HOM1: Dyraniadau Tai

Allocate the the site (comprising 3 enclosures) for housing in the Revised LDP.

There is a shortage of plots in Ammanford which is why part of [ILLEGIBLE] was included in the local plan but is not in the deposit LDP. We seek to include this land please.
This land meets eligibility criteria for sustainable development & has infrastructure for development and is within easy walking distance to the town. Details enclosed.

Include the site within Plan.

We are instructed by Mr B. O. Beynon 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/074/011, seeking the inclusion of their land within the development limits of Kidwelly as
part of the Replacement Local Development Plan.
The Candidate Site comprises a potential second phase of Housing Allocation SeC3/h4
“Dinas Yard”, being a series of immediately adjoining grazing fields, which shares a common
boundary with that future housing site, also located to the rear of Holloway Farm, and
extends near the rear of established properties fronting Stockwell Lane. Its extents are
illustrated by the site edged in red, being a site location plan, at Figure 1 below.
The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our clients’ submission, reasons why the site was not selected for inclusion within the draft
settlement limits of Kidwelly, 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), and Stage 2A (Initial Detailed Site Assessment). It however did not
proceed further than Stage 2b (Further Detailed Site Assessment) of the Council’s site
assessment. The Council have published reasons for non-inclusion, which are reported as
follows: “It is considered that there would be deliverability issues with this site, particularly
with the permission on the adjacent site which would cater for the needs of the settlement in
the long term.”
Figure 1 – Location plan of Candidate Site at Kidwelly
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 Kidwelly, 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 Kidwelly, as reproduced below in Figure 2. 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
- Location and indicative site layout plans
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits

1.0 Overall Housing Supply at Kidwelly within Deposit Draft

1.1 The Council consider that there are sufficient residential sites allocated elsewhere in the settlement, and they believe there would be deliverability issues, with the first phase of the former Dinas Yard site being sufficient to cater for future housing growth at Kidwelly. The Candidate Site borders Site Allocation SeC3/h4 which has the benefit of Approval of Reserved Matters, granted in June 2022, for a total of 71 dwellinghouses. The Candidate Site is seen as a logical second phase of that allocated site, with the proposed access estate road extending east from that development, which initially junctions off Pembrey Road.

1.2 The Council’s Assessment conclusions, suggest that they accept that the form of the Candidate Site set between the Kidwelly By-Pass and former railway line to Stockwell Lane is in accord with the spatial form and character of the settlement.

1.3 The proposals under this Representation seek the addition of circa 80 residential units to the overall housing supply of Kidwelly, which forms a Tier 2 Service Centre, being part of the Llanelli Cluster as defined within the draft LDP. Figure 3 below provides an extract of the indicative site layout plan for this Representation site.
Figure 3 – Indicative Site Layout plan of Representation Site

1.4 The Llanelli Cluster (Cluster 2) aims to provide an additional 3039 residential units
over the Plan period to 2033, with Kidwelly (Settlement SeC3) providing three
allocated sites at expected to provide a combined total of 115 units to that overall
Cluster total (reproduced at Figure 4 below). We would submit in the first instance
that the addition of an additional allocated site of 80 units will not lead to an oversupply
of dwellinghouses within the wider Llanelli Cluster settlement supply.
Figure 4 – Extract from Policy HOM1 for Kidwelly

1.5 We have examined and researched sites which have been brought forward as
Residential Allocations with the Deposit Draft. In Kidwelly, 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. Within the Draft Plan, we note the continued allocation of
Dinas Yard and land part of Holloway Farm, 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 6-10, being 2024 to 2028. Indeed, construction works will be commencing in Summer 2023 following the granting of Approval of Reserved Matters for 71 dwellinghouses.

1.6 However, we note that in the case of the other proposed allocation at “Llys Felin,” work is complete upon a first phase of 9 bungalows, with a further 15 units currently subject of a planning application. Site Allocation SeC3/h2 at “Land off Priory Street” is a new allocation for 20 units, having appeared as outside settlement limits in the 2014-adopted LDP, as reproduced at Figure 5 below.
Figure 5 - Extract of 2014-adopted LDP Proposal Map for Kidwelly

1.7 The current Development Plan Map for Kidwelly reveals the success of residential allocations in the town. Sites T3/3/h2, h6, h7 and h8 have all been completed or nearing completion, and site T3/3/h9 and h10 has Approval of Reserved Matters with a commencement imminent. Sites T3/3/h3, h4 and h5 do not have the benefit of planning permission, and it is noted have been omitted from the new Second Deposit Draft accordingly.

2.0 Llanelli, Burry Port, Hendy 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. Kidwelly 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 6 below provides an extract of such sites.
Figure 6 – 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. 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 45 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 forty 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. 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 80 units such as that proposed at Holloway Farm in Kidwelly. There is clear evidence that such moderately 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 CONCLUSION

3.1 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 80 dwellinghouses will not appear at odds to the prevailing spatial pattern of development in Kidwelly. 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 Holloway Farm is no different, resulting in it being respectful to the character and setting of the locality.

3.2 The Council must acknowledge that the costs in preparing, submitting and negotiating through to a positive decision for Approval Of Reserved Matters
demonstrates our client’s commitment to deliver housing allocations. The site will shortly be under construction with a regional housebuilder with a view to completion within two years, and thus the proposed Phase 2 will enable house building to continue into the latter years of the Replacement LDP Plan Period.
We respectfully request that this Representation be given careful examination, and consequently the defined settlement limits of this part of Kidwelly realigned to include the Representation Site, as a Residential Allocation in the Proposals Map of the adopted Local Development Plan.

Allocate the land for residential use.

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

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

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

4 The Site
4.1 The site consists of two broadly rectangular shaped blocks of land
which currently form part of field enclosures associated with
Coedmoelion Farm. Both Blocks of land front onto Greenfield
Terrace at the eastern end of the settlement of Pontyberem.
4.2 The block of land along the northern flank of Greenfield Terrace lies
between an established row of road frontage dwellings fronting
onto the adjacent highway. The site represents a gap measuring
approximately 90 metres in length between existing residential
properties.
4.3 In contrast, the block of land along the southern flank of Greenfield Terrace forms part of a wider gap between existing dwellings fronting onto the highway, however, the section of land immediately adjacent, to the west, has now been included in the revised settlement development limits for Pontyberem.
4.4 The site fronts directly onto Greenfield Terrace and is located within a predominantly residential area at the eastern edge of the settlement. The site lies approximately 300 metres east of Heol y Bryn.
4.5 Beyond the block of land on the northern flank of Greenfield Terrace, to the east, there consists a row of 12 residential dwellings, whilst beyond the block of land on the southern flank of the terrace, there are 5 dwellings to the east.
4.5 The proximity of the site to neighbouring dwellings and its proximity to the existing built form associated with this part of the village, particularly along Greenfield Terrace is illustrated on the map extract below (Figure i).
Figure i – Location Plan
4.6 Whilst the site currently occupies an open countryside location, it lies immediately adjacent to the settlement development limits associated with Pontyberem. The actual proximity of the site to the
predominantly residential area within the village is clearly shown on the aerial photograph below (Figure ii).
Figure ii – Aerial Photograph
4.7 The site is essentially a greenfield site, nevertheless, given the residential dwellings immediately west and east along Greenfield Terrace, it clearly represents an infill site within the immediate street context.
4.8 Vehicular access into the filed enclosures is currently gained via existing field entrances which come directly off the adjacent public highway.

