built-up form of Burry Port, than open gorse and shrub to the north and north-west.
7.1.4 In addition to the above, the site lies within close proximity and walking distance of the existing community services and local facilities of Burry Port, particularly convenience shops, supermarket, convenience shops, public houses, rail station and Primary and Secondary Schools, which will ensure it makes a positive contribution to both national and local sustainable development objectives.
7.1.5 With the Candidate Site having no access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints, its delivery if allocated is assured. Combined therefore with its locational characteristics, the Site in question represents a sustainable candidate for future housing development.
7.1.6 In view of the above and information provided in this Statement, it is respectfully requested that the Candidate Site in question be allocated for a modest residential development.

Include Candidate Site reference SR/116/006 as a HOM1 allocation within the Plan.

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

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/0116/006, seeking the inclusion of their land within the development limits of
Mynyddygarreg as part of the Replacement Local Development Plan.

The Candidate Site comprises an irregular-shaped grazing paddock set off the western flank
of Llangadog Road that runs north to south from the centre of the village of Mynyddygarreg.
The proposals seek inclusion of the well-defined enclosure to provide a modest development
of detached and semi-detached houses to complement established properties which lie
directly alongside the road off the eastern flank of the road. It therefore represented a logical
opportunity for infilling within the settlement and providing a much-need and deliverable
residential opportunity which can generate 11 dwellings. Its extents are illustrated by the site
edged in red, being a site location plan, at Figure 1 below.

The Council published a First Deposit Draft of the Replacement Local Development Plan in
January 2020. At that time, the Council revealed its analysis of each submitted Candidate
Site within a “Site Assessment Table” (January 2020) We noted at that time that our Clients
land was considered as part of this process and as a result the Authority concluded that the
site had successfully passed through all four Assessment Stages, being Stage 1 (site
compatible against the location of future growth presented in the Preferred Strategy), Stage
2A (Initial Detailed Site Assessment), Stage 2b (Further Detailed Site Assessment) and
Stage 3 (Sustainability Appraisal and Habitat Regulation Assessment) of the Council’s site
assessment. Accordingly at Stage 4 the Council reported “Site to be allocated within the
revised LDP reference SuV22/h3”
Figure 1 – Location plan of Candidate Site at Mynyddygarreg
As a result of the above Council assessment, Figure 2 presents an extract of the First Deposit LDP Proposals Map for Mynyddygarreg, which clearly identified part of our clients’ land as within the defined development limits and allocated for Residential Development.
Figure 2 – Extract of Proposals Map for Mynyddygarreg with site included within settlement limits as shown by a red arrow

Our clients are therefore astonished to discover that upon publication of the Second Deposit Draft of the LDP, the Council have sought to amend the draft settlement limits, to exclude all the field frontage from within the proposed settlement limits. That new Draft Plan for this southern part of Mynyddygarreg is reproduced as Figure 3 below.
A new Site Assessment Table, dated January 2023, now indicates that the Council conclude that “The site includes High Grade Agricultural Land (Grade 2), whilst there are other opportunities to develop within the village.”
Figure 3 – Second Deposit Draft extract of Mynyddygarreg limits at Llangadog Road

Our clients consider the LDP is “unsound” and should be changed, as it fails to meet the tests for “soundness”, in that the Plan “is not appropriate”, and “will not deliver”, as defined by the Planning Inspectorate’s LDP Examinations Procedural Guidance.
Specifically, our clients consider that the draft settlement limits for Mynyddygarreg, as defined under Policy SD1 “Settlement Limits”, should be amended to include the land as edged in red upon the extract of the Proposals Map for Mynyddygarreg, as reproduced below in Figure 4. The land should be appropriately allocated for housing under Policy HOM1 “Housing Allocations.”
Figure 4 – Extent of Representation Site edged in red
This formal representation letter supplements the following documents which comprise a complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits

1.0 Overall Housing Supply at Mynyddygarreg and Cluster 2 within Deposit Draft

1.1 The Council consider that there are two reasons for the Candidate Site at Llangadog Road as not being included within the draft Plan as a Residential Allocation. One reason is that they believe that there are sufficient residential sites allocated elsewhere in the settlement. The second reason relates to the grading of agricultural land and that the Council now there years later from assessing and presenting matters in a First Deposit Draft, consider that constructing residential properties Grade 2 Agricultural Land in Mynyddygarreg is unacceptable? We will respond to that reason in the Section 3 of this Representation.

1.2 On this basis, it must be accepted that the form of the Candidate Site set as an infill opportunity between established properties which front the minor road running through this part of Mynyddygarreg, together with the proposals to create new vehicular accesses onto Llangadog Road is deemed acceptable, and in accord with the spatial form and character of the settlement.

1.3 The proposals under this Representation merely seek the addition of 11 residential units to the overall housing supply of Mynyddygarreg, which is regarded as a Tier 3 Sustainable Village, identified within the Llanelli within the draft LDP. Figure 5 below provides an extract of the indicative site layout plan for this Representation site. The proposals can provide a mix of 3 and 4 bed detached and semi-detached dwellinghouses all fronting the Llangadog Road frontage and allowing a safe buffer zone from the rear elevations of the proposed dwellings to an existing Welsh Water sewer apparatus that transverses the field enclosure.
Figure 5 – Proposed Indicative Site Layout Plan for Representation Site

1.4 The Llanelli Cluster (Cluster 2) aims to provide an additional 3039 residential units over the Plan period to 2033, with Mynyddygarreg (Settlement SuV22) providing two allocated sites at expected to provide a combined total of 31 units to that overall Cluster total (reproduced at Figure 6 below). We would submit in the first instance that the addition of an additional allocated site of 11 units will not lead to an over-supply of dwellinghouses within the Cluster, nor the defined Mynyddygarreg settlement supply.
Figure 6 – Extract from Policy HOM1 for Mynyddygarreg

1.5 We have examined and researched sites which have been brought forward as Residential Allocations with the Deposit Draft. In Mynyddygarreg, we consider reference should be made to the current adopted (2014) Local Development Plan to enable a comparison to be made as to the Council’s aspirations for the future growth of housing in that settlement. Great emphasis within the Draft Plan has been placed upon the continued allocation of the Gwenllian Gardens housing site, which was allocated from the 2008-21 Local Development Plan. The above table indicates that
the Council expect that site to be delivered to the market between LDP years 1-5 and 6-10, being 2018 to 2028. Indeed, construction works are at an advance stage on the site and we consider that it is reasonable to continue the allocation of this site.

1.6 However, we note that in the case of the other proposed allocation at “Land adjacent to Ty Newydd, Meinciau Road,” it is a new allocation having appeared as outside settlement limits in the 2014-adopted LDP, as reproduced at Figure 7 below.
Figure 7 - Extract of Current LDP Proposal Map for Mynyddygarreg
and Residential Allocations for Period 2008-21

1.7 The current Development Plan Map for Mynyddygarreg reveals the success of residential allocations in the village. Sites SC17/h1, h2 and h3 have all been completed, and site SC17/h4 is the Gwenllian Gardens site, which as referred to above, is under construction.

1.8 The draft allocation of “Land adjacent to Ty Newydd at Meinciau Road” for 8 dwellings is a new allocation in the Replacement LDP. We note that it was included in the First Consultation Draft in 2020, along with our client’s site at Llangadog Road as new allocations. It is immediately apparent that whilst Meinciau Road has been retained in the Second Draft Plan, our client’s draft allocation at Llangadog Road has been sacrificed. One of the grounds relates to our client’s land being classified as High-Grade Agricultural Land, but we have discovered that the Meinciau Road site is also classified under such a similar designation, and yet it remains in the Second Draft Plan.

1.9 We understand that the Meinciau Road site is under the ownership of Kidwelly Town Council, and yet no explanation has been given as to how that Candidate Site being brought forward by a non-private body is being preferred to a private individual’s Candidate Site which clearly through the absence of any regulatory controls is able to offer his allocated site to the market is a far more streamlined and practical manner.

2.0 Llanelli, Burry Port, Kidwelly and remainder of Cluster 2

2.1 We have examined and researched sites which have been brought forward as Residential Allocations with the Deposit Draft. Mynyddygarreg falls under the Llanelli Cluster which extends along the Burry Estuary coast from Kidwelly in the west to Bynea in the east, and north to Llangennech and Hendy about the M4 corridor.
Great emphasis within the Draft Plan has been placed upon the continued allocation of proposed housing sites still left allocated from the 2014-21 Local Development Plan. Figure 8 below provides an extract of such sites.
Figure 8 – Selection of Deposit Draft Housing Schedule in Llanelli Cluster

2.2 We note that within the Proposals Map for Burry Port, it included for three sites, two of which have been completed at Goodig and Glanmor Terrace leaving just one proposed site, which being the Harbourside site for 364 dwellings. The site has been marketed by the County Council for many years, and despite its coastal position, has failed to receive firm interest and any form of detailed planning application. Ground conditions require extensive remediation of former historic uses.

2.3 The Llanelli suburbs of Llwynhendy / Cefncaeau and Dafen, where four of the above allocations are identified, has not altered since the 2014 adopted LDP and remain undeveloped but re-allocated in the Deposit Draft.
Cwm-y-Nant (PrC2/h22) and Dafen East Gateway (h/23) were both sites allocated within the Carmarthenshire Unitary Development Plan (2006) and as mentioned above, within the Local Development Plan (2014) as sites GA2/h27 and h/30 & h/31.
They have a combined total of 352 dwellings, although neither site has been the subject of any detailed planning application, let alone market interest.
The locality is riddled with historic coal mining activity, with low lying coal seams, together with multiple mine entries across all Dafen sites. Clearly, any residential development upon either site will have to overcome ground remediation to stabilise the ground for residential foundations. The abnormal costs of which are likely to be significant, and hence present the development costs as leading to unviable and undeliverable sites.

2.4 Beech Grove at Pwll (PrC2/h1) has remained allocated for 10 units for the last 10 years in Development Plans. No application for planning permission has even been lodged at the site.

2.5 Cae Linda in Trimsaran (SeC8/h2) for 20 units has been in Development Plans stretching back to the Llanelli Borough Local Plan in 1995. It has only been developed with 5 houses, and thus its continued allocation for twenty more units in the draft LDP must surely come under question?

2.6 Consequently, at least twenty years of Development Plan allocations have elapsed without any signs of wholesale delivery of these sites. Clearly, there is no historic demand for sites of these scales in parts of the Llanelli, Trimsaran and Burry Port / Pembrey areas. All are certainly physically challenging sites, many of which have historic industrial or coal mining legacy issues, which may require significant abnormal costs to achieve developable areas for residential use.
We submit that the above draft allocations be omitted from the Plan, and that housing allocation be redistributed to Alternative Sites, of circa 10 units such as that proposed at Llangadog Road in Mynyddygarreg. There is clear evidence that such modestly sized sites are far more likely to be brought forward and developed in full by regional and local housebuilders given that construction and development costs are more likely to be viable in relation to house sales and the general housing market in this part of Carmarthenshire.

3.0 Alleged Loss of Grade 2 Agricultural Land

3.1 The Council originally included the Candidate Site at Llangadog Road as a new Residential Allocation in the 2020 First Deposit Draft. They now have concluded that the development of the site should not proceed forward as the land is classified as Grade 2 High Grade Agricultural Land. We have researched such a land classification using Welsh Government’s “Data Map Wales” service, and the map extract for this part of Mynyddygarreg is reproduced below as Figure 9, with the Candidate Site highlighted by a red arrow.
Figure 9 – Data Map Wales Agricultural Land Classification at Llangadog Road

3.2 It is noted that Grade 2 “High Grade” agricultural land is coloured a light blue colour, however, the accuracy of the map base and therefore whole premise of identifying such classifications must be called into question as the Grade 2 tone includes a modern housing site located directly opposite the Candidate Site. That site was previously brownfield land, being the site of the Optical Factory at Mynyddygarreg, and thus never formerly agricultural land of high substance?

3.3 We also note that the classification of land as Grade 2 Agricultural Land has not prevented the Council from allocating land for future residential development in this Replacement and former LDPs. Indeed some of those sites have been developed, one locally by the Council itself, and one now has the benefit of planning permission. Figures 10 and 11 below illustrate three such examples at Pembrey and Hendy.
Figure 10 below illustrates that allocated site SeC5/h1 at Garreglwyd in Pembrey for 14 units has been developed by the Council on Grade 2 Agricultural Land. Planning permission has now been granted at Awel-y-Mynydd at Pembrey (SeC5/h2) for 100 units.
Figure 11 below illustrates that Allocated Site SeC6/h1 at Llwyngwern at Hendy is allocated for 20 units.
Figure 10 – DMW extract for Pembrey and two allocated sites in Grade 2 Land
Figure 10 – DMW extract for Hendy and an allocated and partly completed site is identified upon Grade 2 Land

3.4 We would therefore submit that not only can the Land Classification Map not be relied upon as an accurate guide as to the grade of agricultural land, even if it is broadly accurate, the Council has saw fit to develop its houses upon it, and also grant planning permission to Applicants to develop multiple residential properties thereon, without any apparent agricultural compensation for that activity and construction.
In conclusion, this Representation to the Second Deposit Draft of the Revised LDP has sought to examine the Council’s reasons for non-inclusion of a Candidate Site.

Our clients have illustrated that their indicative proposals to construct 11 dwellinghouses will not appear at odds to the prevailing spatial pattern of development in Mynyddygarreg. The proposals will provide a modern frontage development, mirroring modern estate development at the former Optical Factory site, and thus being respectful to the character and setting of the locality.

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

Include Candidate Site reference SR/069/014 as an allocation in the Plan.

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

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/069/014, seeking inclusion of their land for future residential development within the
defined settlement limits of Hendy & Fforest within the Replacement Local Development
Plan. The Candidate Site comprises the rear garden area of “Oaklands”, a substantial
detached dwellinghouse which has two independent vehicular accesses onto Heol-y-Felin,
and Bronallt Road respectively.

The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our clients’ submission, reasons why the site was not selected for inclusion within the draft
settlement limits of Hendy & Fforest, as contained within the Deposit Draft.
We note that the submission successfully passed through all three Assessment Stages,
being Stage 1 (site compatible against the location of future growth presented in the
Preferred Strategy), Stage 2A (Initial Detailed Site Assessment), Stage 2b (Further Detailed
Site Assessment) and Stage 3 (Sustainability Appraisal and Habitat Regulation Assessment)
of the Council’s site assessment.

It therefore crucially was adjudged acceptable in all technical aspects of formal
assessment, but was only rejected at the final selection stage, with reasons for non-inclusion
reported as follows:
“There is sufficient residential elsewhere allocated in the settlement. The site will remain
outside of the development limits.
It is immediately apparent that the Council have repeated the same conclusion from when they published the First Draft of the Replacement LDP in January 2020.
Our clients consider the LDP is “unsound” and should be changed, as it fails to meet the tests for “soundness”, in that the Plan “is not appropriate”, and “will not deliver”, as defined by the Planning Inspectorate’s LDP Examinations Procedural Guidance.

