HOM3: Cartrefi mewn Pentrefi Gwledig

Maintain the existence of development limits in Tier Four Rural Villages.

I am objecting to the removal of existing development limits in Tier Four Rural Villages. Removal of limits could lead to abuse of the system with proposals to build in open fields e.g. Candidate Site SR/013/001 in Broad Oak.

No change to Plan.

We are instructed by Mr. M. Thomas to make a formal representation in relation to the
settlement of Cross Inn within the Second Deposit Draft of the Carmarthenshire Local
Development Plan.
Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/166/005, seeking the inclusion of their land within the development limits of Cross Inn as
part of the Replacement Local Development Plan.
The Council published a First Deposit Draft of the Replacement Local Development Plan in
January 2020. At that time, the Council revealed its analysis of a new “Settlement
Framework” as referred to within Policy SP3 “Sustainable Distribution – Settlement
Framework”, which categorised settlements in the County into Clusters and subsequently
into Tiers. We note that the Candidate Site Register has distinguished Cross Inn (SR/166)
as a separate settlement from Laugharne (SR/075) for the purposes of assessment of
representations. “Cross Inn” is accordingly listed as a Tier 4 “Rural Village”
The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission. We note that
our client’s land was considered as part of this process and as a result the Authority
concluded as follows: “The site is within a Tier 4 settlement and therefore any site proposal
will be considered under policies set out within the revised LDP.”

We note that Cross Inn continues in the Second Draft to be categorised as one of the Tier 4
“Rural Villages”, under Policy SP3. It forms one of a number of Rural Villages named, and
reproduced below, within “Cluster 6 – Western Carmarthenshire.”

Policy HOM3 of the Deposit Draft deals with small extensions to existing rural villages and
so provides a useful series of criteria in determining where such extensions would be
acceptable, namely the following:
• Minor infill or a small gap between the existing built form; or
• Logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
• Conversion or the sub-division of large dwellings.
Our clients land lies as part of the small holding of Parson’s Leys and is noted for fronting
the southern flank of the A4066 St. Clears to Laugharne main road, as shown below as
edged in red upon the location plan at Figure 1. It is notable that the opposite, northern flank
of the road is conspicuous by a continuous built-up frontage of individual residential
properties, all orientated to front the road. Parson’s Leys Cottage lies to the immediate
eastern side of the field frontage, and the main farmhouse and compacted range of holiday
cottages lie to the south off a separate vehicular driveway access. Established woodland lies
bordering the western perimeter of the field frontage.
The field frontage accordingly lies as an ideal small-scale residential opportunity to provide a
“logical extension / rounding-off to the development pattern that fits in with the character of
the village form and landscape” as required above under the provisions of Policy HOM3.

Our client has therefore given careful consideration to the categorisation of Cross Inn as a
Tier 4 “Rural Village”, and accordingly wholeheartedly welcomes and supports the decision
of the Authority to include the village in those settlements listed under Tier 4 within Cluster 6
of the Carmarthenshire Local Development Plan.

see attachments

No change to the Plan

Following your invite to a drop in session, I would like to confirm that I agree with the HOM3 plan in rural/ local areas. I have a site in Cross Inn, Laugharne which I think would be very suitable for HOM3. The site is a 10 acre field adjacent to oak trees. I do not want a large development, just building for myself and my daughter/ family who has moved to be near us to support/ care for us due to health and age.
I have previously submitted a plan for L. D. P. with a surveyors report, which was favourable to the criteria you wanted.
As I have stated I do not want a large development just for myself / husband and my daughters family.
The site is
a) On a bus route
b) New business / shops etc.
c) New local school which would benefit as my daughters have three children
d) New local hospital (possibly nearer when new hospital built)
e) New railway station
f) Not on a flood plain
g) Access to water and electricity and other utilities

I am presently renting from private landlord and endure quite a lot of stress in case they decide to sell, leaving me homeless.
I appreciate that HOM3 has to be passed by a Welsh Office etc., but the benefits to rural communities would be great.

No change

Introduction

1.1 Further to Carmarthenshire County Council’s ‘Second Deposit Revised Local Development Plan’
consultation, Asbri Planning on behalf of the client, T.H James and M.A. Tomos wish to provide
a statement that supports the principles of Policy HOM3 (Homes in Rural Villages).

1.2 Asbri Planning, on behalf of the client, T.H James and M.A. Tomos previously submitted a
candidate site submission for a plot of land within Broad Oak, Llandeilo as part of the first call
for candidate sites in 2018 (see Appendix A).

1.3 In the First Deposit Revised LDP Written Statement, Policy HOM3 (Homes in Rural Villages)
stated:
“In those settlements identified as rural villages under Policy SP16, proposals for 1 to 4 dwellings
will be permitted for the following:
 minor infill of a small gap between the existing built form; or,
 logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
 conversion or the sub-division of large dwellings.
Such proposals will be subject to other detailed planning considerations set out within LDP
policies.
Reference made to the guidance on acceptable plots in the County's rural villages (see below).
Proposals which exceed the 20% cap above the number of existing homes in the settlement, as
at the LDP base date, will not be permitted except where they conform to Policy AHOM1 in
relation to the provision of affordable homes”.

1.4 The Second Deposit Revised LDP Written Statement for the relevant policy noted:
“In those settlements identified as rural villages under Policy SP3, proposals for 1 to 4 dwellings
will be permitted for the following:
 minor infill of a small gap between the existing built form; or,
 logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
 conversion or the sub-division of large dwellings.
Such proposals will be subject to other detailed planning considerations set out within LDP
policies.
Reference made to the guidance on acceptable plots in the County's rural villages (see below).
Proposals which exceed the 10% cap above the number of existing homes in the settlement, as
at the LDP base date, will not be permitted except where they conform to Policy AHOM1 in
relation to the provision of affordable homes”.

1.5 The policies are identical, apart from the fact that between the first and second draft written
statement, a decision has been made to halve the cap concerning proposals that exceed the
number of dwellings currently within a settlement.

2. Reasoning behind supporting Policy HOM3

2.1 Housing need within rural areas of Wales has always been an issue. In 2022, 96% of dwellings
within the settlement of Cwm-yr-Eglwys in Pembrokeshire were holiday homes. Within Future
Wales, it notes that in rural areas “Where housing, employment, key services and infrastructure
are not sufficient to accommodate current or future needs, or are not easily accessible, the
resilience and sustainability of an area may be undermined, possibly leading to economic and
social decline”.

2.2 Paragraph 9.3 of the Revised Draft LDP correctly recognises the role that smaller settlements
within Carmarthenshire have in delivering local and sustainable growth. This is further
expanded upon in Paragraph 9.16 which again correctly recognises that by supporting growth
of a proportionate scale in such areas, a positive contribution can be made towards the long
term sustainability and cohesiveness of rural communities and the rural economy. One such
positive impact relates to the promotion of the Welsh Language as recognised in Paragraph 9.18 of the Revised Draft LDP.

2.3 Policies such as HOM3 ought to be included within the next LDP as at present, the lack of
rural housing opportunities is having a detrimental effect on rural communities, companies
and the economy in rural settings which is currently deemed to be an important contributor
to labour shortages within sectors such as tourism and agriculture.

2.4 Having said this, addressing the issue ought to be done in a manner that considers the current
makeup of the rural setting therefore promoting small scale residential developments in a
proportionate manner is considered appropriate. There has previously been examples of an
over dependence on some larger sites which has impacted the resilience of housing land supply,
with these larger sites not delivering the homes and jobs they previously promised. A different
approach is warranted in certain areas of Carmarthenshire, with a large proportion of the County
being rural in nature.

2.5 Allowing a sustainable amount of growth in rural villages by adding a small number of homes
that represent a minor infill or logical extension of the existing built form appears far more
realistic, allowing increased opportunity to focus on aspects such as design which matches the
character of the neighbouring surroundings. In addition to this, the nature of Policy HOM3 will
enable the location of these additional dwellings to enhance and maintain the vitality of rural
communities.

2.6 The policy in question aligns neatly with Policy 4 of Future Wales – Supporting Rural
Communities. This policy sets out that the Welsh Government supports sustainable and
vibrant rural communities. The policy states that “Strategic and Local Development plans must
identify their rural communities, assess their needs and set out policies that support them”. It
also notes the importance of providing affordable and market housing within these
settlements, therefore implementing this policy will contribute to a wider national strategy for
rural settlements.

2.7 The Policy also aligns well with the seven well-being goals of the Well-being of Future
Generations Act, including ‘A Resilient Wales’, ‘A Wales of Cohesive Communities’, and ‘A Ales
of Vibrant Culture and Thriving Welsh Language’.