5 The Development
5.1 The aim of the development advanced as part of this LDP representation would be to provide approximately 8 residential plots, fronting directly onto Greenfield Terrace, split equally along the northern and southern flanks of the road.
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.
The Site
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 Pontyberem in the current Local Development Plan 2006-2021 (LDP) is illustrated in the map extract below, Figure (v).
Figure v – Proposals Map (LDP 2006-2021)
6.5 The proximity of the site to the defined settlement development limits for Pontyberem in the 2nd Deposit Revised Carmarthenshire Local Development Plan (LDP) is illustrated in the map extract below, Figure (vi).
6.6 It is evident from the revised proposals map that the settlement development limits have been altered and reconfigured to include additional land along the southern flank of Greenfield Terrace.
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 Pontyberem which is classed as a Tier 2 Service Centre and its proximity to nearby villages such as Bancffosfelen, Tumble and Drefach, ISA Objective 1 (Sustainable Development) is satisfied in this instance.
7.3 As illustrated on the indicative plan below (Figure vii), the site can potentially accommodate eight dwellings which would equate to 4 dwellings either side of Greenfield Terrace.
Figure vii – Indicative Plot Layout Plan
7.4 The site is directly related to the identified settlement of Pontyberem. As illustrated on the previous location plan (Figure i), the site represents a sustainable location given its close proximity to Pontyberem, which falls within the Ammanford/Cross-Hands cluster and is classed as a Service Centre in Strategic Policy SP3 of the LDP.
7.5 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 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 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
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 proposed development would be sited immediately adjacent to existing residential dwellings and would represent an infill form of development between an established row of houses. 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.
The Site
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 would not involve the re-use of suitable previously developed land, hence it is acknowledged that the land is a greenfield site, as such, ISA Objective 7 (Soil) is not satisfied in this instance.
7.16 The site has a road frontage boundary that fronts onto an Greenfield Terrace. As such, the site is readily accessible from the existing
public highway. The site has existing and established entrances with adequate visibility splays, which allows direct access into the site from the adjacent highway.
7.17 Greenfield Terrace is a relatively quiet road which serves primarily as a link between Pontyberem and Capel Seion. The road junction onto Heol Y Bryn is also served by adequate visibility splays. The map below (Figure xi) illustrates the number of crashes in the immediate vicinity of the site.
Figure xi (Source:Crashmap.co.uk)
7.18 Data obtained from Crashmap.co.uk confirms that in the last 20 years, there have been no slight, serious or fatal crash incidents along this part of Greenfield Terrace. Neither have there been any such accidents at the Heol y Bryn road junction. This would suggest that there are no highway issues relating to the site or the public road(s) which serve the site.
7.19 The site lies in fairly close proximity to National Cycle Network Route 47, which is approximately 1.8km away. This proximity of the site to this cycle route is illustrated on the Sustrans National Cycle Network Map extract below (Figure xii).
Figure xii (Source:Sustrans)
7.20 The site is readily accessible to a local bus services (First Cymru South & West Wales) Route No. 128, with the nearest bus stop less than a 3 minute walk away. There’s a regular bus service which links the village to the commercial centres of Carmarthen, Llanelli and Cross Hands.
7.21 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 Pontyberem. The nearest play space identified on the LDP Proposals Map is approximately 650 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 green spaces in the village of Pontyberem.
Figure xiii – LDP2 Proposal Map
7.24 The site is within a reasonable walking distance of a number of retail and employment provisions; and services and facilities that can be found in Pontyberem service centre. Other provisions / services / facilities within a reasonable driving distance (approx. 5 minutes) can be found in nearby settlements such as Tumble, Drefach and Pontyates.
7.25 In addition, the site is within a reasonable distance of the commercial centre of Cross Hands which has a wide range of employment/retail provisions, services and facilities. Whilst the site occupies a rural location, it represents a very sustainable location given its close proximity to the service centre.
7.26 It is considered the site is within a reasonable distance of a number of employment and retail provisions as well as other local services and facilities, given its proximity to Cross Hands, Carmarthen and Llanelli. As such, the site satisfies the following ISA Objectives; ISA 6 (Material Assets), ISA 10 (Population), ISA 14 (Economy), ISA 15 (Social Fabric).
7.27 The site represents a sustainable location in terms of its proximity to nearby nursery schools and Pontyberem Primary School. The site is also within a reasonable distance of Ysgol Maes y Gwendraeth (5km). As such, ISA Objective 13 (Education & Skills) is satisfied in this instance.
7.28 The site is not located within or adjacent to a mineral buffer zone, as such, ISA Objective 6 (Material Assets) is satisfied in this instance. The site is located within a Mineral Safeguarding Area, as such, ISA Objective 6 (Material Assets) is not satisfied in this instance. The site is not located within or immediately adjacent to an a Air Quality Management Area (AQMA), as such, ISA Objective 3 (Air Quality) is satisfied in this instance.
7.29 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.
7.30 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.
7.31 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.
7.32 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).
7.33 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.
7.34 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.
7.35 It is asserted that owing to the nature of the development proposal being advanced i.e. 4 dwellings on each flank of the road, 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 8
residential plots would conform with the character and appearance of the immediate area in terms of siting and land use.
7.36 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.
7.37 The development would not be readily visible from the wider area; and would represent an infill form of development in an otherwise continuous built up street.
7.38 Given the aforementioned, it is considered that any resulting development would not be inappropriate or disproportionate in scale. It is on this basis that it is considered that the proposal would represent a sensitive form of development, commensurate with the existing built form, hence would not adversely affect the spatial character of the village.
7.39 The development would not have a significant impact on the amenity of adjacent land uses, properties, residents or the community. The impact on the amenity of nearby residents has been fully considered and duly discounted, particularly given the separation distance between the site and the nearest residential properties.
7.40 Overall, the proposed development would satisfy PPW’s objective of achieving sustainable development both by ensuring that the local community has access to sufficient housing and affordable options whilst also working to facilitate a modal shift to more sustainable methods of transport and reducing car borne journeys.

8 Summary and Conclusion
8.1 This Planning Statement has been completed on behalf of Noel Richards and provides planning support for the inclusion of additional land in the revised Local Development Plan to accommodate potential residential development at land adjacent to Greenfield Terrace, Pontyberem.
8.2 It has been established that the principle of residential development is compliant with both national and local policy and represents an acceptable form of infill development at this location. The development would assist with the housing land supply situation in the county.
8.3 While residential development at this location would inevitably change the character of the site itself, the proposed 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.

Amend plan to include site

Please refer to documents enclosed: location plan, supporting text, integrated SA and initial sketch scheme for a proposed candidate site.

Location plan:

Land between Ysgol y Castell and Fairacre, Priory Street, Kidwelly
The proposal is to include the piece of land which sits between Ysgol y Castell and
Fairacre off Priory Street in the proposed LDP for residential use. The site is currently being
used as a site compound for the construction of the new primary school.
The central location of the proposed site
within Kidwelly provides access to a
number of local services and facilities.
Within the immediate vicinity this
includes the adjacent new primary school,
Ysgol y Castell, a Catholic Church and a
Co-Operative food store. The site has
good accessibility to public transport links,
such as bus stops along Priory St with the
nearest directly outside the site. This
provides transport between Llanelli and
Carmarthen via Trimsaran and Ferryside.
A railway station is also located 0.7 miles
west of the site.
As seen in the location plan, the site is surrounded mainly by residential land use. Some
local facilities are available within a short distance of the site, including shops, post office
and sports clubs. Priory Street runs parallel to the north-west end of the site and is a 30mph
traffic calmed road which reduces to 20mph past the school and the site.
The land in question is between
Fairacre and Ysgol Y Castell.
Current LDP has the land as
located outside settlement
limits but designated
recreation/open space. In this
instance the current policy REC1
is currently relevant.
Behind the school in a current
plan is an allocation for
residential use, reference
T3/3/h3.
Excerpt from current LDP
Excerpt from current LDP – enlarged
In the 2nd Deposit Revised Stage LDP shows what we now know as the school site allocated
as ‘outdoor sports’. The site between Fairacre and the school is shown as outside
settlement limits and with no designation. It is no longer required for open space/
recreation.
Excerpt from 2nd Deposit Revised Stage LDP
In the current LDP, behind the school is an allocation for residential use, reference T3/3/h3.
This in no longer included in the 2nd Deposit Revised Stage LDP
The site assessment table supporting the proposed LDP says of the site that
‘The site has been allocated in a number of previous development plans without indication of
delivery. Potential concerns over the scale of the site within the settlement. Site to be deallocated.’
In the 2nd Deposit Revised Stage LDP, the constraints map shows the site is designated as a
part slate and part sand and gravel safeguarding area. We would argue that this is not an
appropriate site to remove slate, sand or gravel from. The nuisance, noise and dust factor of
excavating stone alongside a school and residential properties being a major concern.
Amongst the 2nd Deposit revised LDP documents, the evidence base, there is a paper which
refers to development limits
Infill and extensions to settlements
8.4 Make provision for appropriate infill within, logical extensions to, or rounding off of
defined settlements
We propose that this site be included as a rounding off/ infill of the settlement limits of
Kidwelly. The rear boundary would line up with the rear boundary of the school and a little
way beyond the rear boundary of the residential property Fairacre.
Initial thoughts are that the site could accommodate something like 6 or 7 dwellings. A
sketch plan is included which shows 6 dwellings. A seventh may be possible towards the
front of the site but there may be amenity issues due to the angle at which Fairacre sits and
this will need to be assessed in more detail. The location of the access along the frontage
would need also to be agreed with Highways. The site entrance would be within the 20mph
zone.

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

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

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

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

In total, the documents you received should include the following

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

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

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


Planning statement:

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

Allocate the site for housing in the Revised LDP.

I would like to make comments on the above forthcoming LDP

Why was my request to Carmarthen Council that on the understanding, when a new head of planning was appointed, a meeting with Rhodry Griffiths would be available to me. This never materialised. I did have a meeting with Llinos Quelch on the 10th March 2020 where various issues was discussed.

Why was the village boundary moved from Pontargothi Memorial Hall car park, when sometime ago, this car park belonged on our ground, ground which was given by a previous land owner to the Memorial Hall. We had the right to extend the land to go into the LDP, land which is classified as grade 3

Why has 15 units been allowed on grade 1 ground which goes against all principles held by the Welsh Office, in other words the Welsh Government. Also the remaining ground is liable to flooding. This ground was originally owned by the Welsh Development Agency whom sold the ground at a public auction held at the Chothi Bridge Hotel Pontargothi, dated Friday October 11th 2002, the contract of which included a claw back on any future development value of 50% of land used. Why is it that a planning officer in 2023, did not know nor could be bothered to understand that this claw back is public money, which prompts the question, that I believe at the time of the inspector appointed by the Welsh Government for this enquiry the Welsh Barristers to overlook this matter to which I have insisted upon over the last two years, along with others as mentioned below.

Why was there four detached houses built on the old Chothi Manor in 2019 (or thereabouts) where I am led to believe there was nil contributions paid on these new builds. I stated to Neil Bateman, are these 1st time buyers properties, and that I estimated the value of these properties to be at least £600k or above where a contribution should have been paid so that more social housing could be built in Carmarthenshire. I will elaborate further at the time of the enquiry and would like the inspector to visit this site and make a public statement in regards to these new builds at the same time.

Why was the preferred site of 15 units allowed to go forward this time by the planning department. I was led to believe that the ground in question had not been developed over many years and that it would be taken out of the LDP, this has not been the case and will ( also be discussed at the enquiry ) along with the site at Nantgaredig where 35 units also goes back to the UDP days has been put into the LDP this time. I would also want to discuss why 15 units = 3 contributions but has been stated as (2)

I suggested to Rhodry Griffiths, back in the autumn of 2022, that Planning Aid Wales should conduct meetings throughout Carmarthenshire, to which he replied that, Carmarthenshire County Council could not afford their costs, which I thought was so disgusting that people whom put ground in Carmarthenshire LDP should have a basic right to voice their grievances and be heard by Planning Aid Wales and to undertake their own reports and conclusions reporting back to the Welsh Government. I firmly believe that Carmarthenshire County Council planning department has no intentions of outside organisations such as Planning Aid Wales being involved whatsoever and therefore Carmarthenshire’s planning department rely on their own judgments and decisions which makes a complete mockery of the whole scheme of the LDP.

Back to my land in Pontargothi, Myself and my brother in law purchased this five acres of land West of, and adjourning to, the Memorial Hall in Pontargothi, as I wanted to live there after my retirement. The ground is a good location for me and my sister and her husband to live. The facilities such as a good town for shopping, a doctors surgery and other locations seemed to be for many years, the right location for us. I am a Welshman whom has lived in Monmouthshire all my life and will not be held to ransom by a planning authority like Carmarthen County Council. This land is ideal for housing as this is on the A40 and has all the amenities one could ask for, land that was earmarked for planning to be used for a new bypass some time ago which was scrapped and I would ask the inspector to visit this site and request that I be able to attend. Again, I will elaborate further in this regard at the enquiry.