Specifically, our clients consider that the draft settlement limits for Hendy & Fforest, as defined under Policy SD1 “Settlement Limits”, should be amended to include the land as edged in red upon the extract of the Proposals Map for Hendy & Fforest, as reproduced below in Figure 1. The land should be appropriately allocated for housing under Policy HOM1 “Housing Allocations.”
Figure 1 – Extract from Second Draft Proposals Map with site edged in red
This formal representation letter supplements the following documents which comprise a complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits

1.0 Overall Housing Supply at Hendy & Fforest within Deposit Draft

1.1 The Council consider that the only reason for the Candidate Site at Oaklands not being included within the draft Plan as a Residential Allocation is that they believe that there are sufficient residential sites allocated elsewhere in the settlement. On this basis, it must be accepted that the form of the Candidate Site set to the rear of established properties which front Carmarthen Road (A48), together with the
proposals to utilise the existing vehicular access onto Bronallt Road (subject to
appropriate widening and junction alignment) is deemed acceptable, and in accord

with the spatial form and character of the settlement.
1.2 The proposals under this Representation merely seek the addition of circa 7
residential units to the overall housing supply of Hendy & Fforest, which forms part of
the principal service centre centred upon the Llanelli Cluster as defined within the
draft LDP. Figure 2 below provides an extract of the indicative site layout plan for this
Representation site.
Figure 2 – Indicative Site Layout plan of Representation Site

1.3 The Llanelli Cluster aims to provide an additional 2840 residential units over the Plan
period to 2033, with Hendy & Fforest (Settlement SeC6) providing sites totalling 81
units to that overall Cluster total. We would submit in the first instance that the
addition of an allocated site of 7 units will not lead to an over-supply of
dwellinghouses within the Cluster, nor the defined Hendy & Fforest settlement
supply.

1.4 We have examined and researched sites which have been brought forward as
Residential Allocations with the Deposit Draft. In Hendy & Fforest, great emphasis
within the Draft Plan has been placed upon the continued allocation of proposed
housing sites still left allocated from the 2014-21 Local Development Plan. Figure 3
below provides an extract from the Second Deposit Draft Schedule of Housing Sites
from Policy HOM1.
Figure 3 - Schedule of Allocated Sites for Hendy & Fforest from Second Deposit Draft
This Schedule needs to be contrated with the January 2020 Schedule as reproduced below
at Figure 4, and it is noted that only Fforest Garage has been omitted. That site was
indicated as capable of acommodating a total of 17 units. Also SeC6/h2 at “Land between
Clayton Road and East Of Bronallt Road” has been reduced in capacity from 39 units in
2020 to 20 units in 2023.

Figure 4 – Deposit Draft Housing Schedule
1.5 In relation to land adjacent to Clos Benallt Fawr (SeC6/h4), we note all 35 houses at
the site have since been completed.
Site SeC6/h1 at Clos-Ty-Gwyn (Llwyngwern) has also been completed during the last
LDP period of 2014-21.

1.6 However, we note that the Proposals Map in relation to “Fforest Garage” (SeC6/h5)
and “Land between Clayton Road and East of Bronallt Road” (h2) has not altered.
Both undeveloped sites remain allocated. In the case of the latter site off Bronallt
Road, it has the benefit of planning permission for 8 detached houses, of which only
two have been constructed. The 8 dwellings form a phase immediately off an estate
road junction with Bronallt Road, and the phase is restricted to the north-western part
of the entire allocation of 39 units, which stretches south over steeply sloping and
heavily undulating fields to the rear of Clayton Road. No planning permission has ever been sought for the majority of the site, despite the site being included in the Llanelli Borough Local Plan (1996), Carmarthenshire Unitary Development Plan (2003), and latterly the Local Development Plan (2014).

1.7 Consequently, twenty-five years of Development Plan allocations have elapsed without any signs of wholesale delivery of this site, apart from two units directly off the Bronallt Road frontage. Clearly, there is no historic demand for a site of this scale in this part of the Hendy area. It is almost certainly a physically challenging site, due to steep topography and the inability to adequately dispose of surface water, given there is no obvious watercourse receptor to deal with run-off from new development. Yet still the Council is prepared to allocate the site once again in a new Development Plan?
The allocation fails the test of soundness as the site is clearly unable to deliver any new housing. The Development Plans Manual (Edition 3) is quite clear with regard to rolling forward allocations and states that allocations “ … rolled forward from a previous plan will require careful justification for inclusion in a revised plan, aligning with PPW. There will need to be a substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered.”. no evidence has been presented to demonstrate a change in circumstances to indicate the allocation will now be delivered.

1.8 The Council has agreed with our client’s objection to the First Deposit Draft and not allocated “Fforest Garage” with the Second Draft of the LDP. Nevertheless, it has not sought to compensate our client by re-allocating part of those proposed 17 units to our client’s site at Bronallt Road, where only 7 units are proposed. The substitution of sites, and particularly for one with a lower density and capacity, is unjust, and does not aim to deliver a sound plan as it relates to the Hendy & Forest sustainable settlement.

1.9 We submit that there is clear evidence in Llangennech, Hendy, Fforest and Llanedi that such modest sites are far more likely to be brought forward and developed in full by regional and small housebuilders given that construction and development costs are more likely to be viable in relation to house sales and the general housing market in this part of Carmarthenshire.

1.10 In the case of Oaklands at Bronallt Road, there are little signs within the immediate locality of properties for second sale, and no evidence of undeveloped land available within this part of the settlement limits, which is a strong indicator of a healthy property market at Hendy. Consequently, it is a location where housing proposals are deliverable, assisting to meet housing needs in this part of the Llanelli Cluster.
In conclusion, this Representation to the Second Deposit Draft of the Revised LDP has sought to examine the Council’s reasons for non-inclusion of a Candidate Site.

Our clients have illustrated that their indicative proposals to construct circa 7-10 dwellinghouses will not appear at odds to the prevailing spatial pattern of development in Hendy and Fforest. The locality has numerous examples of modern cul-de-sac development
being completed at backland locations, which in turn, advocates that the form of development proposed at Oaklands is no different, resulting in it being respectful to the character and setting of the locality.

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

Include Candidate Site reference SR/021/038 as a housing allocation within the Plan.

1.0 I NTRODUCTION
1.1 Mr. A. Douch, Mr & Mrs T.A.C. Morgan, Mr. J. Jones, Mrs J. Bromley-Davenport & Mrs S. Boggis-Rolfe (the Land Owners) have instructed Evans Banks Planning Limited to prepare and submit a formal Representation for the inclusion within defined settlement limits, and as a formal Residential Allocation, of land at Mounthill Farm, off Mount Pleasant, Llangunnor, Carmarthen for the purposes of development in the Replacement Carmarthenshire Local Development Plan.
1.2 This Statement has been prepared in line with the Authority’s published documents entitled Revised Carmarthenshire Local Development Plan: Guidance Note and Revised Carmarthenshire Local Development Plan: Candidate Site Assessment Methodology. The contents of this Statement therefore address the set criteria, determining the issues and each qualifying point raised within these documents.
Consideration has also been given to ensuring that this formal submission complies with the guidance and requirements of Planning Policy Wales (Edition 11), in relation to the preparation of development plans and the allocation of land for residential purposes as part of that preparation process.
1.3 The contents of this Statement therefore provide a comprehensive case for the inclusion of the land for residential development purposes within the defined settlement limits of Carmarthen, and it should also be read in conjunction with the accompanying supporting information and indicative site layout plan.
1.4 This site did comprise of a Candidate Site submission formally presented to the Council in August 2018, and referenced SR/021/038. Consideration has subsequently been given by our clients as to the conclusions of the Council in their Site Assessment Table (January 2023). The Council consider that “Development of the site would have a detrimental impact on the character and setting of the settlement. Furthermore, there is sufficient and more suitable land available for development within the town to accommodate its housing need.”
1.5 This Statement seeks to examine that conclusion and provide a comprehensive written response to demonstrate that the proposals seek to address and unequivocally overcome the two issues for non-inclusion as put forward by the Council.

2.0 SITE CONTEXT
2.1 THE SITE
2.1.1 The Candidate Site comprises several adjoining field parcels set immediately off the rear of residential properties which flank the western side of Brynhyfryd in Llangunnor. The land has a frontage to that road at the vehicular access to Mounthill Farm, which lies some 280 metres south of the junction of Brynhyfryd with Roman Road. The proposed Strategic Site is found to be extending to a northern perimeter with the southern flank of Roman Road, as it runs westwards through Llangunnor to junction with Rhiw Babell, at the south-eastern outskirts of Carmarthen, near Pensarn.
2.1.2 The site consists of undulating to rolling pasture, interspersed with mature hedgerow and tree lines which form field boundaries, with the entire eastern perimeter of the site adjoining common rear garden boundaries with Brynhyfryd properties. The complete site has an area of 10.2 hectares (25.1 acres) and has a road side frontage of some 140 metres with Brynhyfryd. The four northern fields share a long boundary with Roman Road of some 370 metres which is almost continuous marked with a continuous mature hedgerow, with occasional tree specimens and series of agricultural metal gates at sporadic intervals to access each of the field parcels.
2.1.3 Roman Road is single width for most of its route west of its junction with Mount Pleasant / Brynhyfryd, although there are occasional passing places for local traffic. Brynheulog farmhouse is owned by one of the Proposers and is set off the northern flank of road, with its former farmyard currently under construction to build 9 dwellinghouses. To date 6 detached and semi-detached houses have been completed, with a further three detached units planned with rear boundaries onto the
northern flank of Roman Road. The re-developed farmyard adjoins the much larger Roman Park development, which had originally 12 large executive properties spread around a cul-de-sac but has now been greatly extended with some 75 modern dwellings set in an estate formation off the north of Roman Road. With the exception of Brynheulog and two other established bungalows at Roman Road, no modern dwellings have vehicular access onto that unclassified road. The cul-de-sac known as “Maes-y-Nant” comprises of an additional 11 bungalows but accessed via the Roman Park estate. Those recently completed bungalows have rear garden boundaries which fall against the Roman Road northern flank.
2.1.4 Roman Road extends westwards to enter a narrow ravine which is heavily wooded to both flanks as the carriageway descends in level and gradient to its junction with Rhiw Babell, near Capel Babell. The junction is only some 70 metres distant from the overpass of the A40 dual carriageway which bridges over Rhiw Babell at this point before merging into Penymorfa Lane and Pensarn Road, and a large commercial estate adjoining the town of Carmarthen.
2.1.5 The southern and south-western parts of the Strategic Site adjoin a single field enclosure which adjoins the A48 dual carriageway as it approaches the Pensarn roundabout and convergence of the A48 with A40 and A484 roads. The western part of the Strategic Site has a boundary with a wooded embankment off the eastbound carriageway of the A48, but the embankment is some 70 metres in depth, and ascends over 10 metres in ground level to the levels of the western fields. Accordingly, the Candidate Site cannot be viewed from the A48, with the only field which is visible due to a lack of tree and landscaping cover from the dual carriageway not in the ownership of the Proposers.
2.1.6 The Candidate Site is identified by being edged in red on the plans below. Plan A illustrates its wider position within the suburb of Llangunnor and adjoining town area of Carmarthen, whilst Plan B provides a detailed Ordnance Survey map extract with the site perimeters identified.
Plan A – wider setting of Llangunnor with site highlighted
Plan B – detailed OS Plan of Candidate Site
2.2 SETTLEMENT SUSTAINABILITY AND SITE SETTING WITHIN THE CURRENT ADOPTED LOCAL DEVELOPMENT PLAN (2014) & SECOND DEPOSIT DRAFT (FEBRUARY 2023)
2.2.1 Under the provisions of the current adopted Local Development Plan (2008-21), the proposed land adjoins the Settlement Limits of Llangunnor. The site is shown edged in red at Plan C. It also shown at Plan D, being an extract from the Second Deposit Draft of the Replacement LDP to enable a comparison to be made:
Plan C – Settlement Limits of Llangunnor in 2014-adopted LDP
Plan D – Second Draft of Replacement LDP at Llangunnor
2.2.2 As can be seen, the Candidate Site adjoins and is well related to the draft defined Development Limits of Llangunnor at Carmarthen. At present the development limits are drawn tightly about the existing settlement form off the northern flank of Roman Road, and off the rear garden perimeters of individual properties which are orientated to front the western flank of Mount Pleasant. The Candidate Site seeks to form a new residential estate development to extend southwards off the modern estate developments that have taken place at Llangunnor over the last 10-15 years, namely at Roman Park, Maes-y-Nant and Maes Lewis Morris, where some 150 dwellinghouses have been successfully completed by two National Housebuilders, together with smaller, additional cul-de-sacs constructed by local house builders.
2.2.3 The Mounthill Strategic Site has excellent accessibility by foot and cycle to the nearby Llangunnor Primary School, public park and children’s playground, and local
convenience store at Brynmeurig, where the local public bus service also stops upon its circulatory route about Llangunnor from Carmarthen Bus Station. Existing and new residents are also able to walk only a distance of several hundred metres along Roman Road to access Pensarn Retail and Employment Parks. From there, National Cycle Route 4 is to be found, as is easy access on foot to Carmarthen Rail Station.