2.8 Within the current deposit statement there is an increased focus on rural areas. Addressing
this housing matter is one way ensuring the resilience of rural villages, however factors such
as employment and transport ought to also be considered. It is evident that the policy would
not benefit only one settlement, with the policy able to sustainably increase the number of
dwellings within 76 rural villages spread across 6 clusters as noted in Policy SP3 of the Deposit
LDP. Such proportionate growth is apt for these tier 4 settlements as development in the
countryside needs to be of a scale that maintains the essential character of the area, whilst
meeting the housing needs of local individuals.

2.9 The Moving Rural Carmarthenshire Forward Report conducted in 2019 stated that in order to
make rural areas attractive for younger people adequate housing needed to be provided to
ensure that they could remain within their local communities. The report stated that a shift
was required from depending on large housing developments to focusing more on smaller
scale residential developments that would address housing requirements in rural settlements.
A survey produced during the report revealed only 15% of respondents were happy with the
housing provided within their rural area.

2.10 It is imperative that this policy is included to ensure that a sustainable and proportionate
amount of housing growth is allowed in rural areas of Carmarthenshire during the plan
period. The lack of such housing has unfortunately resulted in younger individuals departing
rural areas, looking for housing and work in urban areas which is having a detrimental impact
upon the resilience of rural villages.

2.11 This policy will provide for local individuals, and also individuals who may wish to move back
home to be nearer friends and family. Moreover, promoting small scale residential development
is far likelier to meet identified local needs, as its unlikely there is a demand for a large-scale
residential proposal within the rural villages noted in the LDP. The targets set out in the policy
for rural villages in terms of housing are realistic, and therefore can be achieved over the plan
period, and thus the policy is considered to be sound.

3. Case Study – Broad Oak, Llandeilo

3.1 Broad Oak is a tier 4 rural village that contains circa 27 dwellings at present. Any housing
development to occur there during the plan period would have to accord with Policy HOM3.
The acceptable plots of land to meet the requirements of this policy are noted below:
1) Infill sites within these rural villages will take priority over other locations;
2) Where appropriate, sites adjoining a rural village are also acceptable. Such sites will be
required to adjoin the boundary of one property which forms part of the rural village group.
All proposals which adjoin a group (as opposed to infill sites) will be required to
demonstrate the following:
 there is an existing physical or visual feature which provides a boundary for the
group - reducing pressure for unacceptable ribbon development or rural sprawl;
 where such a feature does not exist, there should be potential for such a feature to
be provided so long as it is in character with the scale and appearance of the group.

3.2 The candidate site submission provided in Appendix A shows that a proposed residential
development would adjoin dwellings that already lie within the village. It is evident that the
proposal for up to 6 semi-detached dwellings or two detached dwellings forms a logical
extension to the settlement of Broad Oak, and would not disrupt its character. This is evidence
that this policy would work in such locations as Broad Oak.

3.3 Broad Oak could gain additional dwellings if the cap figure from the first deposit plan was
adopted. Based on the existing number of dwellings in Broad Oak, a 10% cap would only permit
the construction of two dwellings, whereas a 20% cap would permit five dwellings to be erected
during the plan period up to 2033. Due to the cap being put in place, no rural village will be
flooded with additional dwellings as a result of the replacement LDP, however the first deposit
plan offers an opportunity to provide more homes that would enable more people to reside in
rural areas of Carmarthenshire.

3.4 The same reasoning behind the cap is provided in both written statements, however no
justification is provided over it`s halving for the second plan. For example, the image showing
the addition of two detached dwellings to Broad Oak still shows some land to the west where
another two dwellings could be added. This would not go against the cap provided in the first
deposit plan, whilst still being a logical extension to the village and not impacting the character
of this countryside settlement. Furthermore, Broad Oak is in close proximity to the new Tywi
Valley cycle path whilst implementation of this policy would benefit the wider area, including
the recently opened Dryslwyn Business Park that lies a short distance west of the proposed
location of the dwellings further enhancing the economic capability of this rural area.

3.5 It is considered that Policy HOM3 is a policy that has credibility, as evidenced in the applicant’s
previous candidate site submission example. Having said this, the higher cap provided in the
first deposit plan should be reconsidered as that would allow a proportionate but greater
number of dwellings to be built within rural villages without negatively impacting the
settlement. If this is not possible, consideration should be given to a 15% cap rather than the
proposed 10% cap.

4. Conclusion

4.1 In summary, Policy HOM3 (Homes in Rural Villages) is a key policy that addresses an urgent
matter within rural Carmarthenshire. Rural villages will benefit from additional small scale
housing developments that will take into consideration the existing pattern of the settlement.

4.2 One of the findings from the Living Locally in Rural Wales paper published in 2022 was the need
for “Continuing to focus housing development within established, well connected communities”,
which this policy advocates. This policy addresses housing in rural settlements of
Carmarthenshire in a realistic manner which should contribute towards overcoming the issues
currently faced by rural areas.

4.3 Providing further dwellings will make these rural villages more attractive to people, enticing
people back to these areas and encouraging young families to remain within their communities.
In total, 76 rural villages could benefit from this policy which would have an enormous positive
impact on rural Carmarthenshire.

4.4 This statement is also supported by a 2nd Deposit Revised LDP Representation Form that states
our support for Policy HOM3

No change to Plan.

This representation is to propose a new site for residential development.

This candidate site lies within the villages of Carmel / Temple Bar. Both these villages are conjoined as one community which straddles the A476 road which
passes through both settlements. Over past decades residential properties have been constructed primarily alongside this road.

The revised local development plan 2018-2033 makes provision, under policy SP3 and within HOM 3: Homes in Rural Villages, for small developments of 1 - 4 dwellings to be permitted so long as they meet certain criteria in relation to infill sites, or sites adjacent to a rural village within physical boundaries, logical extension/rounding off, all so long as ribbon development does not take place.

In particular in respect of housing allocation, HOM 3 and HOM 4 appear to enable the creation of small sites of either single or just a few dwellings, so as to cater for the strong demand from those seeking to build themselves a family and/or retirement home. The main towns of the county appear to be well provided for with large allocations of new housing, and well suited to the
requirements of national developers, with HOM 3 and 4 enabling small local builders to flourish.

The revised LDP plan 2018-2033 seeks additional land suited for residential development and we would submit that this candidate site as eminently suited for such future residential development.

1. The site, which is edged red on the attached plan, lies adjacent to the main
road and has good frontage to this road with no adverse highway concerns.
There is an existing access which could easily be improved in order to create a
safe vehicular access to serve the site with ample visibility to the latest highway
requirements.

2. The site is directly adjacent to existing dwellings, and would not constitute a
ribbon development. It meets the criteria of acceptable plots set out in Policy
HOM3; Homes in Rural Villages.

3. Mains water electricity and drainage serve the village and pass adjacent to the site, so services are readily available.

4, The site has strong physical boundaries of existing mature hedges containing
the site on two sides so as not to be an intrusion into open countryside. It is
currently an amenity area used with our bungalow home nearby. It is ideally
suited to two individual building plots to enable the construction of
houses/bungalows. There is ample demand for such plots, but a shortage of
them, and this site would be ideal and in keeping with the HOM 3 policy of
homes in rural villages.

We do hope you will consider this site as a suitable candidate for a new site
allocation.

No change to Plan.

This representation is to propose a new site for residential development to
incorporate a small area already within the existing development limits.

This candidate site lies within the villages of Carmel / Temple Bar. Both these
villages are conjoined as one community which straddles the A476 road which
passes through both settlements. Over past decades residential properties have
been constructed primarily alongside this road.

The revised local development plan 2018-2033 makes provision, under policy
SP3 and within HOM 3: Homes in Rural Villages, for small developments of 1 - 4
dwellings to be permitted so long as they meet certain criteria in relation to infill
sites, or sites adjacent to a rural village within physical boundaries, logical
extension/rounding off, all so long as ribbon development does not take place.
In particular in respect of housing allocation, HOM 3 and HOM 4 appear to
enable the creation of small sites of either single or just a few dwellings, so as to
cater for the strong demand from those seeking to build themselves a family
and/or retirement home. The main towns of the county appear to be well
provided for with large allocations of new housing, and well suited to the
requirements of national developers, with HOM 3 and 4 enabling small local
builders to flourish.

The revised LDP plan 2018-2033 seeks additional land suited for residential
development and we would submit that this candidate site as eminently suited
for such future residential development.

1. The site, which is edged red on the attached plan, lies adjacent to the main
road and has good frontage to this road with no adverse highway concerns.
There is a detached single garage already on the site and part of the site [to the
rear of the garage] is already included within existing development limits. There
is an existing access to the garage which could easily be improved in order to
create a safe vehicular access to serve the site with ample visibility to the latest
highway requirements.