Amend Plan to include the site

This representation objects to the exclusion of this site from the development limits for Llanpumsaint. 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 3 Sustainable 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 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 more sustainable and deliverable than the other allocations within Llanpumsaint (SuV12/h1 & Suv12/h2).
The inclusion of this land within revised development limits would be fully supported.

Include site within the development limits for Foelgastell and allocate for housing under Policy HOM1.

This representation objects to the exclusion of this site from the development limits for Foelgastell – a Tier 3 Sustainable Village. Its inclusion would not lead to additional environmental pressure, but instead will foster sustainable growth and allow for a wider choice of housing type. Its development would be in keeping and in character with the settlement and will ensure a deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints and its delivery is assured.
A full description of the site's development potential and merits has previously been provided in the candidate site submission, to which reference should be made. It is considered that this site is both sustainable and deliverable and offers a valuable development option within this Tier 3 Sustainable Village which has no proposed alternative allocation.
The inclusion of this land within revised development limits would be fully supported.

Amend Plan to include site

This representation objects to the exclusion of this site from the development limits for Carmarthen. The objection site has been formally acknowledged to have mixed development use, including industrial and residential – it is technically brownfield land and therefore has considerable sustainable development credentials.
The site is located adjacent to the urban form and should be regarded as a natural extension to the settlement.
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 short term delivery is assured.
A full description of the site's development potential and merits has previously been provided in the candidate site submission, to which reference should be made.
It is considered that this site is both more sustainable and deliverable than those other sites that have been allocated within Carmarthen.
The inclusion of this land within revised development limits would be fully supported.

Include the whole site as a housing allocation.

This representation comprises both an objection and a supporting submission. The proposer's land ownership amounts to one field at Penbryn Farm, Llangynwr. Approximately half of this field has been identified as being suitable for residential development and has been included within development limits (PrC1/h10), the remainder has however been excluded. The part-inclusion of the field is clearly supported, but an objection is hereby made to the exclusion of the remainder of the field. The justification for including only part of the proposer's land will apply to the whole field.
The following objection is made to the exclusion of part of this site from the development limits for Carmarthen. Its whole 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 whole site is both more sustainable and deliverable than other nearby sites that have been allocated within Carmarthen.
The inclusion of this land within revised development limits would be fully supported.

Amend Plan to include the site

This representation objects to the exclusion of this site from the development limits for Carmarthen. Its inclusion would not lead to additional environmental pressure, but instead will 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 more sustainable and deliverable than other sites allocated within Carmarthen.
The inclusion of this land within revised development limits would be fully supported.

Remove sites from Plan

Here are my objections to the LDP

Infrastructure
We do not have a comprehensive bus service that links Llangennech effectively with either Carmarthen, Swansea or Llanelli . Therefore will be more people commuting out of the village. The junction ti M4 top of the village is congested most mornings from 7-5o to at least 8-45. traffic past the school is necessarily slow but the volume of cars turning on junctions is already alarming. Does the school have the capacity to cope with influx ? What is the impact on Welsh language provision ? Will they have bilingual streams and what then the implications for teaching !

What resources are there in Llangennech ti support new families? The GP surgery is a sole GP surgery and sited in a narrow road. Is there capacity to expand and enhance GO surgery? It’s hard enough now to get appointments within a reasonable amount of time. Health visitors midwifery appointments?

Turning to Bryn. Despite signage drop off and pick up times at school are hazardous and dangerous. Drivers negotiate speed bumps parents door openers random children and double parking. Does this school have the capacity to expand and provide safe routes for children. Is there adequate transport provision for additional families to the secondary schools? Who will fund the necessary change

From an ecological point of view this move will bring more commuters and impact on the environment in multiple ways: loss of woodland and green spaces , more vehicles travelling through the village and pit anti ally hazardous situations in and around the schools.

Also the people to be relocated how are they to be integrated effectively in Welsh communities. The housing crisis in North Wales is a prime example. What will be the effect on the agricultural pockets of land around Llangennech. Once lost they will never be recovered . This is not NIMBYism . We have a duty to preserve our woodlands forests and farms. What will why he carbon cost of all this proposed development.

I object for all the reasons above.

Amend Plan to include the site

This representation objects to the exclusion of this site from the development limits for Fforest/Hendy, a Tier 2 Service Centre. There are limited housing opportunities elsewhere within the settlement – most have already been built or are under construction. As the plan period progresses, there will be fewer opportunities for residential development.
Given the proximity of this urban settlement to Swansea and the strategic transport links provided by the nearby M4 and Heart of Wales rail line, this lack of recognised housing opportunities will hinder the future growth of the settlement and will discourage inward investment.
There are significant employment areas within the locality, as well as education, retail and healthcare services, yet there is very little scope for residential development within this Tier 2 settlement. The objection site represents a natural ‘rounding off’ to this part of Fforest and is conveniently located within walking distance of nearby Hendy/Pontarddulais’ services and facilities. Furthermore, there is an important community facility (‘Bird in Hand’ public house/restaurant) opposite the objection site, thereby reinforcing its confirmed sustainability credentials.
The residential element of any scheme would comprise a high quality phased development and would draw on local Welsh vernacular architectural design elements, making every effort to be sustainable, both through the employment of local contractors, the use of local suppliers, and in the long
term, through the provision of residential units within convenient walking distance of Fforest’s services and facilities.
The proposer’s land is in a highly sustainable location being immediately adjacent to the A48 road and in close proximity to the public house. The site has the added advantage of being readily deliverable to provide high quality housing in keeping with existing development in Fforest.
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 Fforest. Its development would be in keeping and in character with the settlement and will ensure a readily deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints and its short term delivery is assured.
It is considered that this site is both sustainable and readily deliverable and its inclusion within revised development limits would be fully supported.

No change.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Dear Manager,

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

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

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

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

2. SuV20/h1 — land adjacent to Llwynhenry Farm

I object for the following reasons:

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

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

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

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

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

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

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

Regards,
Mair Evans

Amend Plan to include the site

Carmarthenshire Local Development Plan 2018-2033 – Second Deposit Draft
Objection on Behalf of NBA Developments Limited
Land part of Tirlan Farm, Off Bethania Road, Upper Tumble

We are instructed by NBA Developments Limited to a make a formal representation to the
“soundness” of the Second Deposit Draft of the Carmarthenshire Local Development Plan.
Our clients own an agricultural holding which is set to the rear of residential properties and
fronting the southern flank of Bethania Road, on the eastern edge of Upper Tumble. The
land comprises low-grade, rough pasture which also borders detached and semi-detached
housing which are orientated to front that highway. Our clients are currently redeveloping the
Tirlan Farmyard with four dwellinghouses, which are being constructed in place of former
agricultural outbuildings which lie off the near side of highway.

Our client’s land interests at the eastern edge of Upper Tumble benefit from an edge-of
settlement location, immediately adjoining established housing, and set only 200 metres
from established semi-detached housing which marks the western edge of Cross Hands.
Tirlan Farm includes two open field enclosures which have their highest point fronting the
A476 Bethania Road, before falling southwards to other farm properties east of Tumble.
The Tirlan Farm site lies within walking distance of the settlement’s community facilities,
including convenience shops, primary school, a medical surgery and pharmacy, and regular
public bus service between Cross Hands and Llanelli. It can be regarded as inclusive within
the settlement form.
Our client therefore seeks inclusion of their land as an Alternative Site for a future
Residential development within the defined settlement limits of Upper Tumble within the
Replacement Local Development Plan.

The Site comprises a single rectangular-shaped field frontage, and generally level to gently sloping grazing field set off the immediate southern flank of Bethania Road. The field is marked by a roadside hedgerow which extends the field length, but is punctured by an agricultural access gateway, from where an unmade farm track leads off to a recently completed agricultural outbuilding set in the eastern field of Tirlan. The Representation Site is currently being used as a contractors’ storage area as the four houses at Tirlan are being constructed. Figure 1 below provides a Google Earth image of the site, whilst Figure 2 provides a detailed Ordnance Survey map extract of the site.
Figure 1 – Google Earth – April 2021 – of Representation Site
Figure 2 – Ordnance Survey Map extract of Representation Site
We have noted that the draft settlement limits have been wrapped around the former Tirlan Farm yard, before crossing to established development off the northern flank of Bethania Road, in the form of Llechyfedach. That estate is predominately local-authority-built in origin, but with a small grouping of three modern bungalows about its junction with Bethania 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 Upper Tumble, 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 Upper Tumble, as reproduced below in Figure 3. The land should be appropriately allocated for Housing under Policy HOM1.
Figure 3 – Extract from Proposals Map with Representation site edged in red
This formal representation letter supplements the following documents which comprise a complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
- Location plan and Indicative Masterplan
Reasons for Allocation as Residential Development within Settlement Limits

1.0 Position within Residential Setting at Bethania Road
1.1 The Council within the Settlement Framework of the LDP, have categorised Upper Tumble as part of the Cross Hands / Ammanford Principal Service Centre, given it lies only one kilometre from Cross hands town centre, and its range of extensive employment, retail and community facilities and has good public transport links to the nearby Principal Service Centres of Ammanford and Llanelli. In such circumstances, the introduction of a modest residential allocation to the edge of Upper Tumble certainly meets the spatial criteria for locating new dwellings as part of the settlement form.
1.2 In terms of its physical location, the Representation Site is flanked on one side by residential development being the redevelopment of the Tirlan Farmyard, the site layout plan for which is reproduced below as Figure 4. The adjoining field enclosure extends over a field frontage of some 95 metres and terminates at an established mature field hedgerow which separates it from the eastern field at this part of the farm holding.
1.3 Bethania Road itself continues from this point for only a few hundred metres to join Heol Bryngwili and the range of community facilities at nearby Cross Hands including public bus stops. In the context, the site is directly related to the settlement, with proposed occupants able to easily access facilities and public transport. Consequently, the proposals would meet the relevant initial criteria of the Policy SP16 where new residential development should seek to be placed in sustainable locations, accessible on foot / cycle to the settlement’s range of community and commercial facilities and services.
Figure 4 – redevelopment of Tirlan Farmyard curently under construction