3.0 Second Deposit Draft LDP (February 2023)
Housing Land Availability
3.1 The Council published a Deposit Draft in February 2023, which is now subject of public consultation. Within the Second Deposit Draft, Llangunnor sits as part of the town of Carmarthen, being the Principal Service Centre (Tier 1) within the Carmarthen Cluster (Cluster 1). The Cluster aims to provide an additional 1690 residential units over the Plan period to 2033. In response to our clients’ Candidate Site submission, the “Site Assessment Table” (January 2023) indicates that the Council consider that “there is sufficient and more suitable land available for development within the town to accommodate its housing need.”
3.2 We have examined and researched sites which have been brought forward as Residential Allocations with the Second Deposit Draft. Policy HOM1 provides details of the residential Allocations in Carmarthen, Llangunnor and Abergwili as shown below. We have analysed each allocation and noted that the Council have highlighted when they consider each site will come forward for development. Given that the base date for this LDP has been running since 2018, its first five years have already lapsed, and accordingly many sites have already either been completed or are under advanced stages of construction. Years 6-10 are therefore taken to be from 2024 to 2028, with Years 11-15 being the end of the Plan Period from 2029 to 2033.
3.3 A total of 20 sites are listed, which include two large “Mixed Use” sites at West Carmarthen and Pibwrlwyd. Table 1 below itemises the 20 sites, their anticipated residential unit capacity and expected timescale for delivery.
Table 1 – Policy HOM1 Residential Allocations in Carmarthen
3.4 The following sites have been completed between 2018 and 2023 –
Penybont Farm – Site h7 – 9 units
Mounthill – Site h9 – 5 units
Rhiw Babell Extension – Site h11 – 12 units
Bronwydd Road (south) – Site h14 – 44 units
Ty Gwynfa – Site h19 – 10 units
The above five sites have therefore already contributed completions totalling 80 units to the new plan Period.
3.5 We have analysed three proposed allocations, with the first being a major allocation in the 2014-adopted LDP, being has been “rolled-over” into the new Second Deposit Draft. We have submitted separate formal objections under this current consultation period to each of the following sites, and would summarise our objections as follows:
3.6 West Carmarthen (PrC1/MU1) – 700 UNITS
In Carmarthen, great emphasis within the Draft Plan has been placed upon the continued allocation of a large, proposed housing site at West Carmarthen. The site is allocated for 700 residential units as Site PrC1/MU1.
This allocation forms the bulk of a Residential Allocation carried over from the current LDP (2014-21) where the allocation was for 1100 units.
We have calculated that of that 1100 units only a total of 141 were constructed between the Plan Adoption date of December 2014 and start of this Replacement LDP Plan Period of 2018. Since 2018, a further 90 units have been constructed, and we note from Land Registry records that the last completed unit was sold at Maes Macsen in September 2021 (18 months ago).
Therefore, since adoption of the 2014 LDP, only a total of 231 units have been completed, equating to a build rate over that 7-year period of only 33 units per annum. This build rate is considerably lower than the anticipated and much promised delivery of 1100 units in the Plan Period of 2014 to 2021, which would have expected an annual build rate of 157 units. An actual return of 33 units per annum equates to only a 21% build rate return on that anticipated for delivery in the 2014-21 Plan.
Only 39 of those units were built in 2017-18 accordingly to the Joint Housing Land Availability Study 2018. The 2019 Study reveals that only a further 5 units were constructed in 2018-19. The August 2019 Study reports that none were under-construction at that time. During 2020 and 2021 when Covid-19 restrictions were at their peak, more units were constructed than at any other time in that LDP plan period. Therefore, we would submit at this point in our formal objection that low build rates cannot be held, and probably will be subsequently argued by the Council, to be reduced as a consequence of Covid-19 restrictions.
It is equally noteworthy that at a time when the housing market was at its most buoyant in 2022, that the only housebuilder with a track record on the site had
ceased construction and sold their last completion (September 2021). We submit that this is testament to the weak marketability and sales demand of the West Carmarthen Site.
Only 231 units out of 1100 units of the Strategic Site have therefore been completed in the 2014-21 LDP period, which equates to only 21% of that allocated total.
The Replacement LDP seeks to delivery 700 units over a Plan Period from 2018 to 2033. The extract from the Proposals Map for Carmarthen reveals that the figure includes for 90 units constructed between 2018 and 2021, leaving a balance of 610 units envisaged in the remainder of the Plan Period to 2033. That would equate to a build rate of 61 units per annum over a 10-year period. Based upon previous build rates at this site, such a predicted build rate can be described as overly optimistic, being nearly double that actually achieved on the site to date.
The West Carmarthen draft allocation includes parcels of residential allocations off the flanks of the A40 that were previously allocated within the Carmarthen District Local Plan (1997), and subsequent Carmarthenshire Unitary Development Plan (2003). No progress was made in bringing the sites at Llysonnen Road and Old St. Clears Road forward, and yet it was allocated within the Local Development Plan in 2014. Consequently, twenty-seven years of Development Plan allocations have elapsed without any signs of delivery of the majority of this site.
Clearly, there is no historic demand for a site of this scale in this part of Carmarthen. More physically challenging sites, such as the Roman Park site in Llangunnor by Redrow Homes, and the Mount Pleasant site (Maes Lewis Morris), also in Llangunnor, by Lovell Homes have come forward, and been fully completed, long before West Carmarthen. Yet still the Council is prepared to allocate the site once again for hundreds of residential units in a new Development Plan.
3.7 Pibwrlwyd (Site PrC1/MU2) – ALLOCATION OF 247 UNITS
We would also question the allocation of land at Pibwrlwyd in Carmarthen, being partly for a residential development of 247 units on the Parc Pibwrlwyd development. The Council published and subsequently adopted Supplementary Planning Guidance on “Pibwrlwyd” in 2014.
Paragraph 3.2 was quite specific in that “The LDP describes the acceptable uses on the site as follows: “The proposed use for the site is for a business park centred around employment uses (Use Classes B1, B2 and B8), with uses associated with, and ancillary to the existing Coleg Sir Gâr.”
A development brief in the form of SPG has been prepared and adopted. This in setting out appropriate uses under Use Classes B1, B2 and B8 for the employment element of the site also explores other compatible uses. Residential use on this site is not considered appropriate.” (self-emphasis)
The Council has seen fit to re-examine the Development Plan status of this Mixed-Use Site and concluded that residential uses should now be brought forward, with a residential capacity of 247 units. No explanation has been provided within the supporting text to LDP policies to warrant a dramatic departure from the adopted SPG.
The site is completely and physically divorced from established housing at Pensarn and Llangunnor. It is physically separated by foot from local schools, community facilities and play facilities by the A40 / A48 trunk road network, with only a dark and insecure pedestrian underpass linking it to the Pensarn Commercial Area.
New housing at this location would accordingly be quite alien in form to the long-established business and education uses at Pibwrlwyd. New residents would in order to access their new homes would have to drive through an established retail park to access their homes. Such a practice is contrary to the underlying objectives of National Planning Policy Wales which seeks to segregate residential and commercial land uses to avoid potential future conflicts in terms of noise, light disturbance, traffic generation (particularly if HGVs are delivering to the Retail Park), and general disturbance to residential amenities.
3.8 Land off Parc-y-Delyn (PrC1/h4) – ALLOCATED FOR 17 UNITS
This new allocation suffers from including Tree Preservation Orders imposed upon specimens at the proposed vehicle access onto Parc-y-Delyn. The site also appears covered in rich flora and fauna and could harbour biodiversity interests.
3.9 There are several satellite settlements about Carmarthen contributing housing allocations to the Carmarthen Cluster Total of 1690 dwellings. However, we have discovered that many allocations have simply and conveniently been “rolled over” from the 2014 adopted LDP, or in some cases even earlier from the 2006 Unitary Development Plan. No explanation, evidence or demonstration of viability or deliverability has been provided within the Site Assessment Table (January 2023) to demonstrate such a widespread practice.
The following sites are examples of such dormant sites:
Cae Camfas, Heol Llanelli, Pontyates (SeC1/h4) – ALLOCATED FOR 8 UNITS
This site in Pontyates was allocated in 2014 in the Local Development Plan, and yet no applications for planning permission have been submitted in the entire 8 years of the Plan Period.
3.10 Gwyn Villa, Llanpumsaint (SuV12/h1) – ALLOCATED FOR 20 UNITS
This site in Llanpumsaint was allocated in 2014 in the Local Development Plan, and yet no applications for planning permission have been submitted in the entire 8 years of the Plan Period.
3.11 Fronheulog, Cynwyl Elfed (SuV1/h1) – ALLOCATED FOR 8 UNITS
This site in Cynwyl Elfed was allocated in 2014 in the Local Development Plan, and also the 2008 UDP, and applications for planning permission have been submitted for only two individual houses in the entire 15 years of the above combined Plan Periods have been commenced.
3.12 We submit that the above draft allocations amount to 910 units (after the 90 already constructed at West Carmarthen is deducted). That balance is heavily skewed to sites “rolled-over” from the 2008-21 LDP, with no demonstrable evidence as to why that rolling over practice is being pursued, and shown as being reasonable and “sound” for the purposes of delivery in a Replacement LDP.
3.13 West Carmarthen should be significantly reduced in scale, and in the case of Pibwrlwyd and above-named satellite allocations be omitted from the Plan and that housing allocation be redistributed to Candidate Sites, of up to 250 units such as that proposed at Mounthill. There is clear evidence in the rapid completion of the Roman Park, Maes Lewis Morris and Maes-y-Nant developments at Llangunnor, which border the Candidate Site are proof that moderately sized sites are far more likely to be brought forward and developed in full by National and Regional housebuilders, in market-proved neighbourhoods, where completion delivery off the back of strong sales are guaranteed.
3.14 In the case of the Mount Pleasant and Roman Park areas, there are little signs within the immediate locality of properties for second sale, and no evidence of undeveloped land available within this part of the settlement limits, which is a strong indicator of a healthy property market at Llangunnor. Consequently, it is a location where housing proposals are deliverable, assisting to meet housing needs in this part of the Carmarthen Cluster.

4.0 THE PROPOSAL’S ALLEGED IMPACT UPON SETTING AND CHARACTER UPON LLANGUNNOR
4.1 The Council in their Site Assessment Table (January 2023) are opined that the “Development of the site would have a detrimental impact on the character and setting of the settlement.” However, there is no detailed justification or evidence provided to warrant such a conclusion.
4.2 The Candidate Site comprises of a series of agricultural fields which are set at a corresponding ground level to residential properties fronting Mount Pleasant, which forms its entire eastern perimeter. It will appear as an extension of the modern cul-de-sac developments that have evolved and been completed in Llangunnor in the last LDP Plan Period, namely Morgan Drive (Roman Park), constructed by Redrow Homes, and Maes Lewis Morris, constructed by Lovell Homes, and latterly Maes-y-Nant, completed by GRD Developments. Photos 1 and 2 below, taken in March 2023 by aerial drone, illustrates how the modern residential estates off the northern side of Roman Road fall to the edge of the Candidate Site, and thus new development will be seen to seamlessly integrate into that setting.
Photo 1 – view looking west / north-west to Roman Road and Brynheulog and Maes-y-Nant completions
Photo 2 – view east / north-east to Roman Park completed residential estate
4.3 The site is set between established residential properties at Mount Pleasant and the embankment of the A48 trunk road. That embankment is however considerably wide at this point, and heavily vegetated with mature trees and landscaping. That embankment borders further grazing enclosures which fall against the western edge of the proposed Statregic Site, and thus act as a green buffer to the trunk road. Consequently, there is no viewpoint of the Candidate Site from that dual carriageway. Photos 3 and 4 below illustrate the dominant natural screen of A48 embankment from viewpoints within the site and alsong the A48 trunk road.
Photo 3 – aerial viewpoint looking west at A48 landscaped embankment, wholly screening views of the site from the A48 and Parc Pibwrlwyd
Photo 4 – view upon A48 carriageway of high expanse of landscaped embankment naturally screening all views of Candidate Site
4.4 The Candidate Site comprises undulating and rolling semi-improved pasture, shown in Photos 5 and 6, which form up to the rear garden perimeters of Mount Pleasant properties. Field boundaries comprise well-managed hedgerows and tree lines which can all be retained and preserved in situ as part of a phased residential development commencing from a new roundabout interchange near Mounthill farmyard, as shown in Plan E below. The development of the site can extend northwards to reach Roman Road, but not link to it, except for use by pedestrians and cyclists.
Photo 5 – View looking south / south-east at Candidate Site perimeter with Mount Pleasant properties
Photo 6 – view south to Mounthill Farm and illustration of well-defined tree lines which can be fully retained as part of a Strategic Development
Plan E – Proposed access onto Mount Pleasant / Brynhyfryd with new roundabout interchange
4.5 The Candidate Site submission has demonstrated that the setting and character of Llangunnor can be preserved, without detriment to any visual amenities, nor those of the neighbouring residents at Mount Pleasant. The site is “sandwiched” between the A48 cutting and Mount Pleasant, and thus provides no greater contrast to the local setting than the Council’s vision for developing Pibwrlwyd off the opposite side of the A48. If residential development is welcomed upon that greenfield plateau, then conversely there is no argument that can be presented by the Council to warrant a different interpretation of Mounthill.
4.6 Similarly, it could be argued that the part development of West Carmarthen at the western extremity of the town across open, rolling fields, devoid of defensible boundaries is not akin to placing a detriment upon the surrounding open countryside about Travellers Rest? For reasons already presented in this Statement, there is a straight choice in the consideration of whether the Replacement Local Development is deliverable in Carmarthen, and that is with the right choice of a deliverable site at Mounthill. Any argument based on visual setting and character is without basis at Mounthill, and no different to the draft allocation of Pibwrlwyd and West Carmarthen as edge-of-settlement Residential Strategic Sites.

5.0 CONCLUSION
5.1 The Candidate Site is significant in overall size, but located in undulating fields extending south off modern, residential estates which have been constructed in recent years off Roman Park, and Maes Lewis Morris. Individual and established residential development is located off the entire eastern side of the Candidate Site, being houses fronting Mount Pleasant and Brynhyfryd. The field enclosures tend to be well screened from public view by virtue of high perimeter trees which shelter the western site from the A48 dual carriageway in that trunk roads’ approach / exit from Carmarthen. High and mature vegetation surmounts tall embankments along that highway, so as to completely screen the plateau of fields at the Candidate Site.
5.2 The Site lies within close proximity and walking distance to the existing community and local services of Llangunnor. It lies in walking and cycling distance via a pleasant stretch of minor highway along Roman Road to Pensarn Retail and Employment Park, National Cycle Route 4 and Carmarthen Rail Station. Such close distances on foot and cycle will ensure that the future development of this Candidate Site makes a positive contribution to both national and local sustainable development objectives.
5.3 The Council have provided no explanation for their contention that the development of the site will cause detriment to the setting and character of the locality. The proposed development is no different in greenfield form to that proposed at West Carmarthen and Pibwrlwyd, being undulating, enclosures set off a good road network and located with perimeters to a trunk road system.
5.4 This Statement has interrogated the Council’s assertion that there remains sufficient land allocated for housing growth elsewhere in the settlement. This Statement has examined all 20 draft allocations in Carmarthen, and others in the satellite villages which contribute to the Carmarthen Cluster allocation total of 1690 units. The analysis has revealed that over 900 residential units proposed for the Carmarthen Cluster are undeliverable, mainly as a cause of a lack of marketability, poor sales demands, and, in the case of Pibwrlwyd, conflicts with established planning policies which aims to segregate employment and residential land to avoid future amenities’ conflicts.
5.5 The Candidate Site has been demonstrated the following considerations:
a) It is not harbouring any ecological interests, evidenced through a comprehensive Preliminary Ecological Appraisal as semi-improved agricultural land, and reported accordingly within the submission.
b) All perimeter and inter-field perimeters can be fully retained as part of a residential development.
c) The site does not fall within any designated flood zone, nor impacted by surface water ingression.
d) It does lie upon any historic coal legacies, nor industrial past use of the land at Llangunnor.
e) It is able to be successfully accessed off Brynhyfryd via a newly formed roundabout interchange. A new series of pedestrian footways within the site will provide Brynhyfryd and Mount Pleasant residents with a safe refuge to walk to school, public park and convenience shop at Brynmeurig.
f) Roman Road can be re-designated as a public footway and cycleway for all existing and proposed residents
g) The site benefits from being located in immediate proximity to modern residential developments, which have been fully implemented in the last LDP Plan Period. The Llangunnor locality has been extraordinarily successful in demonstrating deliverability of those sites allocated for development, evidenced by high market sales, and attractive house designs and layouts. In short, Llangunnor is a deliverable location to provide future housing growth in a Replacement Local Development Plan.
5.6 In view of the above and the information provided within this Statement, it is respectfully requested that the Candidate Site in question be allocated for Residential Development, within settlement limits of the Carmarthenshire Local Development Plan 2018-2033.

Amend Plan to include the site

This representation objects to the exclusion of this site from the development
limits for Pembrey. It should be emphasised that the accompanying illustrative
scheme could readily be developed in phases and includes areas of landscaping
and communal greenspace in order to enhance local biodiversity and to offer
open areas to residents to support physical and mental well-being. Offering
these positive community benefits is a key part of the scheme’s overall ethos.
The site layout encompasses a high proportion of affordable dwellings (both
social and low cost home ownership).
The overall aim is to produce a residential scheme which would comprise a
quality development and would draw on local vernacular architectural design
elements, making every effort to be sustainable, both through the
employment of local contractors and the use of local suppliers.
In addition to zero-carbon design elements to secure ‘Passivhaus’ status, the
energy requirements of the dwellings will be met by several district heating
systems (bore-hole ground source heat pumps) as well as solar collector arrays.
Electric vehicle charging facilities, battery storage compounds, etc., will be
distributed throughout the site.
The inclusion of the proposer’s land would not lead to additional environmental
pressure, but instead will foster sustainable growth and allow for a wider
choice of housing type within this Tier 2 Service Centre. Its development
would be in keeping and in character with the settlement and will ensure a
deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature
conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood
risk, hydrological, ecological, archaeological or land ownership related
constraints and its short term delivery is assured.
It is considered that this site is both more sustainable and deliverable than
other sites that have been allocated within Pembrey.
The inclusion of this land within revised development limits would be fully
supported.