2. The site is directly adjacent to existing dwellings, and would not constitute a
ribbon development. It meets the criteria of acceptable plots set out in Policy HOM3; Homes in Rural Villages. Part of the site is already included within
development limits but this area is inadequate for a single plot, and a further
area to the rear[ that is behind the garage] would be needed to create a small
single plot. The garage is at present a store as we already have a larger existing
garage to serve our bungalow home which is next door. The loss of the garage
would therefore be of no consequence as we have other access, parking and
garage to our bungalow nearby.

3. Mains water electricity and drainage serve the village and pass adjacent to the
site, so services are readily available.

4, The site has strong physical boundaries of a fence to one side adjacent to a
house named Greenhill, and on the other side is an existing mature hedge which
would be a natural boundary, as recognized already by it being the development
limit boundary. The addition of a small area to the rear would not be any
intrusion into the countryside, and would then be ideally suited to a single
individual building plot to enable the construction of a house/bungalow. There is
ample demand for such plots, but a shortage of them, and this site would be
ideal and in keeping with the HOM 3 policy of homes in rural villages.
We do hope you will consider this site as a suitable candidate for a new site
allocation.

No changes to the Plan

This representation is to propose a new site for residential development.

This candidate site lies within the villages of Carmel / Temple Bar. Both these
villages are conjoined as one community which straddles the A476 road which
passes through both settlements. Over past decades residential properties have
been constructed primarily alongside this road.

The revised local development plan 2018-2033 makes provision, under policy
SP3 and within HOM 3: Homes in Rural Villages, for small developments of 1 - 4 dwellings to be permitted so long as they meet certain criteria in relation to infill sites, or sites adjacent to a rural village within physical boundaries, logical extension/rounding off, all so long as ribbon development does not take place.

In particular in respect of housing allocation, HOM 3 and HOM 4 appear to enable the creation of small sites of either single or just a few dwellings, so as to cater for the strong demand from those seeking to build themselves a family and/or retirement home. The main towns of the county appear to be well provided for with large allocations of new housing, and well suited to the
requirements of national developers, with HOM 3 and 4 enabling small local builders to flourish.

The revised LDP plan 2018-2033 seeks additional land suited for residential development and we would submit that this candidate site as eminently suited for such future residential development.

1. The site, which is edged red on the attached plan, lies adjacent to the main
road and has good frontage to this road with no adverse highway concerns.
There is an existing access which could easily be improved in order to create a
safe vehicular access to serve the site with ample visibility to the latest highway
requirements.

2. The site is directly adjacent to existing dwellings, and would not constitute a
ribbon development. It meets the criteria of acceptable plots set out in Policy
HOM3; Homes in Rural Villages.

3. Mains water electricity and drainage serve the village and pass adjacent to the site, so services are readily available.

4. The site has strong physical boundaries of existing mature hedges containing
the site on three sides so as not to be an intrusion into open countryside. It is
currently an amenity area used with our bungalow home nearby. It is ideally
suited to two individual building plots to enable the construction of
houses/bungalows. There is ample demand for such plots, but a shortage of
them, and this site would be ideal and in keeping with the HOM 3 policy of
homes in rural villages.

We do hope you will consider this site as a suitable candidate for a new site
allocation.

No change to the Plan

Further to the publication of the above document, we have been asked by our Client to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the
proposed provisions of Policy HOM3 are of particular interest to our Client and indeed the
Community they form part of. As a result, we offer the following for the Authority’s
consideration, and Inspector’s in due course.

Policy HOM3 – Homes in Rural Villages
It is clear that Policy HOM3 seeks to rectify the deficiency of previous Development Plans
and their policies when it comes to addressing the housing needs and requirements of all
members of a rural community, in addition to those in direct social housing need. In order to
sustain, preserve or recover a community’s level of sustainability, it is vital that provision for
new housing is made available for all its members, irrespective of their social or economic
backgrounds. This then ensures a positive balance within such communities that will secure
their sustainability for the future, as under-provision of new housing in such settlements has
been a key factor in the decline and removal of many key community facilities (e.g. schools)
within them during previous Plan periods. It is considered that Policy HOM3, by in large
therefore, now makes a significant move towards ensuring that local planning policy in
Carmarthenshire goes some way to assist in securing this objective.

Notwithstanding the above, such rural communities and the settlements they relate to or
revolve around are somewhat smaller than established satellite villages and their associated
larger towns. Growth is therefore needed, but in a controlled manner to preserve
environmental aspects of a geographic area. Again, we and our Client welcome Policy
HOM3 criteria related aspects that allow, but at the same time control, growth of the related
Rural Villages. We also welcome that such growth should be limited to take place in the
following circumstances:
 Minor infill or a small gap between the existing built form; or
 Logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
 Conversion or the sub-division of large dwellings.
Support is therefore offered to the principle’s for supporting growth set out in Policy HOM3,
although concerns are raised with regards to the proposed level and calculation of the ‘cap’
set out within its provisions, and this is the subject of a separate representation.
Rural Village – Llansadwrn

The inclusion of Llansadwrn as a Rural Village of Cluster 5 is both welcomed and supported.
Llansadwrn is located at a sustainable location and benefits from a number of community
facilities and local services. It also has good access to nearby larger settlements that contain
a wide range of local services and community facilities. Its position on a regular bus service
route also further contributes to its sustainability level and as a suitable location for further
housing development to serve the immediate rural community.

In addition to the above, we would highlight that our Client’s land (edged red in Plan A)
represents one such opportunity for new housing development and being well related to the
existing form of the village, it would represent a logical round-off opportunity (as supported
by Policy HOM3) in the settlement.

Plan A

On behalf of our Client, we therefore fully support the designation of Llansadwrn as a Rural
Village under the provisions of Policy HOM3 capable of accommodating further open market
housing development following the adoption of the Carmarthenshire Local Development
Plan.

No change to the Plan.

Further to the publication of the above document, we have been asked by our Clients to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the
proposed provisions of Policy HOM3 are of particular interest to our Clients and indeed the
Community they form part of. As a result, we offer the following for the Authority’s
consideration, and Inspector’s in due course.

Policy HOM3 – Homes in Rural Villages
It is clear that Policy HOM3 seeks to rectify the deficiency of previous Development Plans
and their policies when it comes to addressing the housing needs and requirements of all
members of a rural community, in addition to those in direct social housing need. In order to
sustain, preserve or recover a community’s level of sustainability, it is vital that provision for
new housing is made available for all its members, irrespective of their social or economic
backgrounds. This then ensures a positive balance within such communities that will secure
their sustainability for the future, as under-provision of new housing in such settlements has
been a key factor in the decline and removal of many key community facilities (e.g. schools)
within them during previous Plan periods. It is considered that Policy HOM3, by in large
therefore, now makes a significant move towards ensuring that local planning policy in
Carmarthenshire goes some way to assist in securing this objective.

Notwithstanding the above, such rural communities and the settlements they relate to or
revolve around are somewhat smaller than established satellite villages and their associated
larger towns. Growth is therefore needed, but in a controlled manner to preserve
environmental aspects of a geographic area. Again, we and our Clients welcome Policy
HOM3 criteria related aspects that allow, but at the same time control, growth of the related
Rural Villages. We also welcome that such growth should be limited to take place in the
following circumstances:

 Minor infill or a small gap between the existing built form; or
 Logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
 Conversion or the sub-division of large dwellings.

Support is therefore offered to the principle’s for supporting growth set out in Policy HOM3,
although concerns are raised with regards to the proposed level and calculation of the ‘cap’
set out within its provisions, and this is the subject of a separate representation.

Rural Village – Felindre
The inclusion of Felindre as Rural Village of Cluster 5 is both welcomed and supported.
Felindre is located at a sustainable location with good access to a nearby larger settlement
that contains a wide range of local services and community facilities. Access to this
settlement is possible by non-motorised means and the village is also positioned on a
regular bus service route, giving it good access to further settlements of the County and their
associated facilities and services. Its sustainable location therefore merits its designation as
a Rural Village to enable it to facilitate further housing development to serve the immediate
rural community.

In addition to the above, we would highlight that our Clients land (edged red in Plan A)
represents one such opportunity for new housing development and being well related to the
existing form of the village, it would represent a logical extension opportunity (as supported
by Policy HOM3) in the settlement.

Plan A

In addition, with our Clients owning the directly adjoining area of land, any such development
would also be capable of adhering to the requirements of Natural Resources Wales with
regards to the treatment of phosphates from any new development.

On behalf of our Clients, we therefore fully support the designation of Felindre as a Rural
Village under the provisions of Policy HOM3 capable of accommodating further open market
housing development following the adoption of the Carmarthenshire Local Development
Plan.