2.0 Representation Site Proposals
2.1 This submission is accompanied by an Indicative site layout plan which indicates an indicative setting for a frontage of detached, two-storey dwellinghouses to be orientated to front the public highway and thus complementing the newly forming residential properties being formed at Tirlan, and also orientated to front Bethania Road. Figure 5 below provides a reproduction of that Plan which seeks to provide paired accesses onto the A476 road, and dwellings set back to allow for adequate parking and turning facilities. Traditional rear gardens of a minimum of 10 metres depth would be typically arranged, with the rear perimeter of the site denoted with new hedgerow planting.
Figure 5 – Indicative Site Layout Proposals
2.2 The Representation proposals would ensure that massing of scale was sensitively designed with buildings not rising to more than two storeys. The development of the field frontage will necessitate partial re-modelling of ground levels of the field when forming access driveways. However, the footprints of the proposed dwellings themselves would be sited upon a plateau in the enclosure, so that new development would correspond to the ground levels of adjoining Tirlan Farm properties, as shown in the photographs below.
Photo 1 – view looking west along Bethania Road with field frontage to left and established agricultural access to the farm holding
Photo 2 – view eastwards along public highway with new residential construction evident and immediately adjoining the Representation Site
Photo 3 – the site has limited ecological value being semi-improved grassland

3.0 Sustainable Location
3.1 The Site at Bethania Road lies off a public highway which extends as a principal distributor road between Upper tumble and Cross Hands. Public bus stops lie only some 300 metres distant from the site access at Llechyfedach School. Main public bus services call at these bus stops, and in particular:
- Service 128 – Llanelli to Ammanford, via Llannon and Tumble
- Service 129 – Ammanford to Carmarthen via Tumble and Cross Hands
3.2 Strategic Industrial Estates at Cross Hands are a 15 minutes’ walk from the Site, or 5 minutes by bus.
3.3 The Alternative Site lies within a 3 minutes’ walk of Llechyfedach Primary School which is located further west along Bethania Road. Ysgol Cwm Gwendreath lies a 10 minutes’ walk in the opposite direction through Cross Hands.
Tumble contains a post office, range of convenience stores, hot food take-aways, medical surgery, pharmacy, play facilities, community hall, public houses and cafés.
3.4 Cross Hands centre provides a whole range of large food supermarkets, comparison shops, public houses / cafes, offices, industrial estates and leisure / recreation facilities.
Figure 6 below provides an indication of the proximity of the Alternative site to Tumble village centre at Heol-y-Bryn, and nearby Cross Hands town centre and Business Park and strategic road network.
The red star denotes the position of the Representation Site.
Figure 6 – proximity of Site to Tumble village centre, Cross Hands town centre and major road network

4.0 INFRASTRUCTURE CONSIDERATIONS
4.1 Development of the Alternative Site for residential units would be served by mains water, gas, public sewer and electricity connections, which lie within the adjoining stretch of Bethania Road.
4.2 The public highway itself is equipped with roadside gullies and drainage which aid to discharge run-off from the extended carriageway. The Site comprises of former agricultural pasture. There are no areas of water-logging evident, and therefore at first inspection, it appears that the site benefits from good ground percolation of rainwater and discharge to existing perimeter drainage ditches.
Soakaways would be the most sustainable means of disposing of surface water from individual buildings. 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 field’s boundaries, which eventually combine and inter-connect discharging surface water to minor watercourses flowing eventually to discharge into the River Gwili. It is considered that as a result of on-site features, there would be several options available to a future development of the site in terms of surface water disposal.
4.3 We have also referred to The Coal Authority Map detailing “Development High Risk Areas” and the location of historic mine entries. Figure 7 below is an extract from that map, and which confirms that the site lies close to two seams of coal, however, the road frontage appears free from any mining legacy.
Figure 7 – extract from Coal Authority interactive map with site highighted

5.0 Housing Land Availability in Tumble
5.1 Despite being part of the Cross Hands Principal Service Centre Cluster, Policy HOM1 indicates only two sites allocated for housing in the whole of Tumble. An extract from that HOM1 schedule is reproduced below.
Figure 7 – Housing Allocations at Tumble
5.2 The re-development at the former central Garage have already been completed by NBA Developments, whilst the site at Bethesda Road has lain undeveloped since demolition of the commercial unit was completed several years ago. Therefore, for a settlement with several thousand residents, there are no modestly sized residential development opportunities. The development of the Alternative Site for only five additional dwellings will not place any burden whatsoever, or indeed compromise housing land supply.

6.0 Conclusion
6.1 This Representation to the Second Deposit Draft of the Revised LDP has sought to promote the inclusion of an Alternative Housing allocation on land off Bethania Road in Upper Tumble.
6.2 Our client has illustrated that their indicative proposals to develop a small site of frontage dwellings to complement that currently in existence adjoining at the farmyard redevelopment on the adjoining section of road frontage. Accordingly, the development of the field frontage with five detached dwellinghouses will not appear at odds to the prevailing spatial pattern of development in Tumble. The locality has numerous examples of modern frontage development being completed at edge of settlement locations, which in turn, advocates that the form of development proposed for modest housing numbers is no different, resulting in it being respectful to the character and setting of the locality.
6.3 We respectfully request that this Representation be given careful examination, and consequently the defined settlement limits of this part of Tumble realigned to include the Representation Site in the Proposals Map of the adopted Local Development Plan.

Amend the plan to include the site

This representation comprises an objection to the exclusion of this site from the development limits for Llangynwr. The site itself directly abuts the existing built form of Carmarthen and would assist in addressing the imbalance of growth being directed to west Carmarthen.
Topographically the site is relatively level and does not contain any physical features of note. The site is within walking distance of Carmarthen’s town centre with its high order goods and services. Access to the objection site is proposed direct from Capel Dewi Road, a public transport corridor.
The residential element of the scheme would comprise a high quality phased development and would draw on local Welsh vernacular architectural design elements, making every effort to be sustainable, both through the employment of local contractors, the use of local suppliers, and in the long term, through the provision of residential units within convenient walking distance of a range of services and facilities.
Furthermore, there is no other allocation proposed in this part of Llangynwr/Carmarthen and the site therefore offers a valuable and readily available alternative.
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 1 Principal Centre. Its development would be in keeping and in character with the settlement and will ensure a deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints and its short term delivery is assured.
It is considered that this site is both sustainable and readily deliverable and its inclusion within revised development limits should be fully supported.

Include the site as a housing allocation within the RLDP.

Carmarthenshire Local Development Plan 2018-2033 – Deposit Draft
Representation on Behalf of Miss L and Mr A Edwards
Land adjacent to Ger-Y-Llan, Llanarthne
Further to the publication of the above document, we have been asked by our Clients to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the
proposed provisions of Policy HOM1 are of particular interest to our Clients. As a result, we
offer the following for the Authority’s consideration, and Inspector’s in due course.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/076/003, seeking the allocation of their land for future residential development within the
defined settlement limits of Llanarthne as part of the Replacement Local Development Plan.
The Candidate Site is edged red below in Plan A.
Plan A
The Candidate Site comprised part of a single enclosure that adjoined the existing
residential development of Ger y Llan, located to its east, with its southern and eastern
boundaries then being defined by established field boundaries. Access to the site is then
obtained from the public highway that runs along the southern boundary of the site.

Following its due consideration, the Council then excluded the Site from the proposed
development limits for Llanarthne in its 1st Deposit LDP, published in January 2020 (Plan B).
Plan B
In explaining its decision to exclude the site and not allocate it for residential purposes, the
Council advised in its ‘Site Assessment Table’ (January 2020) as follows:
“There is sufficient residential land opportunity within the settlement. Development would
lead to an unnecessary extension of the settlement.”
At the time of publication of the 1st Deposit LDP therefore, the principle reason presented by
the Council for the exclusion of the site from the development limits and its non-allocation for
residential development, was on the basis that the Council considered there to be sufficient
alternative sites within the settlement to accommodate the housing need. This is somewhat
puzzling, as construction on all plots of the only allocation present in the settlement had by
the time of the assessment been commenced or completed, as illustrated by the aerial
photograph below of the time.

Photograph 1
As a result, at the time of the publication of the 1st Deposit LDP, there was no opportunity for
further development in the settlement.
As part of the current consultation process into the 2nd Deposit LDP, the Council have again
published a “Site Assessment Table” (2023), which provides details of the Council’s analysis
of each received Candidate Site submission. We note that our Client’s land was considered
as part of this process and as a result the Council concluded as follows:
“There is sufficient residential land opportunity within the settlement. Development would
lead to an unnecessary extension of the settlement.”

As can be seen, the rationale of the Council for the exclusion of the Site as an allocation in
the LDP has remained the same. This is somewhat puzzling and illogical. In terms of
‘alternative sites, in the 2nd Deposit LDP, Llanarthne no longer has any housing allocations
that will facilitate further development. This seems an extremely erroneous decision,
particularly in terms of (a) the sustainable attributes of the settlement, (b) the clear support
from local developers (see accompanying letter) for further development in the area to
respond to the high demand for housing and (c) the number of undeliverable allocations
being put forward by the 2nd Deposit LDP and so further sites are required (see below).

The second reason given for the exclusion of the site is completely illogical and inconsistent
with other decisions taken by the Council in the preparation of its 2nd Deposit LDP. By their
very nature, any new greenfield allocation will extend beyond the existing built form of a
settlement, as well as going beyond the existing development limits and so into the ‘open
countryside’. On this basis alone, the reason given for the exclusion of the Alternative Site is
incredulous.
In addition to the above, the inconsistency of the decision is in itself an indication that the
Plan is unsound, as the process of assessment of sites undertaken by the Council has
clearly been a flawed one. The examples below (although there are numerous throughout
the Plan) provide an indication of where the Council has allocated housing sites beyond the
existing built form, making it impossible to understand why they should then apply a
completely counter logic with regards to the exclusion of our Client’s land.