Amend Plan to include the site

The section of field highlited in red on attached plan is situated immediately to the rear of 2nd Deposit Revised LDP residential allocation number SuV36/h2. Inclusion of this site would provide an excellent opportunity for an extension to the existing allocation providing an in-depth development. The site would also create a logical rounding off of Llanllwni and follows a similar pattern of development to that on the opposite side of the road. Access to the site would be via the existing allocation, which lies adjacent the bus stop. As can be seen from the attached ISA, the site conforms with general planning principles with no obstacles to development. The inclusion of this field within the LDP will allow further sustainable development opportunities within the village of Llanllwni.

Dim byd yn cael ei ddatgan.
___
Nothing stated.

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

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

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

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

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

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


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

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

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

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

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

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



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

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

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

Hap safleoedd eraill - Amhosib dyfalu nifer!

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Include site as a HOM1 allocation within the Plan.

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

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/026/002, seeking inclusion of their land for future residential development within the
defined settlement limits of Cefneithin within the Replacement Local Development Plan. The
Candidate Site comprises an undeveloped field enclosure set primarily to the rear of
residential properties which front the northern flank of Heol-y-Parc in Cefneithin. The site can
be accessed off a surfaced driveway track which leads off Heol-y-Parc, and accordingly
northwards to our client’s property, associated domestic outbuildings and garden space.

We have noted that the frontage proportion of the rear enclosure (within our clients’
ownership) is included within the Second Deposit draft settlement limits, as part of
Allocated Site PrC3/h8. The client now wishes to seek inclusion of the remainder of the
rear enclosure as an extension of draft Allocated Site.
This formal Representation proposes an Alternative Site to that already accepted as a
Candidate Site in 2018, as shown edged in red at Figure 1 overleaf
Our clients consider the LDP is “unsound” and should be changed, as it fails to meet the
tests for “soundness,” in that the Plan “is not appropriate,” and “will not deliver,” as defined
by the Planning Inspectorate’s LDP Examinations Procedural Guidance.
Specifically, our clients consider that the draft settlement limits for Cefneithin, as defined
under Policy SD1 “Settlement Limits”, should be amended to include the land as edged
in red upon the extract of the Proposals Map for Cefneithin, as reproduced below in Figure 2. The land should be appropriately allocated for housing under Policy HOM1 “Housing Allocations.”
Figure 1 – extent of Represenation site edged in red

Figure 2 – Extract from Draft Proposals Map with Representation site edged in red

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

- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
- Location and indicative site layout plans
Justification for Inclusion
of Enlarged Site within Settlement Limits

1. The proposals under this Representation merely seek the addition of circa 6 residential units to the overall housing supply of Cefneithin, which forms part of the principal service centre of Cross Hands, and within the Ammanford / Cross Hands Cluster as defined within the draft LDP. Figure 2 below provides an extract of the indicative site layout plan for this Representation site.

Figure 2 – Indicative Site Layout Plan of Representation Site

2. The Ammanford / Cross Hands Cluster aims to provide an additional 1267 residential units over the Plan period to 2033, and thus the addition of an allocated site of only 6 units will not lead to an over-supply of dwellinghouses within the Cluster.

3. Only one site is allocated within the draft settlement limits of Cefneithin, that being Site PrC3/h8 “Heol-y-Parc”. That site is expected to provide for 18 units, part of which is included in land owned by our client. This Representation seeks to extend that allocated site east to encompass the entire rear enclosure and add a further 6 units about a cul-de-sac arrangement.

4. It is considered that the settlement of the scale of Cefneithin is highly sustainable given its close proximity to Cross Hands and its wealth of retail, employment and community facilities. The addition of only one modest site in the village will not bring enough housing for the remainder of the new Plan Period. The addition of an
expanded site with only 6 further units will not place a burden on facilities, not the semi-rural backdrop to the settlement.

5. The locality has numerous examples of modern cul-de-sac development being completed at backland locations, especially opposite, off the southern flank of Heol-y-Parc, which in turn, advocates that the form of development proposed off the northern flank of Heol-y-Parc is no different, resulting in it being respectful to the character and setting of the locality. The indicative site layout plan illustrates that new dwellings can be positioned to remain at a healthy and commensurate habitable distance from existing neighbouring properties backing on to the site from Heol-y-Parc.

We respectfully request that this Representation be given careful examination, and consequently the defined settlement limits of this part of Cefneithin realigned to include the Representation Site, as an expanded part of a Residential Allocation in the Proposals Map of the adopted Local Development Plan.

No Change to the Plan.

As the County Councillor of Glanamman, I am writing to support the exclusion of the land off Cwmamman Road, Glanamman SA18 2AF, Grid Reference coordinates XY as follows, 266436: 213116.

I have been receiving very strong objections from residents living within the vicinity of this land, regarding any future housing development from taking place. Some of the residents concerns are as follows:

• The highway’s infrastructure and the impact of the additional traffic would cause safety concern, in what is already a dangerous location.
• High ecological value, and any harm to its biodiversity.
• The long history of coal mining in the area and the recorded subsidence issues in the immediate vicinity.
• The impact a possible housing development would have on other residents, including a secluded dog rescue centre.

Therefore I welcome that this land is not included in the LDP or the second deposit revised LDP and sincerely hope it remains this way.

The development limits to be extended from the current position to Fronhaul to the East of the current limit.

Following discussions on the evolution of site reference CA0053 (land adjacent Darren View SC42/h1) the 2nd deposit of the LDP has included a revised area of land adjacent to the Old Tailors (map reference 51.952138 , -4.144805).
This was revised following discussions on plans to develop only the land adjacent to Abergorlech Road (B4310) of the original CA0053 site.
As land owner, I would appreciate a reconsideration of the allocated area and redefined development limits. In order to unite the disparate upper and lower areas of the village into one cohesive whole, the development limits to be extended from the current allocation to Fronhaul to the East of the current limit. (See attached map)
As has been discussed with the forward planning officer, there is a current pre-planning application submitted for the land discussed above, with a full planning submission to follow once comments on the proposed development have been received.

Allocate site AS2/009/001 under Policy HOM1.

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

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

3.1 The clients are Justin & Janet Parry of Cysgod y Dderwen, Penygroes
Road, Caerbryn, Ammanford.

4 The Site
4.1 The site is an irregular shaped piece of land which forms part of the
immediate residential curtilage associated with the property known
as Cysgod y Dderwen and also part of the wider parcel of land
associated with Cysgod y Dderwen. Cysgod y Dderwen forms part of
a grouping of dwellings at the north-western end of the settlement
of Caerbryn.
4.2 The part of the site immediately adjacent to Cysgod y Dderwen consists of a lawned area, whilst the remainder of the site consists primarily of overgrowth.
4.3 The site fronts onto the unclassified road that serves as the main access route to Cysgod y Dderwen as well as the other residential properties. The site is bounded by tress and vegetation along the majority of its boundaries.
4.4 The site lies directly opposite a row of detached residential dwellings fronting onto the unclassified road and immediately north of Ty Llwyncelyn which is a stand-alone residential dwelling set in extensive grounds.
4.5 The proximity of the site to neighbouring dwellings and its proximity to the existing built form associated with Caerbryn is illustrated on the map extract below (Figure i).
Figure i – Location Plan
4.6 Whilst the site currently occupies an open countryside location, it lies immediately adjacent to the settlement development limits associated with Caerbryn. The actual proximity of the site to the predominantly residential area within the village is clearly shown on the aerial photograph below (Figure ii).
Figure ii – Aerial Photograph
4.7 The site is essentially an overgrown ‘greenfield’ site, however, given the residential dwellings immediately north (Cysgod y Dderwen) and just south (Ty Llwyncelyn), the site, to an extent, can also be described as an infill site.
4.8 Vehicular access into the site is currently gained via existing entrance which come directly off the adjacent public highway.

5 The Development
5.1 The aim of the development advanced as part of this LDP representation would be to provide approximately 5 residential plots, fronting onto the unclassified road/access track.
5.2 Both the Location and Site plans below (Figures iii and iv) illustrate the configuration of the site and extent of the site boundaries in relation to the immediate environs and surrounding area.
Figure iii – Location Plan
5.3 The site plan extract below (Figure iv) illustrates the indicative plot layout which takes into full account the configuration of the site as well as the approximate plot sizes of nearby residential properties.
Figure iv – Indicative Site Layout

6 Policy Context
6.1 A review of the planning policy context associated with the site and the proposed development (at national and local level) is provided within this section of the Statement.
National Planning Policy
6.2 Well-Being of Future Generations (Wales) Act (2015)
6.2.1 The Act places a duty upon public bodies to produce well-being objectives that contribute to achieving a set of overarching well-being goals:
• A Prosperous Wales;
• A Resilient Wales;
• A Healthier Wales;
• A More Equal Wales;
• A Wales of Cohesive Communities;
• A Wales of Vibrant Culture and Thriving Welsh Language; and
• A Globally Responsible Wales.
6.2.2 Each public body is then required to take reasonable steps to meet their objectives in the context of the principle of sustainable development and whilst following a set of five ways of working.
6.2.3 The 'Resilient Wales' and 'Healthier Wales' goals are the key goals that open space and greenspace, as part of the planning process will contribute towards delivering.
6.3 Planning Policy Wales : Edition 11 (February 2021)
6.3.1 Planning Policy Wales (PPW) forms the overarching national planning policy document for Wales and sets out the land use planning policies of the Welsh Government. It is supplemented by a suite of Technical Advice Notes (TANs), Welsh Government Circulars, and policy clarification letters which together with PPW provide the national planning policy framework for Wales. The main objective of PPW is to promote place-making and sustainable forms of development.
6.3.2 The primary objective of PPW is to ensure that the planning system contributes towards the delivery of sustainable development and improves the social, economic, environmental and cultural well-being of Wales, as required by the Planning (Wales) Act 2015, the Well-being of Future Generations (Wales) Act 2015 and other key legislation. PPW and National Development Framework (NDF) set out how the planning system at a national. Regional and local level can assist in delivering these requirements through strategic Development Plans(SDPs) and Local development Plans (LDPs).
6.3.3 There are a number of key planning principles indicated within Planning Policy Wales (PPW) to achieve the right development in the right place.
6.3.4 Paragraph 1.18 emphasises that the legislation secures a presumption in favour of sustainable development in accordance with the development plan, unless material considerations indicate otherwise. The principles of sustainable development are defined in the Well-being of Future Generations Act.
6.3.5 Paragraph 1.22 of PPW states that up-to-date development plans are the basis of the planning system and that these set the context for rational and consistent decision making, where they have been prepared in accordance with up to date national planning policies.
6.3.6 These key planning principles are set out with a view to achieve a number of national sustainable placemaking outcomes, as explained in paragraphs 2.15-2.20 and outlined in Figure 4. The national sustainable placemaking outcomes are:
People and Places: Achieving Well-being Through Placemaking
• Growing our economy in a sustainable manner
• Making best use of resources
• Maximising environmental protection and limiting environmental impact
• Creating and sustaining communities
• Facilitating accessible and healthy environments
6.3.7 Paragraph 2.17 states “In responding to the key principles for the planning system, the creation of sustainable places and in recognition of the need to contribute to the well-being of future generations in Wales through placemaking, development plans and development proposals must seek to deliver development that address the national sustainable placemaking outcomes”.
6.3.8 Sustainable development forms a key consideration central to all policies contained within Planning Policy Wales (PPW). Paragraph 1.2 states: “The primary objective of PPW is to ensure that the planning system contributes towards the delivery of sustainable development and improves the social, economic, environmental and cultural well-being of Wales, as required by the Planning (Wales) Act 2015, the Wellbeing of Future Generations (Wales) Act 2015 and other key legislation.”
6.3.9 Paragraph 2.27 sets out how to assess the sustainable benefits of development: “Planning authorities should ensure that social, economic, environmental and cultural benefits are considered in the decision-making process and assessed in accordance with the five ways of working to ensure a balanced assessment is carried out to implement the Well-being of Future Generations Act and the Sustainable Development Principle. There may be occasions when one benefit of a development proposal or site allocation outweighs others, and in such cases robust evidence should be presented to support these decisions, whilst seeking to maximise contributions against all the well-being goals.”
6.3.10 Paragraph 2.17 states that “in responding to the key principles for the planning system, the creation of sustainable places and in recognition of the need to contribute to the well-being of future
generations in Wales through placemaking, development plans and development proposals must seek to deliver developments that address the national sustainable placemaking outcomes.”
6.4 Future Wales: The National Plan 2040
6.4.1 Future Wales – The National Plan 2040 is Wales’ national development framework which sets out the direction for development in Wales to 2040. It is a development plan that sets out a strategy for addressing key national priorities including sustaining and developing a vibrant economy, achieving decarbonisation and climate-resilience, developing strong ecosystems and improving the health and wellbeing of our communities.
6.4.2 The spatial strategy is a guiding framework which sets out the key national policies that will guide and encourage development which supports sustainable growth in both urban and rural areas across Wales.
Policy 1 – Where Wales will grow
6.4.3 Policy 1 is the overarching policy which sets out where sustainable growth will take place in Wales. Three National Growth Areas have been established where there will 14 be growth in employment and housing opportunities and investment in infrastructure. The National Growth Areas are:
• Cardiff, Newport and the Valleys;
• Swansea Bat and Llanelli; and
• Wrexham and Deeside.
6.3.4 These National Growth Areas are complemented by Regional Growth Areas, which will grow, develop and offer a variety of public and commercial services at regional scale. There are Regional Growth Areas in three regions:
• The South West;
• Mid Wales; and
• The North.
6.3.5 In addition to the above growth areas, there are a mix of smaller towns and villages and large areas of countryside. The policy states that ‘development in towns and villages in rural areas will support local aspirations and need, complementing rather than competing with efforts to grow our cities and towns.’
Local Planning Policy
6.4 The proximity of the site to the defined settlement development limits for Caerbryn in the current Local Development Plan 2006-2021 (LDP) is illustrated in the map extract below, Figure (v).
Figure v – Proposals Map (LDP 2006-2021)
6.5 The proximity of the site to the defined settlement development limits for Caerbryn in the 2nd Deposit Revised Carmarthenshire Local Development Plan (LDP) is illustrated in the map extract below, Figure (vi).
6.6 It is evident from the revised proposals map that the settlement development limits have been altered and reconfigured to include and to take into account the grouping of residential dwellings all served by the unclassified road.
12
Figure vi – Proposals Map (Revised LDP 2018-2033)