No change to the Plan.

Further to the publication of the above document, we have been asked by our Client to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the
proposed provisions of Policy HOM3 are of particular interest to our Client and indeed the
Community they form part of. As a result, we offer the following for the Authority’s
consideration, and Inspector’s in due course.

Policy HOM3 – Homes in Rural Villages
It is clear that Policy HOM3 seeks to rectify the deficiency of previous Development Plans
and their policies when it comes to addressing the housing needs and requirements of all
members of a rural community, in addition to those in direct social housing need. In order to
sustain, preserve or recover a community’s level of sustainability, it is vital that provision for
new housing is made available for all its members, irrespective of their social or economic
backgrounds. This then ensures a positive balance within such communities that will secure
their sustainability for the future, as under-provision of new housing in such settlements has
been a key factor in the decline and removal of many key community facilities (e.g. schools)
within them during previous Plan periods. It is considered that Policy HOM3, by in large
therefore, now makes a significant move towards ensuring that local planning policy in
Carmarthenshire goes some way to assist in securing this objective.

Notwithstanding the above, such rural communities and the settlements they relate to or
revolve around are somewhat smaller than established satellite villages and their associated
larger towns. Growth is therefore needed, but in a controlled manner to preserve
environmental aspects of a geographic area. Again, we and our Client welcome Policy
HOM3 criteria related aspects that allow, but at the same time control, growth of the related
Rural Villages. We also welcome that such growth should be limited to take place in the
following circumstances:

 Minor infill or a small gap between the existing built form; or
 Logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
 Conversion or the sub-division of large dwellings.

Support is therefore offered to the principle’s for supporting growth set out in Policy HOM3,
although concerns are raised with regards to the proposed level and calculation of the ‘cap’
set out within its provisions, and this is the subject of a separate representation.

Rural Village – Felingwm Isaf
The inclusion of Felingwm Isaf as a Rural Village of Cluster 1 is both welcomed and
supported. Felingwm Isaf is located at a sustainable location with good access to nearby
larger settlements that contain a wide range of local services and community facilities. It is
also positioned on a public highway that is served by a regular service, giving it good access
to further settlements of the County and their associated facilities and services. Its
sustainable location therefore merits its designation as a Rural Village to enable it to
facilitate further housing development to serve the immediate rural community.

In addition to the above, we would highlight that our Client’s land (edged red in Plan A)
represents one such opportunity for new housing development and being encapsulated by
existing development on three sides would represent a logical infill opportunity (as supported
by Policy HOM3) in the settlement.

Plan A

In addition, with our Clients owning the directly adjoining area of land, any such development
would also be capable of adhering to the requirements of Natural Resources Wales with
regards to the treatment of phosphates from any new development.

On behalf of our Client, we therefore fully support the provision of Policy HOM3 and the
designation of Felingwm Isaf as a Rural Village capable of accommodating further open
marking housing development following the adoption of the Carmarthenshire Local
Development Plan.

No change to the Plan.

Further to the publication of the above document, we have been asked by our Client to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the
proposed provisions of Policy HOM3 are of particular interest to our Client and indeed the
Community they form part of. As a result, we offer the following for the Authority’s
consideration, and Inspector’s in due course.

Policy HOM3 – Homes in Rural Villages
It is clear that Policy HOM3 seeks to rectify the deficiency of previous Development Plans
and their policies when it comes to addressing the housing needs and requirements of all
members of a rural community, in addition to those in direct social housing need. In order to
sustain, preserve or recover a community’s level of sustainability, it is vital that provision for
new housing is made available for all its members, irrespective of their social or economic
backgrounds. This then ensures a positive balance within such communities that will secure
their sustainability for the future, as under-provision of new housing in such settlements has
been a key factor in the decline and removal of many key community facilities (e.g. schools)
within them during previous Plan periods. It is considered that Policy HOM3, by in large
therefore, now makes a significant move towards ensuring that local planning policy in
Carmarthenshire goes some way to assist in securing this objective.

Notwithstanding the above, such rural communities and the settlements they relate to or
revolve around are somewhat smaller than established satellite villages and their associated
larger towns. Growth is therefore needed, but in a controlled manner to preserve
environmental aspects of a geographic area. Again, we and our Client welcome Policy
HOM3 criteria related aspects that allow, but at the same time control, growth of the related
Rural Villages. We also welcome that such growth should be limited to take place in the
following circumstances:

 Minor infill or a small gap between the existing built form; or
 Logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
 Conversion or the sub-division of large dwellings.

Support is therefore offered to the principle for supporting growth set out in Policy HOM3,
although concerns are raised with regards to the proposed level and calculation of the ‘cap’
set out within its provisions, and this is the subject of a separate representation.

Rural Village – Maesybont
The inclusion of Maesybont as a Rural Village of Cluster 3 is both welcomed and supported.
Maesybont is located at a sustainable location, being close to a number of community
facilities and local services it and surrounding settlements benefit from. It also has good
access to nearby larger settlements that contain a wider range of local services and
community facilities. Its position on a regular bus service route also further contributes to its
sustainability level and as a suitable location for further housing development to serve the
immediate rural community.

In addition to the above, we would highlight that our Client’s land (edged red in Plan A)
represents one such opportunity for new housing development and being well related to the
existing form of the village, it would represent a logical round-off opportunity (as supported
by Policy HOM3) in the settlement.

Plan A

On behalf of our Client, we therefore fully support the designation of Maesybont as a Rural
Village under the provisions of Policy HOM3 capable of accommodating further open market
housing development following the adoption of the Carmarthenshire Local Development
Plan.

No change to the Plan.

Further to the publication of the above document, we have been asked by our Clients to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the
proposed provisions of Policy HOM3 are of particular interest to our Clients and indeed the
Community they form part of. As a result, we offer the following for the Authority’s
consideration, and Inspector’s in due course.

Policy HOM3 – Homes in Rural Villages
It is clear that Policy HOM3 seeks to rectify the deficiency of previous Development Plans
and their policies when it comes to addressing the housing needs and requirements of all
members of a rural community, in addition to those in direct social housing need. In order to
sustain, preserve or recover a community’s level of sustainability, it is vital that provision for
new housing is made available for all its members, irrespective of their social or economic
backgrounds. This then ensures a positive balance within such communities that will secure
their sustainability for the future, as under-provision of new housing in such settlements has
been a key factor in the decline and removal of many key community facilities (e.g. schools)
within them during previous Plan periods. It is considered that Policy HOM3, by in large
therefore, now makes a significant move towards ensuring that local planning policy in
Carmarthenshire goes some way to assist in securing this objective.

Notwithstanding the above, such rural communities and the settlements they relate to or
revolve around are somewhat smaller than established satellite villages and their associated
larger towns. Growth is therefore needed, but in a controlled manner to preserve
environmental aspects of a geographic area. Again, we and our Clients welcome Policy
HOM3 criteria related aspects that allow, but at the same time control, growth of the related
Rural Villages. We also welcome that such growth should be limited to take place in the
following circumstances:

 Minor infill or a small gap between the existing built form; or
 Logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
 Conversion or the sub-division of large dwellings.

Support is therefore offered to the principle’s for supporting growth set out in Policy HOM3,
although concerns are raised with regards to the proposed level and calculation of the ‘cap’
set out within its provisions, and this is the subject of a separate representation.

Rural Village – Manordeilo
Manordeilo is located at a sustainable location with good access to nearby larger
settlements that contain a wide range of local services and community facilities. Its position
on one of the County’s main transport routes further contributes to its sustainability level and
as a suitable location for further housing development to serve the immediate rural
community.

In addition to the above, we would highlight that our Clients land (edged red in Plan A and
circled in Photograph 1) represents one such opportunity for new housing development and
would clearly be supported by the provision of Policy HOM3.

Plan A

Photograph 1

In addition to accommodating the scale of development permitted by Policy HOM3 on one
site (4 units), the above land would also be able to accommodate the necessary SUDS
features and infrastructure necessary to adhere to the requirements of Natural Resources
Wales with regards to the treatment of phosphates. All of this would be within the
development parameters set by Policy HOM3.

On behalf of our Clients, we therefore fully support the designation of Manordeilo as a Rural
Village under the provisions of Policy HOM3 capable of accommodating further open market
housing development following the adoption of the Carmarthenshire Local Development
Plan.

No change to the Plan

I would like to submit observations on the Carmarthenshire Revised Local Development Plan 2018 – 2033 in relation to the development limit at Cynheidre, Llanelli, especially in the postal code area SA15 5YD. I have land in this area, part of which I would wish to develop.