Plan C Plan D
(Allocation PrC3/h4) (Allocation PrC3/h18)
The allocation of the Alternative Site would be in line with established planning principles
(i.e. not lead to the coalescence of settlements) and be consistent with it and the
assessment approach of the Council in relation to proposed allocations.
On the basis of the above, we consider the sites exclusion to be an illogical and erroneous
decision by the Council and consider therefore that the LDP as it stands is “unsound” and
fails to meet the required Tests of Soundness.

In addition, we consider that alternative allocations within the wider Cluster that Llanarthne
forms part of (discussed below) are neither appropriate nor deliverable. We consider
therefore that the land edged red in Plan A, should be allocated for residential development
under the provision of Policy HOM1 of the Carmarthenshire Local Development Plan. This
formal representation letter therefore supplements the following documents, which comprise
a complete submission to the 2nd Deposit LDP Consultation stage:

- Completed Deposit LDP Representation Form
- Completed Integrated Sustainability Appraisal form
- Copy of Candidate Site Submission Report (August 2018)
- Letter of Support from Morgan Construction Wales

Response to Council’s Reasons for Non-Allocation of Site
Sufficient Residential Land Allocated Within Settlement
As detailed above, we are deeply concerned with the Council’s decision to not allocate the
land in question and understand that this may be because the Council holds the view that
alternative allocations within the wider Cluster it forms part of will deliver sufficient housing
for the area during the Plan period. This is in our view wholly incorrect.
Under the current provision of the Deposit LDP, the Cluster has a range of proposed
residential allocations. Having undertaken a comprehensive review of the proposed
allocations put forward by the 2nd Deposit LDP for the Cluster in question, it has been
identified that a number have significant questions over their ability to be delivered within the
Plan period, including the following:

Ref. No. Site Name Units
PrC1/h4 Land off Parc y Delyn 17
PrC1/MU1 West Carmarthen 700
PrC1/MU2 Pibwrlwyd 247
SeC1/h4 Cae Canfas, Heol Llanelli, Pontyates 8
SuV4/h1 Adjacent Fron Heulog, Cynwyl Elfed 6
SuV12/h1 Adj. Gwyn Villa, Llanpumpsaint 20
Table 1

As a result of the above – all of which have been allocated in previous development plans -
separate objections to their inclusion with the LDP have been made. This is due to the fact
that to continue to allocate such sites for residential development results in the Plan being
unsound. Alternative sites, such as that put forward by our Clients, must therefore be
considered and brought forward in order to address this deficiency and ensure that the Plan
is sound in all respects.

In conclusion, this Representation to the 2nd Deposit Draft of the Revised LDP has sought to
examine the Council’s reasons for non-allocation of a Candidate Site. It has successfully
addressed the reasons put forward by the Authority for its exclusion and has highlighted that
currently proposed allocations are undeliverable.
We therefore respectfully request that this Representation be given careful examination, and
consequently the land in question be allocated for residential development as part of the
Carmarthenshire Local Development Plan to ensure that the document passes all the
relevant tests of soundness.

Amend Plan to include the site.

This representation comprises an objection to the exclusion of this site from
the development limits for Capel Hendre. The 2
nd Deposit LDP acknowledges
the industrial/employment importance of Capel Hendre and it is likely to be
subject of commercial investment over plan period. There is however
inadequate land supply for quality residential development to provide
accommodation for the increasing workforce. The objection site is located
within a convenient walking distance of the designated employment areas and
would thus satisfy sustainable development principles.
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 1 Principal Centre. Its development
would be in keeping and in character with the settlement and will ensure a
readily deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature
conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood
risk, hydrological, ecological, archaeological or land ownership related
constraints and its short term delivery is assured.
It is considered that this site is both sustainable and readily deliverable and its
inclusion within revised development limits would be fully supported.

Allocate the site for housing within the Revised LDP.