7 Detailed Consideration
7.1 As highlighted in the Integrated Sustainability Appraisal (ISA), it is asserted that the site is deemed compatible with Strategic Policy SP3 of the revised LDP which seeks to ensure the provision of growth and development is directed to sustainable locations in accordance with the spatial framework.
7.2 Given its siting immediately adjacent to the village of Caerbryn and its proximity to nearby villages such as Blaenau, Llandybie and Penygroes, together with the fact that Caerbyn is identified as a settlement that falls within the Ammanford/Cross-Hands Cluster, which is classed as a Cluster 3 Principal Centre within the Settlement Settlement Framework, ISA Objective 1 (Sustainable Development) is satisfied in this instance.
7.3 As illustrated on the indicative plan below (Figure vii), the site can potentially accommodate five dwellings.
Figure vii – Indicative Plot Layout Plan
7.4 The site is directly related to the identified settlement of Caerbryn. As illustrated on the previous location plan (Figure i), the site represents a sustainable location given its close proximity to Caerbryn, which falls within the Ammanford/Cross-Hands cluster
which is classed as a Service Centre in Strategic Policy SP3 of the LDP.
7.5 Natural Resources Wales Development Advice Maps indicate that the site does not lie within a Zone C1 or C2 flood area as defined by the development advice maps referred to in Technical Advice Note 15, Development and Flood Risk (TAN 15), as illustrated in the DAM extract below (Figure viii).
7.6 TAN15 states that new development should be directed away from Zone C and towards zone A, otherwise to zone B, where river or coastal flooding will be less of an issue. The site is not considered to be at risk of flooding during at least the 1 in 1000 year event.
7.7 The development advice maps supplemented by sediment data, held by the British Geological Survey (BGS), of historical flooding. The maps adopt a precautionary principle and are based on the best known information available at the time. It is noted that the NRW flood maps show the site as being flood free during the Q100 event and Q1000 event.
Figure viii – DAM Map
7.8 The Flood Map for Planning Wales also indicates that the majority of the site is not at risk from localised or surface water flooding; this is illustrated on the FMfP extract below (Figure ix). The Flood Risk Map below demonstrates that apart from a small section of the site frontage, the site falls outside of Flood Zone 2 and Flood Zone 3, as such falls within and an area deemed at low flood risk from rivers.
The Site
The site will not be affected during the 1 in 1000 fluvial (Q1000 event or 0.1% event) and would also be flood free during the 1 in 100 (Q100) flood event.
Figure ix - FMfP
7.9 The site does not fall within a C1 or C2 flood risk zone as delineated by TAN15 DAM flood maps. Neither does it fall within a Flood Zone 2 or Flood Zone 3 as delineated by FMfP (Flood Map for Planning Wales). As such, ISA Objective 4 (Climatic Factors) and ISA Objective 5 (Water) are both satisfied in this instance.
7.10 The site is not located within or immediately any of the following designated sites:
• Sites of Special Scientific Interest (SSSI)
• Special Areas of Conservation (SAC)
• Special Protection Areas (SPA)
• National Nature Reserves (NNR)
• Local Nature Reserves (LNR)
• Common Land or registered village green
As such, ISA Objective 2 (Biodiversity) is satisfied in this instance.
7.11 The site is not located within or immediately adjacent to any Scheduled Monuments. As such, ISA Objective 8 (Cultural Heritage and Historic Environment) is satisfied in this instance.
7.12 The proposed development is deemed appropriate at this location in that it would not impact on any core planning principles. The
The Site
proposed development would be sited immediately opposite a row of existing residential dwellings and also between two existing residential properties, namely Cysgod y Dderwen and Ty Llwyncelyn. The map extract below (Figure x) illustrates the existing pattern of development at this part of the village and the proximity of the site to the existing built form associated with the settlement.
Figure x – Location Plan
7.13 Clearly the development would not lead to unacceptable ribbon development; it would not be deemed tandem development. It would not lead to unacceptable coalescence of settlements and given its siting between existing properties it would be classed as a form of infill, as such, cannot be described as unacceptable sporadic development or an unacceptable extension to the settlement. In addition it would not result in the loss of areas of public open space or formal recreational land. Given the aforementioned, it is asserted that the development would not be contrary to general planning principles.
7.14 The development would sit comfortably at this location without having any detrimental impact whatsoever on the character or setting of the settlement. Furthermore, the development would not have any detrimental impact on any features of the settlement such
as landscapes, townscapes or buildings of importance as a result of its scale, density and prominence. As such, ISA Objective 8 (Cultural Heritage and Historic Environment) along with ISA Objective 9 (Landscape) are both satisfied in this instance.
7.15 The proposal, in part, would involve the re-use of suitable previously developed land, given that the ruins of a former dwelling occupy part of the site. It is acknowledged that the remainder of the site is a greenfield site, as such, ISA Objective 7 (Soil) is partly satisfied in this instance.
7.16 The site has a road frontage boundary that fronts onto an Unclassified Road. As such, the site is readily accessible from the existing public highway. The site has existing and established entrances with adequate visibility splays, which allows direct access into the site.
7.17 The access is not a through-road and is a relatively quiet road which primarily serves Cysgod y Dderwen along with another 7 residential properties fronting directly onto the road. The road junction onto the B4556 (Penygroes Road) is also served by adequate visibility splays. The map below (Figure xi) illustrates the number of crashes in the immediate vicinity of the site.
Figure xi (Source:Crashmap.co.uk)
7.18 Data obtained from Crashmap.co.uk confirms that in the last 20 years, there have been no slight, serious or fatal crash incidents along the unclassified road or at the B4556 road junction. This would suggest that there are no highway issues relating to the site or the public road(s) which serve the site.
7.19 The site lies in fairly close proximity to National Cycle Network Route 47, which is approximately 4km away an Route 437 which is 3km away. This is illustrated on the Sustrans National Cycle Network Map extract below (Figure xii).
Figure xii (Source:Sustrans)
7.20 The site is readily accessible to a local bus services (First South & West Wales) Route No. 129, with the nearest bus stop less than a 1 minute walk away. There’s a regular bus service which links the village to the commercial centres of Ammanford and Cross Hands.
7.21 It is considered the site has suitable access to public transport as well as identified active travel routes, as such, satisfies the following ISA Objectives; ISA 3 (Air Quality), ISA 4 (Climatic Factors), ISA 6 (Material Assets), ISA 12 (Health & Well-being), ISA 13 (Education s& Skills), ISA 15 (Social Fabric).
7.22 Given its location, the site lies immediately adjacent to an accessible green space. In addition, the site is very accessible to an identified recreation play area in the settlement of Caerbryn. The nearest play space identified on the LDP Proposals Map is approximately 100 metres away which represents a reasonable walking distance. As such, it is considered the site satisfies ISA Objective 12 (Health & Well-being) and ISA Objective 15 (Social Fabric) .
7.23 The plan extract below (Figure xiii), taken from the LDP Proposals Map highlights the proximity of the site to the identified play spaces in the village of Caerbryn.
Figure xiii – LDP2 Proposal Map
7.24 The site is within a reasonable walking distance of a number of services and facilities that can be found in Caerbryn and Blaenau. In addition, the site is within a reasonable distance of the Ammanford/Cross Hands service centre which has a wide range of employment/retail provisions, services and facilities. Whilst the site occupies a rural location, it represents a very sustainable location given its close proximity to the service centre.
7.25 It is considered the site is within a reasonable distance of a number of employment and retail provisions as well as other local services and facilities, given its proximity to Ammanford and Cross Hands. As such, the site satisfies the following ISA Objectives; ISA 6 (Material Assets), ISA 10 (Population), ISA 14 (Economy), ISA 15 (Social Fabric).
7.26 The site represents a sustainable location in terms of its proximity to nearby nursery schools and Blaenau Primary School. The site is also within a reasonable distance of Ysgol Maes y Gwendraeth (4km) and Amman Valley Comprehensive School (3km). As such, ISA Objective 13 (Education & Skills) is satisfied in this instance.
7.27 The site is not located within or adjacent to a mineral buffer zone, as such, ISA Objective 6 (Material Assets) is satisfied in this instance.
The site is not located within a Mineral Safeguarding Area, as such, ISA Objective 6 (Material Assets) is satisfied in this instance. The site is not located within or immediately adjacent to an a Air Quality Management Area (AQMA), as such, ISA Objective 3 (Air Quality) is satisfied in this instance.
7.28 The site does not contain high carbon e.g. peatlands, as such, ISA Objective 7 (Soil) is satisfied in this instance. The site does not contain high quality agricultural land (grades 1,2 or 3A, as identified within the Agricultural Land Classification Maps). As such, ISA Objective 7 (Soil) is satisfied in this instance.
7.29 The site is not located within or immediately adjacent to any Regionally Important Geological or Geomorphological Sites. As such, ISA Objective 9 (Landscape) is satisfied in this instance.
7.30 The site is located within close proximity to a viable water connection and is also located within close proximity to other viable infrastructure requirements such as electricity and main sewer.
7.31 The site is not located within or adjacent to a phosphate sensitive SAC catchment. A such, As such, the site satisfies the following ISA Objectives; ISA 2 (Biodiversity), ISA 5 (Water) & ISA 7 (Soil).
7.32 The site by virtue of its scale and location, would not have the potential to have a detrimental impact on the Welsh Language. As such, ISA Objective 11 (Welsh Language) is satisfied in this instance.
7.33 The traffic movements associated with the development proposal will be marginal and the development could be accommodated on the highway network and will not have a detrimental impact on the free flow of traffic due to the existing volumes of traffic using the local highway network. There are no access or transport constraints to prevent the development of the site for residential purposes.
7.34 It is asserted that owing to the nature of the development proposal being advanced i.e. 5 dwellings, the development has due regard to the existing built form and also character and appearance of the surrounding area. Careful consideration has been given to the proposed layout to ensure the relationship between the proposed dwellings and existing development in close proximity is acceptable. It is considered 5 residential plots would conform with the character and appearance of the immediate area in terms of siting and land use.
7.35 It is not disputed that the siting of five dwellings at this location would introduce built form at an otherwise undeveloped site. However, the dwellings would not represent a prominent or conspicuous form of development. While the proposed development would inevitably change the character of the site itself, the proposed changes would not be to the extent that would result in an unacceptable impact on the surrounding landscape.
7.36 The development would not be readily visible from the wider area; the mature trees and vegetation along the site boundaries would, to a degree, mitigate any visual impact.
7.37 Given the aforementioned, it is considered that any resulting development would not be inappropriate or disproportionate in scale. It is on this basis that it is considered that the proposal would represent a sensitive form of development, commensurate with the existing built form, hence would not adversely affect the spatial character of the village.
7.38 The development would not have a significant impact on the amenity of adjacent land uses, properties, residents or the community. The impact on the amenity of nearby residents has been fully considered and duly discounted, particularly given the separation distance between the site and the nearest residential properties.
7.39 Overall, the proposed development would satisfy PPW’s objective of achieving sustainable development both by ensuring that the local community has access to sufficient housing and affordable options whilst also working to facilitate a modal shift to more sustainable methods of transport and reducing car borne journeys.

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

Dim byd yn cael ei ddatgan
___
Nothing stated

Er syw Pennaeth yr adran gynllunio Cyngor Sir Gaerfyrddin

Rydw i wedi gwario oriau yn ceisio darganfof ffurflenni adrodd nôl ar Ail Gynllun Datblygu lleol Adneuo diwigedig Sir Garfyrddin ond heb unrhyw lwyddiant. Felly rydw i wedi gorfod ebosto.
Fy mhrif pryderon yw

: bod hewl sydd yn cario traffig ym Mharc Pencrug yn anaddas i gario traffig trwm yr adeiladwyr â ‘r ceir ychwanegol a bwriedir eu hadeiladu.

: bod parc chwarae plant ar ochr y ffordd felly fe fydd mwy o draffig yn beryg.

:ydy’r tai fforddiadwy a bwriedir eu adeiladu ar gyfer teuluoedd Llandeilo yn unig neu o ble byddant yn dod ac oes sicrwydd bydd y tai ddim yn cael eu gosod yn y dyfodol i bobl o dros y ffin?

: pryderaf am y nifer o dai a’r efffaith ar yr iaith a diwylliant Gymreig.

Yr eiddoch yn gywir

No change to the Plan.

Firstly may I thank you , on behalf of Gorslas Community Council, for the opportunity to comment on the revised and updated LDP Plan.

Members have noted that cognisance has been taken of the views previously submitted by the Community Council and that revisions have been made such as those relating to Bron Yr Ynn. It is much appreciated.

There was also an appreciation of the value of having a strategic framework for any future developments helping to define the future shape and scale of the communities and area for the future. It helps provide clarity and surety for all.

In relation to the proposals in the revised plan members wished to offer the following observations:-

1.0 Drefach Ward: Nantydderwen Site.

Any proposed future development of the site take into account:
• The existing Surface Water issues
• Impact of additional traffic.
• The effect on the current high level of Anti Social Behaviour.
• Lack of amenities for residents.
2.0 Drefach Ward: Sites opposite Drefach Primary School.
• Consideration be given to the possibility of further housing developments creating a "rat run" in areas where children regularly play.

It would be appreciated if you could kindly include the issues highlighted above as part of the process of review.

Should you require further information , or clarification, in relation to these matters please do ot hesitate to contact me direct.

Amend the Plan to include the site

Trelech SC8/h1
Further to the below email, I would like to object to the above site being de-allocated from the LDP.

I’m thinking of objecting to this site being de-allocated from the LDP. As you are aware two houses have been built and the road has been prepared. Have you been able to contact the owner of the land as after making enquiries I still do not know who the owner is.

The site has been allocated within a number of development plans and little progress to date. Site to be de-allocated from the revised LDP and development limits to be amended, although leaving infill plots on the northern side to allow for small scale development.