My intention would be to construct a maximum of four dwellings which would not increase the village by 10% of the current numbers of dwellings. It is a logical extension to round off the development pattern that fits in with the character of the village form and landscape. The land is of a scrub nature and new development would be more aesthetically pleasing than it is at present. I do not wish to construct further dwellings creating a ribbon development and, as I own the land beyond the requested area marked in red on the attached map for around 150 yards, I have no intention of applying for further development.
I ask that this small area is included within the Local
Development ‘black-line’ limit for Cynheidre. There is an existing physical feature in the form of two dwellings recently completed across the road from the land I refer to. The whole of the proposed land is well within a road subject to a thirty miles per hour speed limit.

These recently completed detached dwellings on the opposite side of the road do not yet show on the current maps. Furthermore, my proposed ‘black line’ ends opposite the allowed planning limit near the two new dwellings which does not extend the village beyond the existing boundary.

Mains drainage is present immediately alongside my proposed land as is mains electricity. Mains water is available directly on the opposite side of the road.

Please find a map of the area concerned with the approximate area marked in red.

I fully accept and support the Homes in Rural Villages HOM3.

No change to Plan

Further to the publication of the above document, we have been asked by our Client to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the
proposed provisions of Policy HOM3 are of particular interest to our Client and indeed the
Community they form part of. As a result, we offer the following for the Authority’s
consideration, and Inspector’s in due course.

Policy HOM3 – Homes in Rural Villages
It is clear that Policy HOM3 seeks to rectify the deficiency of previous Development Plans
and their policies when it comes to addressing the housing needs and requirements of all
members of a rural community, in addition to those in direct social housing need. In order to
sustain, preserve or recover a community’s level of sustainability, it is vital that provision for
new housing is made available for all its members, irrespective of their social or economic
backgrounds. This then ensures a positive balance within such communities that will secure
their sustainability for the future, as under-provision of new housing in such settlements has
been a key factor in the decline and removal of many key community facilities (e.g. schools)
within them during previous Plan periods. It is considered that Policy HOM3, by in large
therefore, now makes a significant move towards ensuring that local planning policy in
Carmarthenshire goes some way to assist in securing this objective.

Notwithstanding the above, such rural communities and the settlements they relate to or
revolve around are somewhat smaller than established satellite villages and their associated
larger towns. Growth is therefore needed, but in a controlled manner to preserve
environmental aspects of a geographic area. Again, we and our Client welcome Policy
HOM3 criteria related aspects that allow, but at the same time control, growth of the related
Rural Villages. We also welcome that such growth should be limited to take place in the
following circumstances:

 Minor infill or a small gap between the existing built form; or
 Logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
 Conversion or the sub-division of large dwellings.

Support is therefore offered to the principle’s for supporting growth set out in Policy HOM3,
although concerns are raised with regards to the proposed level and calculation of the ‘cap’
set out within its provisions, and this is the subject of a separate representation.

Rural Village – Pentregwenlais

The inclusion of Pentregwenlais as a Rural Village of Cluster 3 is both welcomed and
supported. Pentregwenlais is located at a sustainable location with good access to nearby
larger settlements that contain a wide range of local services and community facilities.

Access to these is possible by non-motorised means and the village is also positioned on a
regular bus service route, giving it good access to further settlements of the County and their
associated facilities and services. Its sustainable location therefore merits its designation as
a Rural Village to enable it to facilitate further housing development to serve the immediate
rural community.

In addition to the above, we would highlight that our Client’s land (edged red in Plan A and
circled in Photograph 1) represents one such opportunity for new housing development and
being well related to the existing form of the village, it would represent a logical extension
opportunity (as supported by Policy HOM3) in the settlement.

Plan A

Photograph 1

On behalf of our Client, we therefore fully support the designation of Pentregwenlais as a
Rural Village under the provisions of Policy HOM3 capable of accommodating further open
market housing development following the adoption of the Carmarthenshire Local
Development Plan.

No change to the Plan.

The land referenced above was part of our holding when we lived at Penbrynllan Cil-y-Cwm between the years 1997 to 2009. During that time we had 3 ‘approaches’ regarding the field in question. First for the building of an ‘ecological’ house, a short lived notion that it would make a sensible and convenient location for a village hall and lastly that a substantial number of ‘affordable’ houses of high ecological specification was proposed by a local architect. This last notion was dropped due to local disquiet though our understanding was that the propsoal was not necessarily out of the question from a planning persptctive. A survey was done in the local area and to my recollection, a large number of local families expressed interest, particualarly those with children. The notion was that we would sell the land at lower than commercial rates to keep costs relatively low.
It seemed logical therefore to retain the field when we sold the residual house and land.
Thanks for your consideration of this proposal to make the specified field part of the builable area within Cil-y-Cwm. What we would envisage is a small number of compact and affordable dwellings with the rest of the land being used for community purposes, perhaps an orchard or even allotments and/or even a multi-purpose village hall type building, which would be therefore adjacent to the playing field.
In view of the above we believe that this proposal is fitting and appropriate to the area.

Development limits to be drawn around Four Roads and the site in question to be included within the development limits.