HOM1 (Housing Allocations) / SP16 (Sustainable Distribution - Settlement
Framework) / SP3 (A Sustainable Approach to Providing New Homes)
We have reviewed the housing allocations proposed in the Deposit LDP and note
that only 94 dwellings are proposed in Llangennech. Llangennech is a Tier 2
(Service Centre) which is the second highest tier within the settlement framework.
Llangennech lies within Cluster 2 (Llanelli Area) and within Cluster 2 it is the
settlement that is proposed to accommodate the least amount of residential
development. We note that Burry Port (another Service Centre in the same cluster)
has been allocated 501 dwellings, over five times the amount allocated to
Llangennech whilst Trimsaran/Caraway (also a Service Centre in the same
cluster) has been allocated 345 dwellings. We consider that the distribution of
development within Cluster 2 should be more balanced and proportionate to
ensure that the plan is effective (test of soundness 3).
Llangennech is a highly sustainable settlement, as reflected in its identification as
a Service Centre Settlement in the deposit LDP. Paragraph 10.10 of the Deposit
LDP states:
“Llanelli remains the focus for delivery within this area, along with villages within its
urban outskirts. The service centres which fall within this cluster are key
components in the delivery of new homes and jobs given their overarching
relationship to the rest of the cluster. This cluster has the highest population
density within the county.”
The settlement of Llangennech benefits from numerous facilities and services
including Ysgol Gymraeg Llangennech (a Welsh medium primary school with an
infant and junior school), a GP surgery, nursery, convenience store, post office,
pharmacy and formal sports provision. The settlement is well served by public
transport in the form of a railway station and bus stops. The settlement also
benefits from an established employment area providing valuable job
opportunities.
The settlement is within easy reach of junction 48 of the M4 meaning that
development in Llangennech is unlikely to have as much impact on the A4138 as
development in Llanelli and all the other Cluster 2 settlements with the exception
of Hendy/Fforest. This is because traffic coming off the M4 to Llanelli, Burry Port,
Kidwelly, Pembrey and Trimsaran/Caraway will all need to travel on the A4138 and
through Llanelli. Allocating significant development in the Service Centres beyond
Llanelli is likely to lead to traffic implications as the infrastructure serving these
centres all run through the town of Llanelli. Locating additional residential
allocations in Llangennech as opposed to the settlements west of Llanelli will
assist in delivering the housing requirement, in line with the settlement hierarchy,
in a more proportionate manner which will, as a result assist in reducing the
amount of traffic running through Llanelli.
INF4 (Llanelli Wastewater Treatment Works Catchment Surface Water
Removal)
We also note that development in Llanelli and Burry Port will need to be subject to
draft Policy INF4 and the Burry Inlet SPG as the sites drain into the Llanelli Waste
Water Treatment Works. According to the LDP, within this catchment area there
are concerns that the connection of foul flows generated by new development
introduces the risk of deterioration in the water quality of the Carmarthen Bay and
Estuaries European Marine Site (CBEEMS). This is due to the fact that the
majority of the sewer system in the Llanelli WWTW area is combined (surface and
foul). DCWW has requested that all new development within the catchment be
subject to a requirement to undertake compensatory surface water removal from
the system as part of the granting of planning permission. The LDP (11.204) states
that:
"there is a concern that introducing additional foul flow can lead to overloading to
the WWTW, as well as an increase in the frequency of discharges from storm
sewerage outflows out to the CBEEMS during significant rainfall. There can also
be potential localised flooding issues resulting from these issues."
Given the above concern and necessary compensation requirements we question
the logic of directing so much development to the affected area when suitable
alternatives are available in the cluster. The settlement of Llangennech lies outside
of the catchment in question and therefore we argue that it would be appropriate to
reduce the quantum of development in the Burry Inlet area and to provide some of
the redistributed quantum of development in the nearby settlement of
Llangennech, therefore retaining the quantum of development in Cluster 2.
As previously explained, only 94 dwellings are proposed to be developed in
Llangennech during the lifetime of the plan. All of the 94 dwellings are expected to
come forward within the 6-10 years timeframe with none expected to come forward
within the 0-5 years timeframe. We consider that additional allocations should
therefore be made in Llangennech to ensure that a suitable supply of housing is
able to come forward in the short term to meet local needs. We consider that our
client's site is well placed to meet this short term need because heads of terms
has been agreed with Persimmon Homes, a national house builder to bring the site
forward in the short term if the site is allocated. It is widely acknowledged that, if
allocated, that the site would be capable of early delivery. The Council in its
assessment form states:
"Given the site's size, greenfield status and location close to the M4, it is likely to
have a market appeal."
In addition, Persimmon Homes has provided a Statement which is appended to
this submission. The statement states:
"The viability of the site has been assessed by Persimmon Homes West Wales
utilising external and abnormal rates from a comparable site (in terms of size and
topography) currently under construction in our West Wales Region.
Persimmon Homes West Wales expects to continue its track record of delivering
housing sites in the Region at a rate in excess of 50 dwellings per year and at
‘policy level’. That is, we consider this site to be deliverable with an on-site
provision of Affordable Housing at a rate of 20% together with Education, Open Space, Transportation contributions in line with those on comparable sites
currently under construction in Carmarthenshire.
It should also be noted that following this assessment of the viability of the site,
Persimmon Homes West Wales concluded that it was appropriate to agree the
Heads of Terms for the sale of the land with the landowner. I trust that this serves
to demonstrate our commitment to developing this site and that it is technically
deliverable in line with the Council’s housing delivery aspirations."
Including our client's site would assist in ensuring that Llangennech remains a
vibrant and viable settlement. Additional housing in this area in the short term will
assist in supporting the local primary school in Llangennech. There is a risk that in
delaying the vast majority of development until 2025-2030 that the settlement and
its services and facilities will become stagnant. A critical mass of population is
required in the short term to ensure the vibrancy of the town's facilities and
services.
As explained in our candidate site submission (documents attached again for the
Inspector's benefit) we consider that our client's site is suitable for development. It
is immediately adjacent to the settlement boundary (to the south and east) and
within close proximity to the primary school and other facilities such as play areas,
playing fields and bus stops. There are very limited physical and environmental
constraints and there is no flooding issue - the Council's SFCA confirms that the
site is in the best category in terms of flooding as it has a Risk Category of Low.
Importantly some of the Council's proposed allocations are at a Medium and High
risk of flooding according to the SFCA (February 2023) prepared by JBA. This
includes Nantydderwen (PrC3/h14 33 units), land adjacent Brynlluan (PrC3/h18 29
units) and land off Heol y Parc (PrC3/h8 18 units).
We consider this to be a concern given the recent flooding in South Wales and the
Welsh Government's aspiration of ensuring resilient developments (Well Being
Goal as set out in the Well-being of Future Generations Act) that are not at risk of
flooding. The consultation document on TAN15 seeks to direct development to
Zone 1 (very low risk) and only to Zone 2 (low risk) if the development meets strict
tests. We consider that suitable sites that are of the very lowest flood risk should
be allocated ahead of others that have a higher flood risk. Our client's site
(SR/086/075) should be looked at positively in this regard.
We have demonstrated that the site is viable given the developer interest, meaning
that there is certainty that the site can be delivered. We query whether the
proposed allocations benefit from the same certainty in terms of delivery.
We consider that as currently drafted the plan is not sound. We consider that the
plan fails test of soundness 2 (is the plan appropriate) and test of soundness 3 (will
the plan deliver). We set this out below:
Test of Soundness 2 - Based on the above, we do not consider that the Plan is
logical, reasonable and balanced. The distribution of development across Cluster 2
is unsuitable and the sustainable and desirable settlement of Llangennech has
been overlooked as a settlement to accommodate a fair and reasonable amount of
residential development. We do not consider that the candidate sites put forward in
Llangennech (including SR/086/075) have been considered as a fair alternative to the current sites proposed for allocation in the LDP. The Council notes in its
candidate site assessment for SR/086/075 that the scale of allocations in
Llangennech is appropriate in terms of meeting the identified growth requirement
for the settlement but has not provided evidence to substantiate this claim. In
addition, the Council states that the identified growth requirement (94 dwellings) is
reflective of its role and function within Cluster 2 as a whole. We disagree with this
statement. No evidence has been put forward to explain why Llangennech has
been apportioned the least amount of growth amongst the cluster 2 Service
Settlements. There is no logic or consistency to this disproportionate approach
given that Llangennech is a highly sustainable settlement with ample services and
facilities.
The site assessment for SR/086/075 concludes that:
“ Development would lead to an unnecessary encroachment beyond the
development limits. The site is spatially detached from Llangennech and allocating
for housing at this location isconsidered illogical. The site will remain outside of
development limits”
We disagree with this statement as the site is adjacent to the settlement boundary
of Llangennech and not spatially detached? There is no logic in the LPA’s
assessment of this site. Any greenfield site, will by its very definition be beyond the
development limits.
Test of Soundness 3 - Based on the above, we do not consider that the plan will
deliver, especially in the short term. A specific example is that only a very limited
number of dwellings (67) are to come forward in the settlement of Llangennech in
the short term (as defined by Carmarthenshire Council) first 8 years of the plan
(average of 7.5 per year). This is not an effective way of delivering growth and
planning gain to this area. Within Cluster 2, this is a very small proportion of
growth. This is a noticeable void which would be detrimental to the health of the
settlement.
We also query whether the sites allocated will be capable of meeting the revised
TAN15 policy when it is published given that some of the sites are located in areas
of potential flooding. If the sites are not able to meet TAN15 policy then they will
not be deliverable. This will render the LDP undeliverable.
HOM1 (Housing Allocations) / SP6 Strategic Sites / SG2 Reserve Sites / SG1:
Regeneration and Mixed Use Sites
In addition to the points that we have raised about the strategy and spatial
distribution of development we also wish to make comments about the suitability,
viability and deliverability of the housing allocations that have been proposed. This
is in the context of our consideration of the fact that site SR/086/075 is a suitable
and deliverable site with limited technical or environmental constraints. We have
attached our comprehensive candidate site submission as well as a recent
statement from Persimmon Homes confirming their continued interest in the site
and that they consider the site to be deliverable in the short term.
Foul Water (Llanelli WWTW
The issue of foul water being treated at Llanelli WWTW is widely acknowledged
and we have referenced this in our response above. We consider this to be an
impediment to the delivery of the large number of dwellings located in this
catchment area. Whilst there may be a solution to each respective site, the issue is
likely to cause a delay to the delivery of these sites and the added burden of the
compensatory matters (in kind works or financial contribution) may have a
consequential impact upon viability, meaning that affordable housing and other
planning obligations cannot be delivered as the plan has envisaged. Has the
mitigation been included in the Local Plan Viability Assessment? Have the
impacted sites explained how they will overcome the issue in relation to their site?
Rolled Forward Allocations and General Lack of Information About
Viability/Deliverability
Planning Policy Wales (Edition 11 states) emphasises the importance of
deliverable sites. It states that as part of demonstrating the deliverability of housing
sites, financial viability must be assessed prior to their inclusion as allocations in a
development plan. At the ‘Candidate Site’ stage of development plan preparation
land owners/developers must carry out an initial site viability assessment and
provide evidence to demonstrate the financial deliverability of their sites. For sites
that are key to the delivery of the plan, a more detailed viability appraisal is
required.
We are concerned about sites that have been allocated in previous development
plans that have not been developed being allocated again without sufficient
justification/evidence that they will be delivered this time around. We consider that
these sites should not be included again unless robust evidence is presented. We
are also concerned that candidate sites have been allocated without any real
information being provided about their viability/deliverability. For our client's site we
have provided regular updates to the Council regarding the firm developer interest
in developing the site in the short term and an update in the form of a Statement
from Persimmon Homes that is attached with our deposit representations. We are
concerned that a number of sites have been allocated without a developer that is
lined up to build out the site, especially those that are to contribute to the
development trajectory in the first 5 years. In reviewing the Council's assessment
of sites we are concerned with the lack of certainty about deliverability.
We set out a few examples below:
Emlyn Brickworks, Penygroes (177 dwellings)(PrC3/MU1) - This site was
allocated in the previous LDP for 250 dwellings. It was also allocated in some form
in the previous UDP and before then the Dinefwr Local Plan. Various planning
permissions and variations have occurred over the years since the early 2000s.
Despite this, only 9 dwellings have been completed on site. We understand that
full planning permission (E29521) is in place since 2014 for the development of a
further 70 dwellings but development has not been forthcoming, highlighting that
there is a deliverability issue for this site. The LPA's candidate site assessment for
this site acknowledges that there is an issue but continues to propose allocation of
the site:
"The site presents an opportunity to regenerate or redevelop a previously
developed site. However, given that the site has been previously allocated with
only a small portion of the previous allocation being developed, it is considered more realistic that a smaller area of the site is carried forward into the revised LDP
which would be more manageable to develop. Further information will be sought
as necessary from the landowner to demonstrate the site's deliverability and
viability, particularly given the potential remediation costs."
It is currently identified as a site that will deliver housing in year 10-15 of the Plan.
This further highlights the uncertainty regarding the delivery of this site. We consider that credible information about the deliverability and viability of the
site should be presented now before committing to allocating the site again. If the
site cannot demonstrate that it can be delivered then the LPA should identify other
sites that can provide the necessary evidence. PPW (Para 4.2.18) states that for
housing regeneration sites, where deliverability is considered an issue, planning
authorities should consider excluding such sites from their housing supply so that
achieving their development plan housing requirement is not dependent on their
delivery. We don’t consider that this site should be used as a component to meet
the housing requirement. The site should either be removed from the LDP or
identified as a housing led regeneration site that does not form part of the supply
to meet the housing requirement.
We are also concerned that Policy HOM1 does not differentiate between
completions, sites with planning permission, sites under construction and new
allocations. This should be clarified in the final version of the LDP.
Burry Port Waterfront (364 dwellings) (SeC4/MU1 and SeC4/h2)) - The initial
outline application for this site was submitted in 2008 and outline permission was
subsequently granted on 27 January 2016. However, to this date no development
has come to fruition. We are aware that an extension of time was issued in
December 2019 in order to extend the timescale for submission of reserved
matters. However, prior to any development commencing a number of pre
commencement conditions require discharging and reserved matters approval will
be required. We are not aware that a developer is on board. This raises real
questions about the delivery of the scheme. As a housing led regeneration site we
consider that if the LPA wish to continue allocating this site then it should not be
relied upon in the Council's housing land supply due to the uncertainty about
delivery. As explained above, we are also concerned about the SFCA's
classification of the site as an amber flood risk where JBA (the Council’s flood
advisors) note that they have ‘concerns for the allocation’.
Brynlluan, Gorslas (29 dwellings) (PrC3/h18) - The site has been identified to
deliver housing in the 10 to 15 year timeframe. We question why so much time is
required to deliver a fairly small scheme. The Council's Candidate Site
Assessment states that "Additional information will be sought as necessary as the
LDP progresses towards examination to identify when the site is likely to be
brought forward." We assert that information about the deliverability of the site
should be presented now to understand why the long timescale is required,
otherwise sites that have provided this information should be prioritised.
Land at factory site between no. 22 & 28 Bethesda Road (30 dwellings)
(PrC3/h28) - The Council's Candidate Site Assessment states that "the site is
subject to planning permission, however, further information will be sought as necessary as the LDP progresses towards examination to identify when the site is
likely to be brought forward". If the site benefits from planning permission then we
question why the site is not being brought forward. Is there an issue to the
deliverability of the site? The initial outline planning permission was granted in
2013 and no reserved matters applications have been forthcoming. We suggest
that if credible evidence is not presented to demonstrate deliverability then the site
should not be reallocated. Evidence has not been provided to demonstrate that a developer will build the site.
Land off Heol Llannon, 15 dwellings (SeC11/h1) - The Council's Candidate Site
Assessment states that "Additional information will be sought as necessary as the
LDP progresses towards examination to evidence the site's financial viability and
to identify when the site is likely to be brought forward." The site has not passed
question C26 (Deliverable and Financially Viable). We therefore question how the
Council can propose that the site is allocated when insufficient evidence has been
provided in relation to its deliverability. The site is noted as being delivered in year
10-15 and we question why such a small site would take this long to be delivered.
We have set out a number of examples above where we consider that insufficient
evidence has been provided to demonstrate the deliverability of the site. This totals
615 dwellings. However, we have only cited a few examples. On the whole, we are
generally concerned that the LPA has allocated sites without the robust evidence
that is required by PPW and the Development Plan Manual to demonstrate that
the sites are deliverable from a technical and financial perspective. This includes a
number of Council owned sites. The Council should be transparent about the
timetable for delivery of its own sites.
We note the Welsh Government's research into stalled sites prepared by Arcadis.
One of the recommendations of the report is for LDPs to identify sites which are
deliverable. This requires LDPs to provide evidence of deliverability, viability and to
set a trajectory for development. We do not consider that the LDP as drafted
currently has gone far enough in demonstrating the deliverability of sites. If the
LDP is progressed in its current form then we consider that stalled sites will
continue to be evidenced. The Report explained that Carmarthenshire had the
highest number of stalled sites (approximately 70) out of all of the Welsh LPAs.
The LPA should seek to adopt an LDP which does not risk further stalled sites.
As a result of this analysis we consider that the Deposit Plan fails Test of
Soundness 3 (Will the Plan Deliver). Not delivering enough housing will have
significant consequential impacts on the Council's ability to attract new jobs to the
area as the LDP aspires to do. Other sites put forward as part of the LDP process
have better prospects of being delivered and written evidence has been provided
of this. This includes our client's site (SR/086/075) which continues to have firm
developer interest in the form of national housebuilder Persimmon Homes.
Policy SG2: Reserve Sites
It is unclear where the reserve sites are located because they are not identified on
the draft proposals map. It is also unclear what form of development will come
forward as part of these sites and therefore we question whether the policy is
sound. We question whether the policies will deliver (test of soundness 3).
We also question the fact that only two sites are to include residential uses and
one of these SG2/4 (Former Ennis Caravans, Cross Hands) has doubts over its
delivery prospects.
We have serious reservations about the deliverability of these sites and whether
the policy will be effective? We cannot see that a site assessment has been
carried out for these sites including evidence on financial viability. Reserve sites
need to be deliverable in order for the LDP to be adaptive and effective.
Policy SG1: Regeneration and Mixed Use Sites
The Welsh Government’s LDP Manual makes it clear that LPA’s should
“consider the reality of the land bank to be delivered. Sites unlikely to be delivered
should be de-allocated and not ‘rolled forward’ from the previous plan. It could be
prudent to identify such sites separately as regeneration sites which do not county
towards the housing requirement.”
It is unclear to us why regeneration sites such as Emlyn Brickworks (PrC3/MU1)
forms part of the housing supply under HOM1 as it is clear that there has been
deliverability issues for a prolonged period of time. The Regeneration sites
identified under Policy SG1 should be separate to the land supply and should be
treated as ‘bonus sites’. Emlyn Brickworks has been allocated in various plans
over the years and failed to deliver. The LDP Manual states, in terms of rolling
over allocations:
“If an LPA wishes to retain such sites but cannot evidence they will be delivered,
i.e. for aspirational or regeneration purposes, they can still be allocated in the plan
but not relied upon as contributing to the provision. It will not be appropriate to
include such sites in the windfall allowance. They should be treated as ‘bonus
sites’.”
The fact that the SG1 sites are included in the housing supply is a concern and we
consider it fails the test of soundness 3 (will the plan deliver). There are better
sites available to the Council that are deliverable and will ensure that the housing
requirement can be delivered.