Existing LDP Allocation SC8/h1 Adj. Picton House Residential
Existing LDP Allocation SC8/h1 Adj. Picton House Residential

No change to the Plan

Dear Planning Manager

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

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

Include the site within the Plan

1 General Description
1.1 This LDP Representation relates to the potential revision of the
defined settlement limits to include a new site for residential
development in the Carmarthenshire Revised Local Development
Plan 2018 – 2033.
2 LDP Representation
2.1 The statement has been prepared by Ceri Davies BA Hons, Dip UP,
MRTPI, (Director of Ceri Davies Planning Ltd). The statement is
based on information provided by the client and other consultants.
All stated dimensions and distances are approximates and based on
the best information available at the time. Please refer to the
submission plans for detailed information.
2.2 The LDP Representation details include:
• 2
nd Deposit Revised LDP Representation Form
• Location & Site Plans
• Planning Statement
3 Client Details
3.1 The client is Gwyn Lewis of Gilfach Stables, Broadway, Laugharne,
Carmarthenshire, SA33 4NS.
4 The Site
4.1 The site consists of broadly rectangular shaped piece of land which
is currently used for grazing and keeping of horses. The site lies
immediately adjacent to existing dwellings in Broadway, just west
of Laugharne.
4.2 The block of land lies on the northern flank of the A4066, between
an established row of road frontage dwellings to the east, fronting
onto the adjacent highway and a caravan park to the west. The site
represents part of a wider gap between the row of houses and the
caravan site.
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4.3 The site fronts directly onto the A4066 and is occupies a position
below the road level. Directly opposite is arow of more recently built
dwellings on the southern flank of the A4066. There are a number
of dwellings beyond the block of land to the west.
4.5 The proximity of the site to neighbouring dwellings and its proximity
to the existing built form associated with this part of the village of
Broadway, particularly along the highway is illustrated on the map
extract below (Figure i).
Figure i – Location Plan
4.6 Whilst the site currently occupies an open countryside location, it
lies immediately adjacent to and opposite existing houses and in
close proximity to the heart of the rural village.
4.7 The actual proximity of the site to the predominantly residential
area within the village is clearly shown on the aerial photograph
below (Figure ii).
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Figure ii – Aerial Photograph
4.7 Vehicular access into the site is currently gained via the existing field
entrance which serves the stable-block and come directly off the
adjacent public highway.
5 The Development
5.1 The aim of this representation is to challenge the removal of the
defined settlement development limits associated with Broadway
and also to challenge its designation as a Tier 4 Rural Village within
Cluster 6, as outlined in the draft Strategic Policy SP3: Sustainable
Distribution – Settlement Framework. In re-introducing the
settlement limits to Broadway and re-designating it as a Tier 3 –
Sustainable Village, this representation also seeks to incorporate
the aforementioned site, edged in red, in the said defined limits.
5.2 Both the Location and Site plans below (Figures iii and iv) illustrate
the extent of land the client considers ought to be included in the
revised settlement development limits associated with the village of
Broadway, if the said limits are to be re-introduced.
The Site
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5.3 The built up area consists predominantly of residential dwellings
and also consists of a public house which provides a communal
place for congregating.
Figure iii – Location Plan – Suggested revised limits for Broadway
5.4 The site plan below illustrates in greater detail the extent of the land
deemed appropriate for inclusion in the revised settlement limits
for the village.
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Figure iv – Site Plan
6 Policy Context
6.1 A review of the planning policy context associated with the site and
the proposed development (at national and local level) is provided
within this section of the Statement.
National Planning Policy
6.2 Well-Being of Future Generations (Wales) Act (2015)
6.2.1 The Act places a duty upon public bodies to produce well-being
objectives that contribute to achieving a set of overarching wellbeing goals:
• A Prosperous Wales;
• A Resilient Wales;
• A Healthier Wales;
• A More Equal Wales;
• A Wales of Cohesive Communities;
• A Wales of Vibrant Culture and Thriving Welsh Language; and
• A Globally Responsible Wales.
6.2.2 Each public body is then required to take reasonable steps to meet
their objectives in the context of the principle of sustainable
development and whilst following a set of five ways of working.
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6.2.3 The 'Resilient Wales' and 'Healthier Wales' goals are the key goals
that open space and greenspace, as part of the planning process will
contribute towards delivering.
6.3 Planning Policy Wales : Edition 11 (February 2021)
6.3.1 Planning Policy Wales (PPW) forms the overarching national
planning policy document for Wales and sets out the land use
planning policies of the Welsh Government. It is supplemented by a
suite of Technical Advice Notes (TANs), Welsh Government
Circulars, and policy clarification letters which together with PPW
provide the national planning policy framework for Wales. The main
objective of PPW is to promote place-making and sustainable forms
of development.
6.3.2 The primary objective of PPW is to ensure that the planning system
contributes towards the delivery of sustainable development and
improves the social, economic, environmental and cultural wellbeing of Wales, as required by the Planning (Wales) Act 2015,
the Well-being of Future Generations (Wales) Act 2015 and other
key legislation. PPW and National Development Framework (NDF)
set out how the planning system at a national. Regional and local
level can assist in delivering these requirements through strategic
Development Plans(SDPs) and Local development Plans (LDPs).
6.3.3 There are a number of key planning principles indicated within
Planning Policy Wales (PPW) to achieve the right development in
the right place.
6.3.4 Paragraph 1.18 emphasises that the legislation secures a
presumption in favour of sustainable development in accordance
with the development plan, unless material considerations indicate
otherwise. The principles of sustainable development are defined in
the Well-being of Future Generations Act.
6.3.5 Paragraph 1.22 of PPW states that up-to-date development plans
are the basis of the planning system and that these set the context
for rational and consistent decision making, where they have been
prepared in accordance with up to date national planning policies.
6.3.6 These key planning principles are set out with a view to achieve a
number of national sustainable placemaking outcomes, as
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explained in paragraphs 2.15-2.20 and outlined in Figure 4. The
national sustainable placemaking outcomes are:
People and Places: Achieving Well-being Through Placemaking
• Growing our economy in a sustainable manner
• Making best use of resources
• Maximising environmental protection and limiting environmental
impact
• Creating and sustaining communities
• Facilitating accessible and healthy environments
6.3.7 Paragraph 2.17 states “In responding to the key principles for the
planning system, the creation of sustainable places and in
recognition of the need to contribute to the well-being of future
generations in Wales through placemaking, development plans and
development proposals must seek to deliver development that
address the national sustainable placemaking outcomes”.
6.3.8 Sustainable development forms a key consideration central to all
policies contained within Planning Policy Wales (PPW). Paragraph
1.2 states: “The primary objective of PPW is to ensure that the
planning system contributes towards the delivery of sustainable
development and improves the social, economic, environmental
and cultural well-being of Wales, as required by the Planning
(Wales) Act 2015, the Wellbeing of Future Generations (Wales) Act
2015 and other key legislation.”
6.3.9 Paragraph 2.27 sets out how to assess the sustainable benefits of
development: “Planning authorities should ensure that social,
economic, environmental and cultural benefits are considered in
the decision-making process and assessed in accordance with the
five ways of working to ensure a balanced assessment is carried out
to implement the Well-being of Future Generations Act and the
Sustainable Development Principle. There may be occasions when
one benefit of a development proposal or site allocation outweighs
others, and in such cases robust evidence should be presented to
support these decisions, whilst seeking to maximise contributions
against all the well-being goals.”
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6.3.10 Paragraph 2.17 states that “in responding to the key principles for
the planning system, the creation of sustainable places and in
recognition of the need to contribute to the well-being of future
generations in Wales through placemaking, development plans and
development proposals must seek to deliver developments that
address the national sustainable placemaking outcomes.”
6.4 Future Wales: The National Plan 2040
6.4.1 Future Wales – The National Plan 2040 is Wales’ national
development framework which sets out the direction for
development in Wales to 2040. It is a development plan that sets
out a strategy for addressing key national priorities including
sustaining and developing a vibrant economy, achieving
decarbonisation and climate-resilience, developing strong
ecosystems and improving the health and wellbeing of our
communities.
6.4.2 The spatial strategy is a guiding framework which sets out the key
national policies that will guide and encourage development which
supports sustainable growth in both urban and rural areas across
Wales.
Policy 1 – Where Wales will grow
6.4.3 Policy 1 is the overarching policy which sets out where sustainable
growth will take place in Wales. Three National Growth Areas have
been established where there will 14 be growth in employment and
housing opportunities and investment in infrastructure. The
National Growth Areas are:
• Cardiff, Newport and the Valleys;
• Swansea Bat and Llanelli; and
• Wrexham and Deeside.
6.3.4 These National Growth Areas are complemented by Regional
Growth Areas, which will grow, develop and offer a variety of public
and commercial services at regional scale. There are Regional
Growth Areas in three regions:
• The South West;
• Mid Wales; and
• The North.
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6.3.5 In addition to the above growth areas, there are a mix of smaller
towns and villages and large areas of countryside. The policy states
that ‘development in towns and villages in rural areas will support
local aspirations and need, complementing rather than competing
with efforts to grow our cities and towns.’
Local Planning Policy
6.4 The proximity of the proposed housing allocation to the defined
settlement development limits for Broadway in the current Local
Development Plan 2006-2021 (LDP) is illustrated in the map extract
below, Figure (v).
Figure v – Proposals Map (LDP 2006-2021)

6.5 The proximity of the proposed housing allocation to the existing
village with its undefined boundaries in the 2
nd Deposit Revised
Carmarthenshire Local Development Plan (LDP) is illustrated in the
map extract below, Figure (vi).
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Figure vi – Proposals Map (Revised LDP 2018-2033)
7 Detailed Consideration
7.1 It is asserted that the incorporation of defined settlement limits for
Broadway would be compatible with Strategic Policy SP3 of the
revised LDP which seeks to ensure the provision of growth and
development is directed to sustainable locations in accordance with
the spatial framework.
7.2 Given the close proximity of Broadway to the to the town of
Laugharne which is classed as a Tier 2 Service Centre, it is asserted
that Broadway could potentially play an important role in facilitating
any future growth which would assist in sustaining Laugharne as a
recognised service centre.
7.3 Given the well documented physical constraints associated with
Laugharne, particularly its location with a C2 Flood Zone together
with the topography of the surrounding area, evidently there is no
scope whatsoever to accommodate any further housing. The DAM
map extract below (Figure vii) highlights the extent of the flooding
hazard.
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Figure vii – DAM Map extract (Source:NRW)
7.4 In contrast, Broadway, in occupying an elevated position is well
placed to accommodate any future residential development which
would be of significant benefit given its close links to Laugharne. The
proximity of the housing site being promoted as part of this
representation, to both Broadway and Laugharne, means ISA
Objective 1 (Sustainable Development) is satisfied in this instance.
7.5 It is asserted that the consequence of not allowing any future
housing expansion to be accommodated within Broadway would
have a negative impact on the township of Laugharne itself.
7.6 It is considered the highlighted land for potential residential
development represents a sustainable location given its close
proximity to existing housing in Broadway as well as its proximity to
Laugharne which is classed as a Service Centre in Strategic Policy SP3
of the LDP.
7.7 Natural Resources Wales Development Advice Maps indicate that
the land does not lie within a Zone C1 or C2 flood area as defined by
the development advice maps referred to in Technical Advice Note
15, Development and Flood Risk (TAN 15), as illustrated in the DAM
extract below (Figure ix).
7.8 TAN15 states that new development should be directed away from
Zone C and towards zone A, otherwise to zone B, where river or
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coastal flooding will be less of an issue. The site is not considered to
be at risk of flooding during at least the 1 in 1000 year event.
7.9 The development advice maps supplemented by sediment data,
held by the British Geological Survey (BGS), of historical flooding.
The maps adopt a precautionary principle and are based on the best
known information available at the time. It is noted that the NRW
flood maps show the site as being flood free during the Q100 event
and Q1000 event.
Figure ix – DAM Map
7.10 The Flood Map for Planning Wales also indicates that the rear of the
land subject of this representation is at risk from localised or surface
water flooding; this is illustrated on the FMfP extract below (Figure
x).
7.11 However, the intention would be to develop along the front part of
the site as this part of the site falls outside of Flood Zone 2 and Flood
Zone 3, as such falls within and an area deemed at low flood risk
from rivers. The land will not be affected during the 1 in 1000 fluvial
(Q1000 event or 0.1% event) and would also be flood free during
the 1 in 100 (Q100) flood event.
The Site
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Figure x – FMfP
7.12 The land does not fall within a C1 or C2 flood risk zone as delineated
by TAN15 DAM flood maps. Neither does the part of the site to be
developed fall within a Flood Zone 2 or Flood Zone 3 as delineated
by FMfP (Flood Map for Planning Wales). As such, ISA Objective 4
(Climatic Factors) and ISA Objective 5 (Water) are both satisfied in
this instance.
7.13 The land is not located within or immediately any of the following
designated sites:
• Sites of Special Scientific Interest (SSSI)
• Special Areas of Conservation (SAC)
• Special Protection Areas (SPA)
• National Nature Reserves (NNR)
• Local Nature Reserves (LNR)
• Common Land or registered village green
As such, ISA Objective 2 (Biodiversity) is satisfied in this instance.
7.14 The land is not located within or immediately adjacent to any
Scheduled Monuments. As such, ISA Objective 8 (Cultural Heritage
and Historic Environment) is satisfied in this instance.
7.15 The proposed inclusion of additional land within the redefined
settlement development limits is deemed appropriate at this
location in that it would not impact on any core planning principles.
The land would be located immediately adjacent to existing
residential dwellings, and would represent a natural rounding off
the existing built form.
Land under consideration
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7.16 It is asserted that the addition of further residential plots would not
lead to unacceptable ribbon development as it is sited within a
defined and mature hedgerow boundary. It would not be deemed
tandem development, it would not lead to unacceptable
coalescence of settlements and it cannot be described as
unacceptable sporadic development or an unacceptable extension
to the settlement. If anything the inclusion of these house along
with the vacant plot represents a logical extension do the
settlement.
7.17 In addition it would not result in the loss of areas of public open
space or formal recreational land. Given the aforementioned, it is
asserted that the development would not be contrary to general
planning principles.
7.18 Additional residential plots would sit comfortably at this location
without having any detrimental impact whatsoever on the character
or setting of the settlement. Furthermore, the development would
not have any detrimental impact on any features of the settlement
such as landscapes, townscapes or buildings of importance as a
result of its scale, density and prominence. As such, ISA Objective 8
(Cultural Heritage and Historic Environment) along with ISA
Objective 9 (Landscape) are both satisfied in this instance.
7.19 The proposal would not involve the re-use of suitable previously
developed land, hence it is acknowledged that the land is a
greenfield site, as such, ISA Objective 7 (Soil) is not satisfied in this
instance.
7.20 The site has a road frontage boundary that fronts onto the A4066.
As such, the site is readily accessible from the existing public
highway. The site has existing and established entrances with
adequate visibility splays, which allows direct access into the site
from the adjacent highway.
7.21 The map below (Figure xi) illustrates the number of crashes in the
immediate vicinity of the site.
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Figure xi (Source:Crashmap.co.uk)
7.22 Data obtained from Crashmap.co.uk confirms that in the last 10
years, there have been no slight, serious or fatal crash incidents
along this part of the A4066 County Road. This would suggest that
there are no highway issues relating to the site or the public road(s)
which serve the site.
7.23 The site lies in very close proximity to National Cycle Network Route
4, which is approximately 1km away. This proximity of the site to
this cycle route is illustrated on the Sustrans National Cycle Network
Map extract below (Figure xii).
Figure xii (Source:Sustrans)
7.24 The site is readily accessible to a local bus services (First Cymru
South & West Wales) Route. There’s a regular bus service which
links the village to Laugharne and commercial centres beyond.
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7.25 It is considered the site has suitable access to public transport as
well as identified active travel routes, as such, satisfies the following
ISA Objectives; ISA 3 (Air Quality), ISA 4 (Climatic Factors), ISA 6
(Material Assets), ISA 12 (Health & Well-being), ISA 13 (Education
s& Skills), ISA 15 (Social Fabric).
7.26 Given its location, the site lies immediately adjacent to an accessible
green space. In addition, the site is very accessible to an identified
recreation play area in the settlement of Laugharne. As such, it is
considered the site satisfies ISA Objective 12 (Health & Well-being)
and ISA Objective 15 (Social Fabric) .
7.27 The site along with the existing houses are within a reasonable
walking distance of a number of retail and employment provisions;
and services and facilities that can be found in Laugharne service
centre. Whilst the site occupies a rural location, it represents a very
sustainable location given its close proximity to the service centre.
As such, the site satisfies the following ISA Objectives; ISA 6
(Material Assets), ISA 10 (Population), ISA 14 (Economy), ISA 15
(Social Fabric).
7.28 The site represents a sustainable location in terms of its proximity
to nearby nursery schools and Primary School. As such, ISA
Objective 13 (Education & Skills) is satisfied in this instance.
7.29 The site is not located within or adjacent to a mineral buffer zone,
as such, ISA Objective 6 (Material Assets) is satisfied in this instance.
The site is not located within a Mineral Safeguarding Area, as such,
ISA Objective 6 (Material Assets) is satisfied in this instance. The site
is not located within or immediately adjacent to an a Air Quality
Management Area (AQMA), as such, ISA Objective 3 (Air Quality) is
satisfied in this instance.
7.30 The site does not contain high carbon e.g. peatlands, as such, ISA
Objective 7 (Soil) is satisfied in this instance. The site does not
contain high quality agricultural land (grades 1,2 or 3A, as identified
within the Agricultural Land Classification Maps). As such, ISA
Objective 7 (Soil) is satisfied in this instance.
7.31 The site is not located within or immediately adjacent to any
Regionally Important Geological or Geomorphological Sites. As
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such, ISA Objective 9 (Landscape) is satisfied in this instance.
7.32 The site is located within close proximity to a viable water
connection and is also located within close proximity to other viable
infrastructure requirements such as electricity and main sewer.
7.33 The site is not located within or adjacent to a phosphate sensitive
SAC catchment. A such, As such, the site satisfies the following ISA
Objectives; ISA 2 (Biodiversity), ISA 5 (Water) & ISA 7 (Soil).
7.34 The site by virtue of its scale and location, would not have the
potential to have a detrimental impact on the Welsh Language. As
such, ISA Objective 11 (Welsh Language) is satisfied in this instance.
7.35 The traffic movements associated with additional residential plots
will be marginal and the development could be accommodated on
the highway network and will not have a detrimental impact on the
free flow of traffic due to the existing volumes of traffic using the
local highway network. There are no access or transport constraints
to prevent the development of the site for residential purposes.
7.36 It is asserted that owing to the nature of the development proposal
being advanced, the development has due regard to the existing
built form and also character and appearance of the surrounding
area. Careful consideration has been given to the proposed layout
to ensure the relationship between the proposed dwelling and
existing development in close proximity is acceptable.
7.37 It is not disputed that the siting of an additional dwellings at this
location would introduce built form at an otherwise undeveloped
site. However, the dwellinsg would not represent a prominent or
conspicuous form of development. While the proposed
development would inevitably change the character of the site
itself, the proposed changes would not be to the extent that would
result in an unacceptable impact on the surrounding landscape.
7.39 Given the aforementioned, it is considered that any resulting
development would not be inappropriate or disproportionate in
scale. It is on this basis that it is considered that the proposal would
represent a sensitive form of development, commensurate with the
existing built form, hence would not adversely affect the spatial
character of the village.
7.40 The development would not have a significant impact on the
amenity of adjacent land uses, properties, residents or the
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community. The impact on the amenity of nearby residents has
been fully considered and duly discounted, particularly given the
separation distance between the site and the nearest residential
properties.
7.41 Overall, the proposed development would satisfy PPW’s objective
of achieving sustainable development both by ensuring that the
local community has access to sufficient housing and affordable
options whilst also working to facilitate a modal shift to more
sustainable methods of transport and reducing car borne journeys.
8 Summary and Conclusion
8.1 This Planning Statement has been completed on behalf of Gwyn
Lewis and provides planning support for the inclusion of additional
land in the revised Local Development Plan to accommodate
potential residential development in Broadway.
8.2 It has been established that the principle of residential development
is compliant with both national and local policy and represents an
acceptable form of infill development at this location. The
development would assist with the housing land supply situation in
the county.
8.3 While residential development at this location would inevitably
change the character of the site itself, the proposed change would
not result in an unacceptable impact on the surrounding landscape
nor would they have an adverse impact on the existing neighbouring
development, highway network or local infrastructure.
8.4 In conclusion, it has been demonstrated that there are significant
material considerations weighing in favour of the inclusion of the
existing group of dwellings along with the inclusion of one additional
site for residential development in the upcoming revised local plan.