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

Amend Policy

This representation is made in response to the ‘Carmarthenshire County Council Second Deposit Revised
Local Development Plan’ (“the LDP”) consultation and is submitted on behalf of Mr James George.
Mr George owns “Llwyndu” Land at Milo, Llandybie (‘the site’) which has been considered in the Candidate
Sites Register Assessment for potential inclusion within the LDP. The site can be seen, outlined in red, on
the plan found at Appendix 1.
It is respectfully suggested that the site should be allocated in the LDP, to provide confidence that houses
can be delivered to meet local needs in Milo. Alternatively, the site is capable of meeting the criteria set out
in the proposed policy framework of the LDP to allow its development for new homes, so long as some
flexibility and judgment can be applied.
THE SCALE OF PROPOSED GROWTH
We support the ambition and principle of the LDP, and specifically the targets set out in Policy SP1:
Strategic Policy - SP1: Strategic Growth
The LDP will provide for the future growth of a sustainable economy and housing
requirement through the provision of:
a. 9,704 new homes to meet the identified housing requirement of 8,822.
b. A minimum of 71.21ha of allocated employment land.
The focus on regeneration and growth reflects the Council's core strategic ambitions with
development distributed in a sustainable manner consistent with the spatial strategy and
settlement framework.
It is clear that the Council has taken seriously its responsibility to support he delivery of the homes and jobs
which are needed in Carmarthenshire. The targets appear aspirational, but realistic. What should not be
overlooked in these strategic targets however is the very real need to support the more rural parts of the
community and meeting their needs.
Sites like “Llwyndu” Land at Milo, Llandybie provide a valuable opportunity to deliver new homes in a rural
hinterland which supports an overall network of social and economic growth. This growth is set out in the
LDP, and the site could be delivered through an allocation, or as a windfall – and either way, it would
contribute to the overall housing target set by the Council.
MILO AS A LOCATION FOR GROWTH
Introduced in chapter 10 of the LDP is the concept of “Clusters” and Milo falls within the settlements grouped
in “Cluster 3: Amman and Upper Gwendraeth.”
We note with interest the way in which Cluster 3 is described in the LDP. In particular, we note the following
elements of the spatial portrait, and that the cluster:
“…is characterised by a series of interrelated settlements; [and]
…has grown as a centre with a focus for investment in jobs, homes, and services.”
And specifically, that:
“Ammanford …plays an important service centre role by providing localised retail, employment,
education, and leisure facilities.”
We also note that:
Cross Hands as a former mining community has developed over recent decades through its position
on the A48 strategic transport route.
Regarding Cross Hands, it is exciting to see a range of significant economic growth is planned to include:
• PrC3/E1 – Employment allocation of some 8.31 Ha
• PrC3/E3 - 4.76 Ha extension to business park
• SG2/3 – reserved expansion area for large scale employment uses.
This growth will also be accompanied by:
TRA1: Transport and Highways Infrastructural Improvements
Transport routes, improvements and associated infrastructural facilities which deliver the objectives
and priorities of the Joint Transport Plan for South West Wales (2015 – 2020) will be supported.
The improvements to the highway infrastructure as part of the Cross Hands Economic Link Road will
be safeguarded with the route identified on the proposals map.
Proposals which maintain and enhance an integrated sustainable transport network will also be
supported where they accord with the policies and provisions of this Plan. Development proposals
which do not prejudice the efficient implementation of any identified improvement or scheme will be
permitted.
Land at Milo, Llandybie is approximately 4 miles from Cross Hands via the A476 and the new Cross Hands
relief road, avoiding additional traffic on the congestion pinch points of the Cross Hands roundabout and
Gorslas.
These points suggest that each settlement in the cluster has a role to play in supporting the successful social
and economic activity in the area, and that the services and facilities of the larger settlements, support a
hinterland of slightly dispersed but nonetheless connected communities.
To maintain this success, and to ensure the continued vitality of the more rural communities it is vital that
development is allowed to happen at all tiers (and sizes) of settlement in the cluster.
We note that potential development in Milo is proposed to be manged primarily through two policies: SP3:
Sustainable Distribution, and HOM3: Homes in Rural Villages.
Therefore, taking each of these policies in turn:
STRATEGIC POLICY – SP3: SUSTAINABLE DISTRIBUTION – SETTLEMENT FRAMEWORK
We generally support the principle of this policy. Settlement hierarchies are a well-recognised way of
managing growth and directing it to the most sustainable locations, and it is important that the role of smaller
settlements such as Milo is not over looked, and that the needs of people who live in these more rural
locations are also met.
We note that Milo is listed as a “Tier 4 – Rural Villages (No development limits).” On the face of it, given the
size of Milo this is reasonable, and the fact that the village is a well-connected part of the ‘cluster’ is also
recognised.
Furthermore, we read with interest in the supporting text to Policy SP3 that in “Rural Villages (No
Development Limits)” the following scale of development will be acceptable:
• Small sites – housing through infill or logical extensions/rounding off.
• Small Scale Rural Exceptions Schemes for Affordable Housing
We respectfully suggest that Land at Milo, Llandybie represents a small infill site as presented in the
supporting text to Policy SP3. The site should be allocated as such in the LDP to provide confidence that it
will be delivered in the plan period to help meet both the strategic needs of Carmarthenshire and specifically
the local housing needs in “Cluster 3: Amman and Upper Gwendraeth” and Milo.
HOM3: HOMES IN RURAL VILLAGES
Should the Council decide that Land at Milo, Llandybie does not need to be allocated for development, the
site has the potential to be delivered as ‘windfall,’ broadly in conformity with proposed Policy HOM3.
There are, however, some element of this proposed policy which are somewhat arbitrary, and we suggest
that some flexibility and planning judgement is allowed, to ensure the most appropriate development
opportunities are delivered, and the most efficient use is made of land.
In particular we note that proposed Policy HOM3, suggests the following:
In those settlements identified as rural villages under Policy SP3, proposals for 1 to 4 dwellings will be
permitted for the following:
• minor infill of a small gap between the existing built form; or,
• logical extensions and/or rounding off of the development pattern that fits in with the character of the
village form and landscape; or
• conversion or the sub-division of large dwellings.
Such proposals will be subject to other detailed planning considerations set out within LDP policies.
As we have explained in response to proposed Policy SP3, and is elaborated upon in our site specific
comments - Land at Milo, Llandybie is a sensible and logical infill site. However, because the most logical
infill is for 6 new homes the potential to develop the site would – in principle – be contrary to proposed Policy
HOM3, but the 1 to 4 dwellings requirement is entirely arbitrary and does not appear to be justified in the
supporting text to the policy, or in any supporting evidence.
We suggest therefore that the reference to 1 to 4 dwellings is removed from the policy text, and this would
have a limited effect on how the policy operates. There is still sufficient scope for a ‘case by case’
assessment of the acceptability of infill sites, and for some flexibility to be applied where perhaps 6 houses
might be more appropriate and in character with a site’s surrounds, but equally importantly it makes an
efficient use of land.
The final paragraph of proposed Policy HOM3 is also arbitrary and not justified in evidence that we have
been able to identify. The following part of the pollciy is not necessary, and should be removed:
Proposals which exceed the 10% cap above the number of existing homes in the settlement, as at
the LDP base date, will not be permitted except where they conform to Policy AHOM1 in relation to
the provision of affordable homes.
By way of an example, there are currently 50 homes in Milo, and Land at Milo, Llandybie can deliver 6 infill
homes, but this would be apparently contrary to proposed policy HOM3 (by a factor of a single house) for no
reason other than it breaches an arbitrary 10% cap. This risks both the viability of schemes, and the efficient
use of land.
“LLWYNDU” LAND AT MILO, LLANDYBIE
Turning to the site which we are proposing should be allocated for development. This submission
commends to the Council, Land at Milo, Llandybie (‘the site’) which has been considered in the Candidate
Sites Register Assessment for potential inclusion within the LDP.
The site address is as follows:
Llwyndu
Milo
Llandybie
Ammanford
SA18 3NQ
The site has been assessed by the Council and the site reference is SR/114/001. The assessment of the
site states
“The site may comply with the provisions of the Preferred Strategy, however each individual site will
require assessment at application stage to ensure it complies with the relevant specific policy. In
respect of this settlement, the Preferred Strategy identifies it as a Tier 4 with no development limits”
We support the general assessment of the site and suggest that it should be allocated for development to
provide confidence in its delivery.
However, should the Council disagree with this position, we remain confident that the site is acceptable, and
achievable as infill development.
Site Context
The site comprises 4.64 acres of agricultural fields within the settlement of Milo, which is identified in Policy
proposed policy SP3 as a sustainable community. A site location plan, which was submitted with our initial
submissions to the candidate sites register is included again for completeness (Appendix 1).
The site benefits from an existing access with good visibility onto the main road running through Milo, as
shown in Figure 1 below.
Figure 1 – Access to the site from the main road through Milo (Google Street View - 2011)
The site is bound by agricultural fields to the south west, residential properties to the south east and a chapel
to the North West. The site is bounded by the road to the north east, whilst two and three storey residential
properties lie on the opposite side of the road.
There are two listed buildings to the north of the site: Capel Milo (ID: 22200) and Hen Gapel Milo (ID:
22199).
The village of Milo contains around 50 homes. Milo is approximately 4.5 miles north of Ammanford, which is
recognised as a growth area in proposed Policy SP3 and the heart of a cluster or network of connected
communities. Milo is approximately 5 miles south west of Llandeilo which is also identified as a service
centre. There is a bus service from Milo to Llandeilo.
Proposed Development
It is considered that the site could be developed along the road following the existing linear patter of built
form in Milo. In this case, it is considered that the site could comfortably accommodate approximately six
dwellings and utilise the existing access, as shown in Figure 1 above. Such development would mirror the
existing settlement and would constitute ‘infill’ development, as supported in proposed Policies SP3 and
HOM3.
As highlighted within our initial submission, an alternative option is to develop the whole of the site, again
utilising the existing access, which could accommodate approximately 15 dwellings, thus triggering the need
for affordable housing which would provide additional benefits to the locality.
Two broad indicative layouts were provided within our initial submission and have been included again for
completeness (see Appendix 2).
The site also lies within a sustainable location within Milo itself, located approximately 140m to the local bus
stops from the existing access into the site shown in Figure 1 above.

CONCLUSION
We are pleased to have had the opportunity to comment on the ‘Carmarthenshire County Council Second
Deposit Revised Local Development Plan.’ We support the general vision, and approach of the LDP but
suggest that some flexibility and room for judgement must be retained to allow for the continued vitality of
some of the more rural parts of the county.
“Llwyndu” Land at Milo should be allocated for development to provide some confidence that local housing
needs will be met. However, failing that the site is capable of providing a reasonable ‘windfall’ development
as infill.
As has been demonstrated above, the site (SR/114/001) constitutes a suitable and sustainable form of
development within the settlement of Milo.
Overall, it is considered that the site (SR/114/001) constitutes the only suitable and sustainable Candidate
Site within Milo for residential development. The site is capable of mirroring the linear form of development
that exists along the main road through Milo, and would therefore be a logical means of increasing housing
within this sustainable community (as promoted through proposed Policy SP3 Local Development Plan).
I trust the information provided in this submission is sufficient. Should you require any further information,
please do not hesitate to contact me.

Amend policy

Carmarthenshire Local Development Plan 2018-2033 – Deposit Draft
Objection to Policy HOM3 on behalf of Evans Banks Planning Ltd

Further to the publication of the above document, we have been asked by our Clients to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so we consider it necessary to
make a formal representation to the “soundness” of the Carmarthenshire Deposit Local
Development Plan, including in relation to the provisions of part of Policy HOM3 (Homes in
Rural Villages). As a result, we offer the following for the Council’s consideration, and
Inspector’s in due course.

It is clear that Policy HOM3 seeks to rectify the deficiency of previous Development Plans
and their policies when it comes to addressing the housing needs and requirements of all
members of a rural community, in addition to those in direct social housing need. In order to
sustain, preserve or recover a community’s level of sustainability, it is vital that provision for
new housing is made available for all its members, irrespective of their social or economic
backgrounds. This ensures a positive balance within such communities that will secure their
sustainability for the future, as under-provision of new housing in such settlements has been
a key factor in the decline and removal of many key community facilities (e.g. schools) within
them during previous Plan periods. It is considered that Policy HOM3, by in large therefore,
now makes a significant move towards ensuring that local planning policy in
Carmarthenshire goes some way to assist in securing this objective.