No change to the Plan.

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

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

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

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

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

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

Include site within Plan.

This document supports the promotion of Land South of Lon Fair, St Clears. The Site would
represent a significant contribution to meeting housing need and, in particular, the anticipated
demand associated with the new hospital site being delivered in the area.
Strategic Policy SP 1 sets out the preferred Spatial Strategy for Camarthenshire. The focus of
Policy SP 1 is on regeneration and growth, which reflects the Councils core strategic ambitions
with development distributed in a sustainable manner consistent with the spatial strategy and
settlement hierarchy. This confirms that the distribution of housing is sought to be directed to
sustainably located areas, whereby there is a known potential for projected growth.
The Spatial Strategy identifies a settlement hierarchy to meet the identified housing
requirement of 8,882 new homes. The strategy furthermore recognises the role employment
plays in creating a prosperous County – with appropriate growth of housing with jobs and
employment opportunities. This strategy has been informed by a number of ongoing
assessments, through various sages leading up to its publication.
At Preferred Strategy stage (published December 2018) it was determined that a strategic
growth option based upon a ‘Population Growth Long Term’ scenario would be the most
appropriate option for the authority area. This was promoted by the authority on the basis that
it would best assist in delivering the Plan’s Vision and Strategic Objectives, driving sustainable
housing growth and supporting the economic ambitions of the county. This scenario equated to
a need over the revised LDP period for 9,887 dwellings on the basis of the variant vacancy rate.
These figures were based upon a Population and Household Forecast Paper published by Edge
Analytics in October 2018 on behalf of the LPA in order to inform the Preferred Strategy, when
NHS plans for a new super-hospital on the Pembrokeshire-Carmarthenshire border were at an
early formative stage, and consequently were not accounted for within the forecast.
The Population and Household Forecast Paper was updated by Edge Analytics in September
2019 to inform the 1
st Deposit rLDP, which updated housing requirement scenarios in light of
new evidence, including Carmarthenshire’s 2018 mid-year population estimate and the
consultation on the then draft National Development Framework. Again however this did not
account for any growth associated with the new super-hospital.
In February 2023 the LPA published a Population and Household Topic Paper to inform the 2nd
Deposit rLDP, which utilised data from a Housing and Economic Growth Paper prepared by
Turley (with the support of Edge Analytics). This provided an updated analysis of housing need,
reflecting the “WG 2018-based sub national population and household projections, in addition
to other population estimated published since the first Deposit Revised LDP”. Despite, however,
the fact that the location for the new super-hospital had, by this stage, been narrowed down to
just three sites within a 5 mile area (2 in Whitland, and 1 in St Clears), the implications of the
hospital on housing need/growth was not a consideration in the adjustments to the figures.
Policy SP 1 projects a target of 9,704 new homes to meet the identified housing requirement of
8,822, informed by the above assessments. The aim of Policy SP 1 is to facilitate the delivery of
new homes in sustainably located areas. The assessments which informed these projected
figures were undertaken before the implementation of the hospital was confirmed in the area.

Therefore, the housing need is greater than what is identified, and the distribution of housing
should furthermore be directed to sustainably located areas near the hospital.
Supporting text 11.11 of Policy SP 1 state that:
“by ensuring that our housing growth requirements are reflective of, and are in support of our
economic ambitions, it allows for a co-ordinated and integrated approach to ensure that the
shared role for economic growth is not in isolation of housing and vice a versa.”
It has been acknowledged that the search for a suitable location for the new hospital has made
progress since the publication of the Preferred Strategy. The search has narrowed down to only
three sites, all situated within a 5-mile radius of the promotion site. One of these sites is
located just a few hundred meters away. (See fig.1 below). Considering the significant potential
for job creation during both construction and operation that the hospital is expected to bring, it
is imperative that the LDP is capable of providing adequate levels of new homes in sustainable
locations near the hospital.
Fig.1 Proposed Potential Hospital Site: -
See Candidate Site Representation Document
See 2nd Deposit Plan LDP Representation Document

Amend the Plan to include the site.

This document supports the promotion of Land at Spring Gardens, Whitland. The Site would
represent a contribution to existing housing need and anticipated demand associated with the
new hospital site being delivered in the area.

The Spatial Strategy identifies a settlement hierarchy to meet the identified housing
requirement of 8,882 new homes. The strategy furthermore recognises the role employment
plays in creating a prosperous County – with appropriate growth of housing with jobs and
employment opportunities. This Strategy has been informed by a number of ongoing
assessments, through various stages leading up to its publication.
At Preferred Strategy stage (published December 2018) it was determined that a strategic
growth option based upon a ‘Population Growth Long Term’ scenario would be the most
appropriate option for the authority area. This was promoted by the authority on the basis that
it would best assist in delivering the Plan’s Vision and Strategic Objectives, driving sustainable
housing growth and supporting the economic ambitions of the county. This scenario equated to
a need over the revised LDP period for 9,887 dwellings on the basis of the variant vacancy rate.
These figures were based upon a Population and Household Forecast Paper published by Edge
Analytics in October 2018 on behalf of the LPA in order to inform the Preferred Strategy, when
NHS plans for a new super-hospital on the Pembrokeshire-Carmarthenshire border were at an
early formative stage, and consequently were not accounted for within the forecast.
The Population and Household Forecast Paper was updated by Edge Analytics in September
2019 to inform the 1
st Deposit rLDP, which updated housing requirement scenarios in light of
new evidence, including Carmarthenshire’s 2018 mid-year population estimate and the
consultation on the then draft National Development Framework. Again, however this did not
account for any growth associated with the new super-hospital.
In February 2023 the LPA published a Population and Household Topic Paper to inform the 2nd
Deposit rLDP, which utilised data from a Housing and Economic Growth Paper prepared by
Turley (with the support of Edge Analytics). This provided an updated analysis of housing need,
reflecting the “WG 2018-based sub national population and household projections, in addition
to other population estimated published since the first Deposit Revised LDP”. Despite, however,
the fact that the location for the new super-hospital had, by this stage, been narrowed down to
just three sites within a 5-mile area (2 in Whitland, and 1 in St Clears), the implications of the
hospital on housing need/growth was not a consideration in the adjustments to the figures.
Policy SP 1 projects a target of 9,704 new homes to meet the identified housing requirement of
8,822, informed by the above assessments. The aim of Policy SP 1 is to facilitate the delivery of
new homes in sustainably located areas. The assessments which informed these projected
figures were undertaken before the implementation of the hospital was confirmed in the area.
Therefore, the housing need is greater than what is identified, and the distribution of housing
should furthermore be directed to sustainably located areas near the hospital.
Supporting text 11.11 of Policy SP 1 states that:
“by ensuring that our housing growth requirements are reflective of, and are in support of our
economic ambitions, it allows for a co-ordinated and integrated approach to ensure that the
shared role for economic growth is not in isolation of housing and vice a versa.”
It has been acknowledged that the search for a suitable location for the new hospital has made
progress since the publication of the Preferred Strategy. The search has narrowed down to only
three sites, all situated within a 5-mile radius of the promotion site.
Two of these locations are within a very close proximity to the development site (See fig.1 and
fig. 2 below). Considering the significant potential for job creation throughout both
construction and operation that the hospital is expected to bring, it is imperative that the LDP
can provide adequate levels of new homes in sustainable locations near the hospital.