Amend Plan to include the site

The Plan is currently unsound as it fails to allocate land at Maesarddafen Road/ Erw Las, Cefncaeau provide for residential development. The Plan is therefore not considered to be appropriate or effective.

Please refer to the accompanying cover letter and related enclosures for further details.

Cover letter:

I write on behalf of our client, Tata Steel Europe Limited (Tata Steel), in response to the current Carmarthenshire Second Deposit Revised Local Development Plan (RLDP) Consultation.

INTRODUCTION
Tata Steel owns and operates the Trostre Steel Works and owns Land at Maesarddafen Road/ Erw Las, Cefncaeau, which is allocated in the adopted Carmarthenshire Local Development Plan (2014) for residential development of 300 dwellings (site reference GA2/h35).
Part of this site (Land at Maesarddafen Road) was granted outline planning permission (reference: S/34991), for a residential development of up to 94 units on 7 March 2022. This permission remains extant. The Second Deposit RLDP includes this site as a proposed residential allocation (PrC2/H15).
An outline planning application for residential development is currently being considered by your Authority for the remaining land at Erw Las, which forms part of the current LDP allocation (GA2/h35). The application (reference: PL/05187) was registered on 29 December 2022 and the description of development is:
“The erection of new residential dwellings, vehicular access, open space and other associated infrastructure.”
Dialogue with the Council regarding this application is ongoing and we hope that it will be positively determined shortly.

The land in Tata Steel’s control at Erw Las, which forms part of the current LDP allocation (GA2/h35), is not retained as a residential allocation in the emerging RLDP.
Accordingly, the representations set out below:
• Provide support for the proposed residential allocation at Maesarddafen Road (PrC2/H15).
• Object to the failure to allocate land at Erw Las, Cefncaeau for residential development. A Sustainability Appraisal relating to this site, along with a site location plan accompanies this submission.
• Provide commentary on Policy EME1: Employment- Safeguarding of Employment Sites and request clarification of the policy wording.
Our detailed representations in relation to the RLDP are set out below. A copy of the requisite response form is also attached.

SUPPORT FOR POLICY HOM1 ALLOCATION PRC2/H15 – LAND AT MAESYRDDAFEN ROAD
Our client strongly supports the proposed residential allocation PrC2/H15 (Land at Maeryrddafen Road, Llanelli). The proposed allocation provides for approximately 94 new homes on the site.
The proposed allocation reflects that the site benefits from an extant outline planning permission for a residential development of up to 94 dwellings. This permission is dated 7 March 2022. The Council’s approval of this application clearly demonstrates the suitability and acceptability of the proposed development for residential development.
Carmarthenshire County Council’s Committee Report for the application (S/34991, dated 19 March 2019) confirms that the principle of development of the site is acceptable and the proposal complies with key planning policies and sustainability objectives.

The Committee report confirms that:
‘The site is well integrated with the existing pattern of development in Llwynhendy and is capable of accommodating a development of the scale and density proposed without compromising the quality of the scheme or detracting from the character and appearance of the surrounding area. The development will provide a wide range and choice of housing types and sizes which will be well related to the existing services and facilities in the wider Llanelli area as well as being within easy access of a variety of sustainable modes of transport. It will also contribute to the improvement of educational, open space and pedestrian and cycling facilities in the surrounding area. The level of contributions secured are considered to be commensurate with the scale and nature of the development.

In addition, the development satisfies the sustainability requirements of the LDP from an environmental quality and utility provision perspective by implementing a drainage strategy that will dispose of foul and surface water in a sustainable and controlled manner as well as providing betterment to the capacity of the public sewerage system. Furthermore, and as outlined in the appraisal above, there are no highway, amenity, or ecological objections to the development.’ (Page 13)
The conclusions drawn in granting outline planning permission remain unchanged when considered against national planning policy/guidance and the emerging RLDP. The site remains well integrated to the existing pattern of development, accessible to a range of sustainable modes of transport and capable of accommodating the scale and density of new homes proposed.

The site has been marketed by Harris Lamb Property Consultancy and offers have been received. We understand that discussions are progressing and Tata Steel has entered into an exclusivity period with a preferred developer. This demonstrates that the site is viable and deliverable in the short term.
POLICY HOM1: HOUSING ALLOCATIONS
Whilst supportive of the proposed allocation at Maeryrddafen Road, Llanelli (PrC2/H15) through Policy HOM1 (as set out above), our client strongly objects to the failure to allocate land at Erw Las, Cefncaeau for residential development.
The proposed site (see attached plan) forms part of a wider allocation within the adopted LDP (alongside land at Maesyrddafen Road) for a development of 300 residential homes (GA2/h35). As outlined above, the Council has already granted outline planning permission for up 94 units on part of this allocated site (application reference: S/34991 – land at Maesyrddafen Road). Whilst land at Maesyrddafen Road is proposed as an allocation in the RLDP, the remaining land within Tata Steel’s control at Erw Las is not carried forward as a proposed allocation.

Our client strongly supports the continued allocation of land at Erw Las for residential development. This would provide for additional new homes to come forward on a sustainable site, which is currently allocated in the adopted LDP.
The site is subject to an outline planning application for residential development (application ref: PL/05187) which was registered on 29 December 2022 and is currently being considered by Carmarthenshire County Council. We hope that the application will be determined positively shortly.
The plans and suite of supporting technical documents submitted alongside the application demonstrate that there are no significant constraints that would prevent the development of the site for the proposed use and confirm that the development complies with relevant planning policy.

Interest from the market has been received in relation to the site at Erw Las. This demonstrates that the site is both viable and deliverable in the short term.
In summary, Tata Steel wish to see its land at Erw Las retained as an allocation for residential development of circa 100 dwellings. The land holding (and existing allocation) also includes residual land which provides the opportunity to bring forward a considerable area of new public open space and green infrastructure.
Sustainability Appraisal
Accompanying this submission is a Integrated Sustainability Appraisal for the proposed site at Erw Las, Cefncaeau. The Sustainability Appraisal follows the template provided within the Council’s ‘Integrated Sustainability Appraisal (ISA) Guide for Promoters of Sites for Development’ (February 2023).
The appraisal confirms that the site represents a sustainable development option. The Integrated Sustainability Appraisal does not raise any significant constraints beyond those that could be mitigated through the detailed design of the development.
The technical documents prepared to support the outline planning application (application reference: S/34991) further establish the suitability of the site to provide residential development.
The site is also well served by good quality pedestrian routes and public footpaths providing links to the centre of Llanelli. A play area and area of open space is located directly to the north of the site to the rear of Tir Einon. The site is within walking distance of existing bus stops on Heol Hen, Maes Ar Ddafen Road and Llwynhendy Road, providing access to a range of destinations within Llanelli and further afield, including Llanelli Town Centre and the Trostre and Pemberton Retail Parks.
In addition to the Trostre and Pemberton Retail Parks, a range of services and facilities are located along Llwynhendy Road. A range of key services and facilities are therefore located within a 300-1500m walk of the site, ensuring the site has good accessibility.
Furthermore, there are clear similarities between the assessment of the allocated site at Maesyrddafen Road and the proposed site at Erw Las. Both sites were considered jointly in the adopted LDP and form a single allocation, acknowledging the close physical and functional relationship between the two sites, which includes a footpath running between the sites. It is considered that the land at Erw Las land performs as well as the proposed allocation at Maesyrddafen Road.
The land controlled by Tata Steel at Erw Las would provide a viable and deliverable allocation that could be brought forward quickly. As demonstrated above, a significant amount of technical work has been completed to support the outline planning application, confirming that the site is not impeded by significant technical constraints. The site could therefore be brought forward swiftly, contributing to the continuous supply of deliverable sites and thereby helping to address the identified need for new housing.
The development of the site will also help to sustain and enhance the existing services and facilities available within Llanelli, resulting in a wide range of spin-off benefits for the local community.

POLICY EME1: EMPLOYMENT- SAFEGUARDING OF EMPLOYMENT SITES
The Tata Steel owned Trostre Steelworks is designated within the RLDP as an existing employment area through Strategic Policy 7 (SP7): Employment and the Economy. Policy SP7 recognises the contribution of existing employment sites as part of the employment portfolio in meeting ongoing need.
Policy EME1 safeguards sites identified for employment purposes for such uses (specifically Class B1, B2 and B8 uses). Our client welcomes the designation of the Trostre Steelworks as an existing employment site. Tata also welcome the support for employment related proposals within this area as provided by both Policy EME1 and EME2, which allows for the extension and / or intensification of existing employment enterprises.
Policy EME1 sets out criteria where, exceptionally, proposals which result in the loss of employment sites is acceptable. The wording to that policy does not make it clear whether all or some of the criteria need to be met. This should be clarified. It is considered that only some of the criteria would need to be met as not all the criteria would be relevant to every proposal.
Support is, however, given to criterion (f) of Policy EME1 which allows uses which are complementary to the primary employment use of the surrounding area. This recognises that non B-class uses and ancillary uses can be appropriate for locations within an employment site. Examples (not exhaustive) of such uses could include those relating to education or visitor centres.

Summary
I trust that the above representations assist and changes are made to reflect the position of Tata Steel in the preparation of the Plan as it progresses.
I would be grateful if Turley/Tata can be kept informed of future stages of the emerging Revised Carmarthenshire Local Development Plan.
If you require any further information please do not hesitate to contact me.

Allocate site for housing in Revised LDP.

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

Include site within the Plan.

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

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

3 Client Details
3.1 The clients are Richard and Catrin Safadi of Glannant, Idole,
Cwmffrwd, Carmarthen.

4 The Site
4.1 The site is an irregular shaped piece of land forming part of a field
enclosure immediately adjacent to the village of Idole. The site is
predominantly pastureland and is relatively flat in nature. The field
fronts onto Heol y Lan (U2206) and lies just south of the road
junction with the A484 Trunk Road. The site is bounded by mature
hedgerows along its western, southern and northern boundaries.
4.2 The site lies directly opposite a row of dwellings at the northern end of the Idole as illustrated on the map extract below (Figure i).
4.3 Whilst the site currently occupies an open countryside location, it lies in close proximity to a predominantly residential area within the settlement of Idole. The proximity of the site to nearby residential dwellings is shown on the aerial photograph below (Figure ii).
4.4 The site is essentially a greenfield site, however, given the residential dwellings immediately south (Bryndolau) and just north (Glannant), it can also be described as an infill site.
4.5 Vehicular access into the site is currently gained via the existing field entrance which comes directly off the adjacent public highway.

5 The Development
5.1 The aim of the development would be to provide 5 residential plots, fronting directly onto Heol y Lan, with indicative plans illustrating a suggested site layout.
5.2 The site plan extract below (Figure iii) illustrates the indicative layout.