Notwithstanding the above, such rural communities and the settlements they relate to or
revolve around are somewhat smaller than established satellite villages and their associated
larger towns. Growth is therefore needed, but in a controlled manner to preserve
environmental aspects of a geographic area. Again, we welcome Policy HOM3 criteria
related aspects that allow, but at the same time control, growth of the related Rural Villages.

We also welcome that such growth should be limited to take place in the following
circumstances:
 Minor infill or a small gap between the existing built form; or
 Logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
 Conversion or the sub-division of large dwellings.
Notwithstanding the above, we have concerns and would object to the proposed ‘cap’ on
new open market housing development. Under the provisions of the 2nd Deposit LDP the
cap on new housing development within the Plan period must not exceed “ …10% over and
above the number of existing homes, as of the base date of the Plan in the settlement will be
allowed.”. However, in the 1st Deposit LDP this figure was 20%, although no explanation of
evidence has been provided by the Council as to why this figure should be halved? This lack
of justification or clarity on the decision in itself causes the Plan to be deemed ‘unsound’.
Firstly, we would strongly argue that in order to ensure those communities identified as Rural
Villages in the Plan can become truly sustainable and recover from years of policy neglect,
this cap should be returned to 20%. 10% is far too restrictive and will go nowhere near to
meeting the pent-up demand in rural communities for new housing.

Secondly, the 10% cap and limitation to ‘existing homes’ (and so not taking into account
recent consents) is so overly restrictive and prescriptive that it will lead to potentially bad,
illogical and unnatural placemaking. For example a village of 40 homes with natural infill
opportunities for 6 units over 2 equally sized sites, would only be able to deliver 3 units, as
the part development of the second could result in an illogical form of development that does
not compliment an existing settlement pattern or meet other policy requirements in the Plan.
The construction of all 6 would do so, but under the current 10% cap would be prevented
from doing so.

The settlement patterns of Carmarthenshire’s Rural Villages are extremely varied and each
has numerous opportunities for small scale new housing that follow the three locational
criteria of Policy HOM3, which they have been prevented from doing so historically due to
continual restrictive and illogical ‘development limits’ style policies of successive plans.
However, even with the more pragmatic approach being proposed by Policy HOM3, such
rural communities will continue to be failed and prevented from declining further if the 10%
cap is retained.

In summary, we full support the principles put forward by Policy HOM3 and its overall
approach to supporting rural communities in the identified Rural Villages. However, we
object to the proposed 10% cap put forward by the 2nd Deposit LDP, as without clear
evidence for halving the figure put forward in the 1st Deposit LDP, we are unable to see how
the objective of Policy HOM3 can be achieved. This in turn puts the soundness of the Plan
into question. In addition, in order to provide clarity and a true positive impact on rural
communities in Carmarthenshire, we propose that the relevant wording of the Policy should
be amended to read as follows:
“…20% over and above the number of existing homes and those under construction, as of
the adoption date of the Plan in the settlement will be allowed.

We therefore respectfully request that this Representation be given careful examination, and
that the cap figure and associated wording included within Policy HOM3 be revisited to
ensure that the document passes all the relevant tests of soundness.

Amend policy

Please find my comments below re LDP

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

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

Ni nodwyd unrhyw newid penodol.
___
No specific change noted.

Ymateb Cyng Jean Lewis i’r CDLl.
1. Hom3 – Cartrefi ym Mhentrefi Gwledig (Homes in Rural Villages)
11.90
Er mod i’n croesawu’r polisi hwn rwyn gobeithio y bydd e’n ddigon hyblyg i fynd i’r afael â phroblemau cymunedau gwledig. Mae angen polisi a darpariaeth sy’n diwallu’r angen i sicrhau bod yna ddarpariaeth briodol i bobl leol o bob oedran sy’n dymuno ymgartrefi ac ymddeol yn eu milltir sgwar. Er mwyn cyflawni hyn, dylir cydnabod cynhwysedd datblygiadau pellach posibl mewn pentrefi gwledig ac o'u cwmpas.
Tan 6: TAN 2.2.1: Many rural communities can accommodate development, particularly to meet local needs. In particular, planning authorities should support developments that would help to achieve a better balance between housing and employment, encouraging people to live and work in the same locality.
PPW Housing 4.2.1: Planning authorities must understand all aspects of the housing market in their areas, which will include the requirement, supply and delivery of housing.
¬¬¬¬¬¬¬¬¬¬
2. Hom3- Tai o fewn terfynau datblygu (Housing within development limits)
Proposals which exceed the 10% cap above the number of existing homes in the settlement, as at the LDP base date, will not be permitted except where they conform to Policy AHOM1 in relation to the provision of affordable homes.
Mae’r ffigwr o 10% yn llawer rhy fach ar gyfer rhai ardaloedd e.e. dim ond fesul 1 cartref y gall pentrefan o 10 cartref dyfu yn ystod oes y CDLl. Nid yw anhyblygedd y cap o 10% yn gydnaws â'r dyhead i adeiladu cymunedau gwledig cynaliadwy ac mae’n groes i:
Tan 6: TAN 2.2.1: Many rural communities can accommodate development, particularly to meet local needs. In particular, planning authorities should support developments that would help to achieve a better balance between housing and employment, encouraging people to live and work in the same locality.
PPW Housing 4.2.1: Planning authorities must understand all aspects of the housing market in their areas, which will include the requirement, supply and delivery of housing.


3. HOM3 - Canllawiau ar Leiniau Derbyniol (Guidance on Acceptable Plots)
Er mwyn diwallu’r dyhead i adeiladu cymunedau gwledig cynaliadwy, dylid archwilio'r potensial mewn pentrefi gwledig ac o'u cwmpas. Efallai bod y cyfyngiadau yn addas ar gyfer nifer fach o bentrefi ond mae’n rhaid cymryd i ystyriaeth y pentrefi hynny na fydd y cyfyngiadau anhyblyg yma yn addas nac yn ymarferol oherwydd natur yr ardal a’r tirwedd. Nid wyf yn teimlo bod angen y cymal hwn gan ei fod yn rhwystro, caethiwo a chyfyngu:
Proposals located in open fields adjoining a group, which have no physical features to provide containment will not be considered acceptable.

___________________________________________________________
4. HOM4: Cartrefi mewn Aneddiadau Gwledig Amhenodol (Homes in Non-Defined Rural Settlements)
11.93 a 11.94
Nodir yn un cymal bod y datblygiad ar raddfa sy'n gyson â chymeriad yr ardal ac wedyn gwelir mewn cymal arall bod rhaid i’r annedd fod yn dŷ fforddiadwy sy’n neges gymysglyd. Gormod o bwysau ar fforddiadwy ac nid ar yr angen lleol. Er bod angen tai fforddiadwy mae’n rhaid bod yn barod i gael cymysgedd o dai gerllaw ei gilydd sy’n adlewyrchu angen y trigolion a’r gymuned ac i fod yn gynhwysol o ran cyd-fyw beth bynnag yw statws y trigolion. Dylir adolygu mesur tŷ fforddiadwy i gyd-fynd gyda’r ffordd mae pobl yn byw. Dim yn cyd-fynd gyda’r gwahaniaethu rhwng pobl a’i gilydd ac nid yw’n gydnaws gyda’r Ddeddf Llesiant o barchu pawb a rhoi’r un chwarae teg i bob un.


5.¬¬¬¬¬¬¬¬¬¬¬¬¬¬¬¬¬ EME4 - Cynigion Cyflogaeth ar Safleoedd Heb eu Neilltuo (Employment Proposals on Non-Allocated Sites)
11.165
Dylir ystyried diwallu anghenion pobl leol o weithio yn eu cymuned a hefyd darparu mannau gweithio sy'n cynnwys cyflogaeth leol mewn ardaloedd y tu allan i derfynau datblygu.

