HOM1: Dyraniadau Tai

No change in respect of this representation, however attention is drawn to the respondent's other representations: 5703, 5704 & 5705.

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

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

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

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

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

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

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

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

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

No change in respect of this representation, however attention is drawn to the respondent's other representations: 5707, 5708 & 5709.

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

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

Attention is drawn to the respondent's other representation - 5711 which relates to a reclassification of the site.

[Email text and Q5 in form left blank. Refers to ref SeC10/h4 under Q1 & Q4]

No change in respect of this representation, however attention is drawn to the respondent's other representations: 5713, 5714 & 5715.

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

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

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

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


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

No change

Thank you for consulting Cyfoeth Naturiol Cymru/National Resources Wales (NRW) on the above, which was received on 17 February 2023.

We welcome the opportunity to provide comments on your Second Deposit Revised
LDP.

We support the intent of the plan’s policies and proposals to enable the delivery of sustainable development and ensure social, economic, environmental and cultural
well-being goals are all suitably balanced in the decision-making process, so the right development occurs in the right place.

We also acknowledge that you have taken on board advice from our previous correspondence which has enabled positive provisions in the second Deposit Plan
both in policy terms and regarding allocation of sites. However, there are issues with the latest draft which we feel challenge the Soundness of the Plan. These key
issues are highlighted below:
• SAC rivers / Habitats Regulations Assessment (HRA)
• Flood risk regarding the following sites allocated for housing under Strategic Policy 4: A Sustainable Approach to Providing New Homes
PrC3/h33 Llys Dolgader
PrC3/h19 Land off Llys y Nant
SeC19/h1 Land at Park View, Whitland
Sec19/h2 Land at Whitland Creamery
• Flood risk regarding allocation - PrC2/GT1 – Land at Penyfan, Trostre, Llanelli, under Strategic Policy SP 10: Gypsy and Traveller provision.
• Biodiversity and ecosystem resilience regarding six allocations (two housing and four employment).
In addition, to matters of soundness we also advise that some refining/clarity be made to the plan in respect of several policies and supporting text to ensure the
robustness of the plan.

Our detailed comments on the plan and supporting documents can be found in the annexes to this letter.

Please note that our comments are without prejudice to any comments we may wish to make when consulted on any subsequent formal planning application submissions
to develop any of the land identified within the plan. At the time of any other consultation there may be new information available which we will need to consider
in providing our formal advice.

Finally, we look forward to continuing to work closely with you to progress the plan and trust these comments are of assistance. If you have any queries, or if you require any further information, please do not hesitate to contact us at the above address.

No change in respect of this representation, however attention is drawn to the respondent's other representations:
5807; 5808 and 5810.

Thank you for the opportunity to reply to your plans. With the support of the Tirycoed Road Campaign Group (TRCG), I should like to make the following observations about your proposals. 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 are protected habitats. I 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).

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 know, 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 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 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. 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 particularly poor 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 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 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 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.
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 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


Thank you for the opportunity to reply to your plans. With the support of the Tirycoed Road Campaign Group (TRCG), I should like to make the following observations about your proposals. 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 are protected habitats. I 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).

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 know, 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 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 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. 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 particularly poor 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 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 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 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.
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 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.

Include site within Plan

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

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

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

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

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

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

No change in respect of this representation, however attention is drawn to the respondent's other representations: 5831, 5832 & 5833.

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, I myself have waitited over 9 days for a telephone appointment and this is not an uncoomon occurance, I do ot feel there is capacity for anymore reisdents in this area. Plus 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. There have been a number of times when we have had considerable amounts of water flowing down Tirycoed Road, removing the Rhos pasture and adding more roads and houses will make this worse. 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


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, I myself have waitited over 9 days for a telephone appointment and this is not an uncoomon occurance, I do ot feel there is capacity for anymore reisdents in this area. Plus 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. There have been a number of times when we have had considerable amounts of water flowing down Tirycoed Road, removing the Rhos pasture and adding more roads and houses will make this worse. 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.

Include the site as a residential allocation.

Dear Forward Planning,

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

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

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

Amend Plan to include the site

See attached document

No change requested

HOM1: Housing Allocations: Why have SeC16/h2 and SeC16/h3 been removed from being identified as Residential Allocation? Why has the Development Limits boundary been altered with the removal of SeC16/h3?

(pic attached of the previous version so you know what I'm referring to…I don’t think those sites have been built on already have they?)

11.351 Why does the Air Quality Management Areas (AQMAs) for Llandeilo not appear as a layer on the interactive map?

(I don’t think I’ve missed it have I? https://carmarthenshire.opus4.co.uk/planning/localplan/maps/2nd-deposit-revised-carmarthenshire-local-development-plan-2018-2033-proposals-map#/center/51.8874,-3.9964/zoom/16/baselayer/b:31/layers/o:9423,o:9424,o:9435,o:9436,o:9437,o:9446,o:9447,o:9448,o:9449,o:9524,o:9525,o:9526,o:9527,o:9528,o:9529,o:9530,o:9531,o:9532,o:9533,o:9560,o:9561,o:9562,o:9563,o:9564,o:9579,o:9580 )

11.550 Towy Valley Transport Corridor (Towy Valley Cycleway) This is described as ‘to Llandeilo’. The current planning application for this does not include any connection to Llandeilo.

No change requested

HOM1: Housing Allocations: Why have SeC16/h2 and SeC16/h3 been removed from being identified as Residential Allocation? Why has the Development Limits boundary been altered with the removal of SeC16/h3?

(pic attached of the previous version so you know what I'm referring to…I don’t think those sites have been built on already have they?)

11.351 Why does the Air Quality Management Areas (AQMAs) for Llandeilo not appear as a layer on the interactive map?

(I don’t think I’ve missed it have I? https://carmarthenshire.opus4.co.uk/planning/localplan/maps/2nd-deposit-revised-carmarthenshire-local-development-plan-2018-2033-proposals-map#/center/51.8874,-3.9964/zoom/16/baselayer/b:31/layers/o:9423,o:9424,o:9435,o:9436,o:9437,o:9446,o:9447,o:9448,o:9449,o:9524,o:9525,o:9526,o:9527,o:9528,o:9529,o:9530,o:9531,o:9532,o:9533,o:9560,o:9561,o:9562,o:9563,o:9564,o:9579,o:9580 )

11.550 Towy Valley Transport Corridor (Towy Valley Cycleway) This is described as ‘to Llandeilo’. The current planning application for this does not include any connection to Llandeilo.

I would suggest that the land areas referred to above are treated as SR/086/051 and made part of the Eco Park so that water can be managed properly.

I am concerned that the planned residential and commercial developments at SR/086/049 AND SR/086/050 in Llanelli will increase the water levels of the area and add to the danger of flooding. Much of the land is waterlogged for most of the winter. Drainage in the area is already a problem and further development will exacerbate it.