The inclusion and delivery of this housing allocation would make a significant contribution to
the critical objectives of Camarthenshire County Borough Council and overreaching aims of
Policy SP 1. The proposed development site is capable of accommodating around 9 new
dwellings, which are sustainably located, and easily accessible from all of the three potential
employment sites. The proposed scheme would serve to promote economic growth for the
local community, while simultaneously maximising employment prospects that prioritise Active
Travel as a fundamental principle.
Strategic Policy SP3 outlines a settlement framework for the sustainable distribution of
residential development.
Fig. 3 Settlement Framework
Supporting paragraph 11.72 states that:
“The settlement framework will, in conjunction with specific policies, also guide the
consideration of appropriate sustainable locations - with access to services and facilities - and
scale of other developments (including employment).”
The proposed site has been classified as a Tier 2 Service Centre Settlement within Cluster 6 of
the spatial plan. The primary focus of new development will be directed towards the upper
tiers of this settlement hierarchy. The necessity for residential developemnt in St. Clears, in
order to be designated as a Tier 2 Service Centre was established through evidence of
anticipated growth in the region, taking into account known employment growth levels. This
was assessed before the hospital's implementation was confirmed. Thus, the inclusion and
implementation of the hospital in this location has subsiquently intensified the need for
residential development in the area further than what is identified within the Revised Local
Developement Plan.
Considering the current housing demand, the proposed site is a suitable location to aid in
supplying more high quality homes to meet the increasing demand as a result of the hospital
development. The promotion of this site for residential development would be consistent with
the Preferred Strategy and support the planned growth of Carmarthenshire and Whitland.


See Candidate Site Representation Document
See 2nd Deposit Plan LDP Supporting Document

Amend the plan to include the site

This representation comprises an objection to the exclusion of these areas of
land from the development limits for Porthyrhyd – a designated Tier 3
Sustainable Village.
The residential element of the scheme would comprise a high quality phased
development and would draw on local Welsh vernacular architectural design
elements, making every effort to be sustainable, both through the
employment of local contractors, the use of local suppliers, and in the long
term, through the provision of residential units ideally located in proximity to
the A48 strategic transport corridor. Likewise, the development will be within
convenient walking distance of village services and facilities, and also the
positive recreational benefits of the nearby National Botanic Garden of Wales.
Allocating the proposer’s land will aid in keeping development adjacent to the
A48 and its slip road, creating a nuclear form in this part of Porthyrhyd, rather
than extending further along the B4310 and perpetuating ribbon development
as proposed by allocation SuV20/h1. The proposer’s land is readily deliverable
and appropriate to a phased development scheme.
The site’s inclusion would not lead to additional environmental pressure, but
instead will foster sustainable growth and allow for a wider choice of housing
type within this Tier 3 Sustainable Village. Its development would be in
keeping and in character with the settlement and will ensure a readily
deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature
conservation interests.
Furthermore, the 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 worth noting that the proposed scheme includes areas of landscaping that
will function as communal greenspace, thus providing a key community benefit
which will enhance both the physical and mental well-being of residents.
The inclusion of this land within revised development limits would be fully
supported.

Amend Plan to include the site

This representation comprises an objection to the exclusion of these areas of
land from the development limits for Porthyrhyd – a designated Tier 3
Sustainable Village.
The residential element of the scheme would comprise a high quality phased
development and would draw on local Welsh vernacular architectural design
elements, making every effort to be sustainable, both through the
employment of local contractors, the use of local suppliers, and in the long
term, through the provision of residential units ideally located in proximity to
the A48 strategic transport corridor. Likewise, the development will be within
convenient walking distance of village services and facilities, and also the
positive recreational benefits of the nearby National Botanic Garden of Wales.
Allocating the proposer’s land will aid in keeping development adjacent to the
A48 and its slip road, creating a nuclear form in this part of Porthyrhyd, rather
than extending further along the B4310 and perpetuating ribbon development
as proposed by allocation SuV20/h1. The proposer’s land is readily deliverable
and appropriate to a phased development scheme.
The site’s inclusion would not lead to additional environmental pressure, but
instead will foster sustainable growth and allow for a wider choice of housing
type within this Tier 3 Sustainable Village. Its development would be in
keeping and in character with the settlement and will ensure a readily
deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature
conservation interests.
Furthermore, the 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 worth noting that the proposed scheme includes areas of landscaping that
will function as communal greenspace, thus providing a key community benefit
which will enhance both the physical and mental well-being of residents.
The inclusion of this land within revised development limits would be fully
supported.

BROWNFIELD SITES -policy
In respect of all unused sites , particularly brown field but not ruling out Housing/retail sites , that have been vacant for more than eg. 25 years then the planning allocation should automatically be mixed use or white land. There is no reason such sites cannot be used for allotments, parking, leisure, innovative trendy housing even built with containers for example.

The former creamery site in Whitland SR/163/007 is an example of such central dereliction and a shameful waste of an area close to services that could have been useful to the town and surrounding areas. It is an eysore and affects visual amenity and the wellbeing of residents.
The inspector, as I understand, removed the lower part of the site from the development line due to a flood plain. Given that the reason for the great flood of 1986 in Whitland is rectified and there are further flood barriers this decision was unfortunate and the site could not even be used for allotments, community car parking, retail and even much needed Housing. Going forward if climate change may impact any parts of the site then it is up to the owners of such sites to provide the requisite studies to suit the proposed uses.
Whitland has excellent transport infrastructure and good work opportunities but needs something exciting doing with this disused site.


RURAL TRANSPORT
There is only a remote chance of rural buses that can be run economically and sustainably on a daily basis at times to suit people who would otherwise use a car.
Disused railway lines such as that was formerly in the UDP as a route from Whitland to Cardigan ( Cardi Bach ) should be protected as these routes were instrumental in the sustainibility and economic generation of rural hamlets. Following closure these villages en route became stagnant. Old railway routes use as pathways and cycle routes enables safe connections between communities and these can used by young people to prevent rural isolation and reliance on parental taxis.. With the increase in the use of electric bikes it ebables Community for less athletic persons as well as potential tourism. Cafes or local historic features along the routes enable rural enterprise supporting the circular economy.

WHITLAND TOWN CENTRE
This designated outline is inaccurate in my view as it omits various very longstanding retail units of half a century or more.see attached map for proposal as a matter of fact.


LOCAL CONCERN
SR/163/010 Residents are concerned about the velocity of the off flow from the hill above this development and indeed this velocity lifted tarmac off a bridge and it does cause localised flooding. The site lacks footways and any such development requires very careful management of downward water flows on both sides of this allocation in case homes here suffer from such velocity and mud spills from the hillside above as do current residences.




HOUSING
Rural needs are greatly restricted by the policies related to affordable Housing. There is a greater level of self employment in rural areas and to provide work life balance homes of sufficient size are resticted by WAG Policy. A home Office, utility area sufficient to manage outerwear from rural surroundings, workshop are essentials to manage rural living in a fast paced environment. Some young people do return after study or working away but much of this depends upon availibility of skilled employment and the possibility of creating a home for life and self employed or remote work in one unit. Affordibility of a larger build size is a restriction but does not take into account that the build may be incremental and if budget is restricted (according to figures presented for build size) then persons can complete the more expensive internal works as budget becomes available.
People (and animals) are healthier in well ventilated, well designed spaces.
Affordable homes generally do not have sufficient garden size as did the old council homes and Commercial estates, in my view, are too uniform. Whilst budgets can be restrictive there is no excuse for inadequate design.
There has not been a housing needs survey for this revision and reliance on the Housing register is not a reflection of the many aspirations of those who wish to return home to contribute to the Community raise families or retire on their family farms.
The same applies to rural enterprise which is essential to the circular economy. Supporting SMEs to thrive where they can find a niche keeps a rural area vibrant and innovative.
Land banking that is tied up in pension schemes perhaps is another issue that restricts potential from none allocated sites.
I recognise this may not be as concise or eloquent as other submissions but there seems to be a mismatch of understanding between urban and rural living needs.

No change in respect of this representation, however attention is drawn to the respondent's other representations: 5683, 5684 & 5685.

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

-Facilitating accessible and healthy environments;

-Creating and sustaining communities; and

-Maximizing environmental protection and limiting environmental impact.

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

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

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

SP19 Waste Management

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

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

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

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

SP1 Strategic Growth

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

SP2 Retail and Town Centres

Having a Community lead facility on this site benefits everyone.

SP3 Sustainable Distribution — Settlement Framework

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

SP6 Strategic sites

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

SP7 Employment and the Economy

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

SP8 Welsh Language and Culture

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

SP9 Infrastructure

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

SP12 Placemaking and Sustainable Places

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

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

SP14 Maintaining and Enhancing the Natural Environment

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

SP15 Protection and Enhancement of the Built and Historic Environment

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

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

SP18 Mineral Resources

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

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

References

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

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

No change in respect of this representation, however attention is drawn to the respondent's other representations: 5687, 5688 & 5689.

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

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

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





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

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




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

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


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

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

No change in respect of this representation, however attention is drawn to the respondent's other representations: 5691, 5692 & 5693.

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

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

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

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

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

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

No change in respect of this representation, however attention is drawn to the respondent's other representations: 5695, 5696 & 5697.

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

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

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

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


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

No change in respect of this representation, however attention is drawn to the respondent's other representations: 5699, 5700 & 5701.

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