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

7 Detailed Consideration
7.1 As highlighted in the Integrated Sustainability Appraisal (ISA), it is asserted that the site is deemed compatible with Strategic Policy SP3 of the revised LDP which seeks to ensure the provision of growth and development is directed to sustainable locations in accordance with the spatial framework.
7.2 Given its proximity to nearby villages such as Banc y Capel, Cwmffrwd and Croesyceiliog, together with the fact that it is only 2 miles south-east of Carmarthen, Idole is identified as a Cluster 1, Tier 3 – Sustainable Village within the Settlement Framework. As such, ISA Objective 1 (Sustainable Development) is satisfied in this instance.
7.3 As illustrated on the indicative plan below (Figure vi), the site can potentially accommodate five dwellings.
7.4 The site is directly related to the identified settlement of Idole. Idole is classed as a Tier 3 Sustainable Village in Strategic Policy SP3 of the LDP
7.5 Natural Resources Wales Development Advice Maps indicate that the site does not lie within a Zone C1 or C2 flood area as defined by the development advice maps referred to in Technical Advice Note 15, Development and Flood Risk (TAN 15), as illustrated in the DAM extract below (Figure vii).
7.6 TAN15 states that new development should be directed away from Zone C and towards zone A, otherwise to zone B, where river or coastal flooding will be less of an issue. The site is not considered to be at risk of flooding during at least the 1 in 1000 year event.
7.7 The development advice maps supplemented by sediment data, held by the British Geological Survey (BGS), of historical flooding. The maps adopt a precautionary principle and are based on the best known information available at the time. It is noted that the NRW flood maps show the site as being flood free during the Q100 event and Q1000 event.
The Site
7.8 The Flood Map for Planning Wales also indicates that the site is not at risk from localised or surface water flooding; this is illustrated on the FMfP extract below (Figure viii). The Flood Risk Map below demonstrates that the site falls outside of Flood Zone 2 and Flood Zone 3, as such falls within and an area deemed at low flood risk from rivers. The site will not be affected during the 1 in 1000 fluvial (Q1000 event or 0.1% event) and would also be flood free during the 1 in 100 (Q100) flood event.
7.9 The site does not fall within a C1 or C2 flood risk zone as delineated by TAN15 DAM flood maps. Neither does it fall within a Flood Zone 2 or Flood Zone 3 as delineated by FMfP (Flood Map for Planning Wales). As such, ISA Objective 4 (Climatic Factors) and ISA Objective 5 (Water) are both satisfied in this instance.
7.10 The site is not located within or immediately any of the following designated sites:
• Sites of Special Scientific Interest (SSSI)
• Special Areas of Conservation (SAC)
• Special Protection Areas (SPA)
• National Nature Reserves (NNR)
• Local Nature Reserves (LNR)
• Common Land or registered village green
As such, ISA Objective 2 (Biodiversity) is satisfied in this instance.
The Site
7.11 The site is not located within or immediately adjacent to any Scheduled Monuments. As such, ISA Objective 8 (Cultural Heritage and Historic Environment) is satisfied in this instance.
7.12 The proposed development is deemed appropriate at this location in that it would not impact on any core planning principles. The proposed development would be sited immediately opposite a row of existing residential dwellings and also between two existing residential properties, namely Glannant and Bryndolau. The map extract below (Figure ix) illustrates the existing pattern of development at this part of the village
7.13 Clearly the development would not lead to unacceptable ribbon development; it would not be deemed tandem development. It would not lead to unacceptable coalescence of settlements and given its siting between existing properties it would be classed as a form of infill, as such, cannot be described as unacceptable sporadic development or an unacceptable extension to the settlement. In addition it would not result in the loss of areas of public open space and formal recreational land. Given the aforementioned, it is
asserted that the development would not be contrary to general planning principles.
7.14 The development would sit comfortably at this location without having any detrimental impact whatsoever on the character or setting of the settlement. Furthermore, the development would not have any detrimental impact on any features of the settlement such as landscapes, townscapes or buildings of importance as a result of its scale, density and prominence. As such, ISA Objective 8 (Cultural Heritage and Historic Environment) along with ISA Objective 9 (Landscape) are both satisfied in this instance.
7.15 The proposal will not involve the re-use of suitable previously developed land, hence, it is acknowledged that the site is a greenfield site, as such, ISA Objective 7 (Soil) is not entirely satisfied in this instance. The site has a road frontage boundary that fronts onto an Unclassified Road (U2206) also known as Heol y Lan. As such, the site is readily accessible from the existing public highway. The site has an existing and established field entrance with adequate visibility splays, which allows direct access into the site.
7.16 Heol y Lan is not a through-road as such, and is a relatively quiet road which primarily serves Maes Dolau residential estate as well as 10 residential properties fronting directly onto the road. The road junction onto the A484 Trunk Road is also served by adequate visibility splays. The map below (Figure x) illustrates the number of crashes in the immediate vicinity of the site.
7.17 Data obtained from Crashmap.co.uk confirms that in the last 10 years, there have been no slight, serious or fatal crash incidents along Heol y Lan or at the A484 Road junction. This would suggest that there are no highway issues relating to the site or the public road(s) which serve the site.
7.18 The site lies in close proximity to National Cycle Network Route 4, which is approximately 1.5km away. This is illustrated on the Sustrans National Cycle Network Map extract below (Figure xi).
7.19 In addition, the site would be very accessible to an identified future cycling route (Cycle Route Ref K13 on the Active Travel Network Map), as annotated in green on the plan extract below (Figure xii).
7.20 The site is readily accessible to a local bus services (First South & West Wales) Route No. X11, with the nearest bus stop less than a 1 minute walk away. The bus journey to Carmarthen takes approximately 21 minutes as illustrated below (Figure xiii).
7.21 It is considered the site has suitable access to public transport as well as identified active travel routes, as such, satisfies the following ISA Objectives; ISA 3 (Air Quality), ISA 4 (Climatic Factors), ISA 6 (Material Assets), ISA 12 (Health & Well-being), ISA 13 (Education s& Skills), ISA 15 (Social Fabric).
7.22 Given its location within a field enclosure, the site lies immediately adjacent to an accessible green space. In addition, the site is very accessible to an identified play area in the settlement of Idole. The play space identified on the LDP Proposals Map is approximately 375 metres away which represents a reasonable walking distance. As such, it is considered the site satisfies ISA Objective 12 (Health & Well-being) and ISA Objective 15 (Social Fabric) .
7.23 The plan extract below (Figure xiv), taken from the LDP Proposals Map highlights the proximity of the site to the identified play space in the village of Idole.
7.24 The site is within a reasonable walking distance of the following employment/retail provisions, services and facilities found in the settlement of Idole itself:
• Cywion Back Nursery (former primary school);
• Chapel Bridal Shop
7.25 Other provisions/services/facilities within a reasonable driving distance (approx. 5 minutes) can be found in nearby settlements such as Banc y Capel, Cwmffrwd and Croesyceiliog. These include the following:
• Banc y Capel Chapel
• Capel Annibynnol Penygraig
• Seventh Day Adventist Church
• Bee Hire Vehicle rental
• AC Aggregates Suppliers
• GD Harries Concrete works
• Methirinfa Bambinos Nursery
• St Annes’s Church
• OC Davies Used Car dealer
7.26 Moreover, whilst the settlement of Idole clearly occupies a rural location, it represents a sustainable location given its proximity to the retail centre at Pensarn, which is approximately 3 km away, and also given its proximity to the market town of Carmarthen, which is approximately 4 km away.
7.27 It is considered the site is within a reasonable distance of a number of employment and retail provisions as well as other local services and facilities, given its proximity to Carmarthen, Pensarn and Llangunnor. As such, the site satisfies the following ISA Objectives; ISA 6 (Material Assets), ISA 10 (Population), ISA 14 (Economy), ISA 15 (Social Fabric).
7.28 The site represents a sustainable location in terms of its proximity to two nearby nursery schools (Cywion Bach and Meithrinfa Bambinos). The site is also within a reasonable distance of Ysgol Gymraeg Bro Myrddin (2km) and Llangunnor Primary School (3.5km). As such, ISA Objective 13 (Education & Skills) is satisfied in this instance.
7.29 The site is not located within or adjacent to a mineral buffer zone, as such, ISA Objective 6 (Material Assets) is satisfied in this instance. The site is not located within a Mineral Safeguarding Area, as such, ISA Objective 6 (Material Assets) is satisfied in this instance. The site is not located within or immediately adjacent to an a Air Quality Management Area (AQMA), as such, ISA Objective 3 (Air Quality) is satisfied in this instance.
7.30 The site does not contain high carbon e.g. peatlands, as such, ISA Objective 7 (Soil) is satisfied in this instance. The site does not contain high quality agricultural land (grades 1,2 or 3A, as identified within the Agricultural Land Classification Maps). As such, ISA Objective 7 (Soil) is satisfied in this instance.
7.31 The site is not located within or immediately adjacent to any Regionally Important Geological or Geomorphological Sites. As such, ISA Objective 9 (Landscape) is satisfied in this instance.
7.32 The site is located within close proximity to a viable water connection and is also located within close proximity to other viable infrastructure requirements such as electricity and main sewer.
7.33 The site is not located within or adjacent to a phosphate sensitive SAC catchment. A such, As such, the site satisfies the following ISA Objectives; ISA 2 (Biodiversity), ISA 5 (Water) & ISA 7 (Soil).
7.34 The site by virtue of its scale and location, would not have the potential to have a detrimental impact on the Welsh Language. As such, ISA Objective 11 (Welsh Language) is satisfied in this instance.
7.35 The traffic movements associated with the development proposal will be marginal and the development could be accommodated on the highway network and will not have a detrimental impact on the free flow of traffic due to the existing volumes of traffic using the local highway network. There are no access or transport constraints to prevent the development of the site for residential purposes.
7.36 It is asserted that owing to the nature of the development proposal being advanced i.e. 5 dwellings, the development has due regard to the existing built form and also character and appearance of the surrounding area. Careful consideration has been given to the proposed layout to ensure the relationship between the proposed dwellings and existing development in close proximity is acceptable. It is considered 5 road frontage plots would conform with the character and appearance of the immediate area in terms of siting.
7.37 It is not disputed that the siting of five dwellings at this location would introduce built form at an otherwise undeveloped site. However, the dwellings would not represent a prominent or conspicuous form of development. While the proposed development would inevitably change the character of the site itself, the proposed changes would not be to the extent that would result in an unacceptable impact on the surrounding landscape.
7.38 The development would not be readily visible from the wider area; the mature trees and vegetation along the site boundaries would, to a degree, mitigate any visual impact.
7.39 Given the aforementioned, it is considered that any resulting development would not be inappropriate or disproportionate in scale. It is on this basis that it is considered that the proposal would represent a sensitive form of development, commensurate with the existing built form, hence would not adversely affect the spatial character of the village.
7.40 The development would not have a significant impact on the amenity of adjacent land uses, properties, residents or the community. The impact on the amenity of nearby residents has been fully considered and duly discounted, particularly given the separation distance between the site and the nearest residential properties.
7.41 Overall, the proposed development would satisfy PPW’s objective of achieving sustainable development both by ensuring that the local community has access to sufficient housing and affordable options whilst also working to facilitate a modal shift to more sustainable methods of transport and reducing car borne journeys.

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

Allocate the site for housing and include within the development limits for Ammanford.

This representation objects to the exclusion of this site from the development limits for Ammanford. Its inclusion would not lead to additional environmental pressure, but instead will foster sustainable growth and allow for a wider choice of housing type within this Tier 1 Principal Centre. Its development would be in keeping and in character with the settlement and will ensure a deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints and its delivery is assured.
A full description of the site's development potential and merits has previously been provided in the candidate site submission, to which reference should be made.
It is considered that this site is both more sustainable and deliverable than those other sites that have been allocated within Ammanford.
The inclusion of this land within revised development limits would be fully supported.

Include site within the Plan.

This representation objects to the exclusion of this site from the development
limits for Capel Dewi – a designated Tier 3 Sustainable Village. Its inclusion
would not lead to additional environmental pressure, but instead will foster
sustainable growth and allow for a wider choice of high quality housing types.
Its development would be in keeping and in character with the settlement and
will be in a manner which ensures development is well-related to the nucleus
of the village rather than incremental extensions in the form of ribbon
development along the highways. Its inclusion will ensure a deliverable source
of future housing for this sustainable community.
There is a residential allocation for Capel Dewi within the 2nd Deposit LDP
(SuV16/h1) but which has been largely completed and thus, during the plan
period, there will be little opportunity for other housing development to take
place.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature
conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood
risk, hydrological, ecological, archaeological or land ownership related
constraints and its short term delivery is assured.
It is considered that this site is both sustainable and readily deliverable and
offers a valuable development option within this Tier 3 Sustainable Village.
The inclusion of this land within revised development limits would be fully
supported.

Allocate for housing and include within the development limits for Ammanford.

This representation objects to the exclusion of this site from the development limits for Ammanford. Its inclusion would not lead to additional environmental pressure, but instead will foster sustainable growth and allow for a wider choice of housing type within this Tier 1 Principal Centre. Its development would be in keeping and in character with the settlement and will ensure a deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints and its delivery is assured.
A full description of the site's development potential and merits has previously been provided in the candidate site submission, to which reference should be made.
It is considered that this site is both more sustainable and deliverable than those other sites that have been allocated within Ammanford.
The inclusion of this land within revised development limits would be fully supported.

Amend the site within the Plan

The residential allocation of land for the Northern development of Llandeilo at map reference 51.887955 , -3.995920 should revert back to full area included in the previous LDP.
The reduction in residential allocation has removed the proposed access point from the A483 to any development. Without this point of access, the only route into the development area will be through the existing estate of Parc Pencrug. This would promote piecemeal development of the northern area that would prevent the aims of PSD2: Masterplanning Principles – Creating Sustainable Neighbourhoods to be met.

Allocate the site for housing within the Revised LDP.

This representation objects to the exclusion of this site from the development
limits for Llandeilo, a designated Tier 2 Service Centre. The majority of this
site formed part of the ‘Llandeilo Northern Residential Quarter’ Planning and
Development Brief adopted as supplementary planning guidance to the
previous Carmarthenshire Unitary Development Plan.
The development of this site would be phased and would not be restricted to
merely residential use but would include a variety of uses. The full justification
for the site's inclusion within Llandeilo’s development limits is comprehensively
described in the aforementioned development brief. Multiple areas of strategic
landscaping and communal greenspace would be provided in order to enhance
local biodiversity and to offer open areas to residents to support physical and
mental well-being. The proposers consider that offering positive community
benefits is a key part of the scheme’s overall ethos.
The residential elements of the scheme would comprise a high quality
development and would draw on local Welsh vernacular architectural design
elements, making every effort to be sustainable, both through the
employment of local contractors and the use of local suppliers.
The inclusion of the proposer’s land would not lead to additional environmental
pressure, but instead will foster sustainable growth and allow for a wider
choice of housing type within this Tier 2 Service Centre. Its development
would be in keeping and in character with the settlement and will ensure a
readily deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature
conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood
risk, hydrological, ecological, archaeological or land ownership related
constraints and its short term delivery is assured.
A full description of the site's development potential and merits have
previously been confirmed in the aforementioned Planning and Development
Brief, to which reference should be made.
It is considered that this site is both sustainable and readily deliverable.
The inclusion of this land within revised development limits should be fully
supported.

Include site within Plan

This representation objects to the exclusion of this site from the development
limits for Ammanford. Its inclusion would not lead to additional environmental
pressure, but instead will provide the opportunity for an attractive, appropriate
development, thereby fostering sustainable growth and allowing a wider choice
of housing type within this Tier 1 Principal Centre. Its development would be in
keeping and in character with the settlement and will ensure a deliverable
source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature
conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood
risk, hydrological, ecological, archaeological or land ownership related
constraints and its delivery is assured.
It is considered that this site is both sustainable and readily deliverable and
offers a valuable development option within this Tier 1 Principal Centre.
The inclusion of this land within revised development limits would be fully supported.