6. Anheddau Menter Wledig (Rural Enterprise Dwellings)
11.379; 11.380; 11.381;
TAN 6: 4.1.1 Fel y nodwyd trwy bolisi cenedlaethol, mae angen annedd menter wledig lle maen galluogi gweithwyr menter wledig i fyw yn eu man gwaith neu'n agos ato. Mae hyn yn cynnwys annog pobl iau i reoli busnesau fferm a chefnogi arallgyfeirio ar ffermydd sefydledig. Gyda hynny mewn golwg, mae angen hwyluso’r broses ac edrych yn fwy cymedrol ar 4 prawf Tan 6 (Adran 3.4: 8, 9, 10, 11).
O ran adeiladu tai fferm, mae angen mynd i’r afael a lleoliad y tŷ. Mae’n afresymol erbyn hyn lleoli tŷ ar glos y fferm ac yn agos i ddomen slyri a’r anifeiliaid. Mae rhaid cofio bod clos y fferm yn gartref i beiriannau mawr ac anifeiliaid. Fel y gwyddom mae damweiniau erchyll yn digwydd ar glos y fferm . Dylai tŷ tu hwnt i’r clos erbyn hyn fod yn dderbyniol.
________________________________________________________________
7. RD3 – Arallgyfeirio ar Ffermydd (Farm Diversification)
11.393, 11.394 a 11.396
Tra bod arallgyfeirio mewn ardaloedd gwledig yn cael ei annog, mae'r gallu i deuluoedd ifanc fyw a gweithio ar safleoedd gwledig y tu allan i derfynau datblygu wedi'i gyfyngu'n ddifrifol. Mae hyn yn niweidiol i gynaliadwyedd cymunedau pentrefol.
Mae llawer o gynlluniau arallgyfeirio ffermydd yn cael eu rhwystro o'r cychwyn cyntaf oherwydd eu lleoliad gwledig, ac felly'n dod o dan y llu o gyfyngiadau ar ddatblygu yng nghefn gwlad agored.
Dylid ystyried incwm y cartref ac nid yn unig incwm y busnes penodol gan bod hi’n cymryd blynyddoedd i sefydlu busnes. gwragedd, partneriaid a'u plant aros yn eu cartrefi teuluol neu ddychwelyd iddynt



8. Tai Cyngor a Chymdeithasol/Council and Social Housing

Mae’n bwysig fod y Cyngor yn adeiladu tai cyngor yn yr ardaloedd gwledig.
______________________________________________________________________________
9.Cyffredinol/General
Nid oes polisïau gan y Sir sydd yn mynd i’r afael ag anghenion gwledig o adeiladu tŷ sydd tu allan i ffiniau’r CDLl heblaw am dŷ fforddiadwy. Ceir tystiolaeth o hyn yn y ceisiadau ar hyd y blynyddoedd sy’n cael ei gwrthod o ran polisi neu’n hytrach diffyg polis. Mae ceisiadau ar gyfer adeiladu tŷ mwy o faint na mesur tŷ fforddiadwy yn cael eu gwrthod. Felly, pam na ellir cael polisi sy’n caniatáu tŷ sydd yn fwy na ei faint na thŷ fforddiadwy gyda chyfraniad at dŷ fforddiadwy?
________________________________________________________________
Mae mwyafrif o’r pwyntiau uchod yn cyd-fynd gyda dogfen Symud Sir Gâr Wledig Ymlaen, sydd a 55 o argymhellion i adfywio ein cymunedau gwledig yn Sir Gaerfyrddin.ar sut mae cryfhau Sir Gâr Mae cyhoeddi’r adroddiad hwn yn garreg filltir arwyddocaol i’r awdurdod gan mai dyma’r tro cyntaf erioed y datblygwyd strategaeth bellgyrhaeddol i adfywio ein cymunedau gwledig yn Sir Gaerfyrddin. Gwelir y rhan sy’n mynd i’r afael â Chynllunio a Thai. Atodaf hefyd y ddogfen at eich sylw.

(MOVING RURAL CARMARTHENSHIRE FORWARD – Report and Recommendations of the Carmarthenshire Rural Affairs Task Group – June 2019, approved by full Council in 2019)

3.2 Cynllunio a Thai
3.2.1 Codwyd y rhan y mae cynllunio yn ei chwarae o ran cefnogi cynaliadwyedd ein cymunedau gwledig yn y dyfodol dro ar ôl tro yn rhan o drafodaethau’r Grŵp Gorchwyl. Wrth gwrs, ceir cydnabyddiaeth o’r angen am ystyriaeth sensitif o nifer o ffactorau wrth ystyried datblygiad mewn ardaloedd gwledig ond mae’r Grŵp Gorchwyl yn teimlo nad yw polisi cynllunio cyfredol Llywodraeth Cymru yn cynnig digon o hyblygrwydd i ganiatáu datblygiad, yn seiliedig ar angen lleol, yn ein cymunedau mwyaf gwledig. Mae’r diffyg twf hwn yn golygu bod cymunedau gwledig yn cael eu gadael ar ôl o ran datblygiad wrth i gyfleoedd ar gyfer tai, busnes ac arallgyfeirio gael eu targedu fwy at y prif ganolfannau poblogaeth. Teimlir hefyd fod hyn yn cyfrannu at lif cyson o bobl iau o oedran gweithio allan o’r cymunedau gwledig i chwilio am dai a chyflogaeth addas, sy’n effeithio wedyn ar gydnerthedd y cymunedau hynny.
3.2.2 Yn benodol, mae angen adolygu polisi cynllunio cenedlaethol o ran cymunedau gwledig cynaliadwy (TAN 6) hefyd i gymryd i ystyriaeth newidiadau economaidd-gymdeithasol y mae cymunedau gwledig wedi eu hwynebu yn y deng mlynedd diwethaf ers datblygu’r TAN, ond yn enwedig o ganlyniad i oblygiadau tebygol Brexit ar y sector amaethyddol. Mae’r sector amaethyddol yn wynebu cyfnod ansicr iawn gan fod llawer o oblygiadau posibl Brexit yn dal i fod yn anhysbys. Fodd bynnag, mae angen adolygu polisi cynllunio er mwyn caniatáu dull mwy hyblyg o ddatblygu, yn seiliedig ar angen lleol a chyfleoedd mewn ardaloedd gwledig, fel y gall pobl sy’n gweithio yn y sector amaethyddol a’r gymuned ehangach arallgyfeirio ac addasu fel sy’n briodol.
3.2.3 Teimlir hefyd, yn dilyn y gydnabyddiaeth yn Neddf Cynllunio 2015 y dylai effaith datblygu ar y Gymraeg fod yn ystyriaeth berthnasol, fod angen diwygio TAN 20 i adlewyrchu’r ddeddfwriaeth newydd. Teimlir hefyd y dylai’r TAN gyflwyno dull penodol ar gyfer asesu effaith Cynlluniau Datblygu Lleol (CDLl) ar y Gymraeg yn ogystal â gwneud darpariaeth ar gyfer asesu effaith datblygiad pob safle ar y cam cais cynllunio, gan mai dim ond ar y cam hwn y mae gennych chi’r manylion angenrheidiol i gynnal asesiad llawn a chadarn.
3.2.4 Mae’r Cyngor wrthi’n diwygio ei Gynllun Datblygu Lleol ac mae’r Grŵp Gorchwyl yn teimlo bod angen unioni’r cydbwysedd presennol i ganiatáu datblygiad priodol ac addas yn ein trefi a’n cymunedau gwledig. Mae angen bwrw ymlaen â’r datblygiad hwn yn seiliedig ar angen lleol yn hytrach na thargedau a rheoliadau cenedlaethol. Wrth gwrs, dylai fod ystyriaeth a dealltwriaeth drylwyr o’r effaith y gallai unrhyw ddatblygiad preswyl neu fusnes ei chael ar natur a chyfansoddiad cymunedau gwledig, yn enwedig o ran ei effaith gadarnhaol neu negyddol bosibl ar y Gymraeg, a dylai maint datblygiad hefyd fod yn gymharol â’r gymuned bresennol, ond mae angen galluogi datblygu cynaliadwy yn ein cymunedau lleol er mwyn sicrhau cynaliadwyedd ein cymunedau gwledig yn y dyfodol.
3.2.5 Mae argaeledd tai fforddiadwy hefyd yn broblem sylweddol mewn cymunedau gwledig. Yn Sir Gaerfyrddin, caiff tai fforddiadwy eu dynodi yn seiliedig ar incwm canolrifol cymunedau penodol (fel y penderfynir gan ddull Paycheck CACI, sy’n darparu amcangyfrifon incwm aelwydydd gros). Er enghraifft, byddai tŷ tair ystafell wely nodweddiadol yn cael ei ddosbarthu’n fforddiadwy os cost y tŷ yw tair gwaith yr
23

incwm canolrifol ar gyfer yr ardal honno yn ogystal â blaendal o 5%. Mae prisiau gwerthu’r cartrefi hyn yn cael eu cyfyngu ar yr adeg werthu gychwynnol ac i feddianwyr dilynol. £26,190 yw enillion cyfartalog trigolion Sir Gaerfyrddin (yr Arolwg Blynyddol o Oriau ac Enillion) a £207,635 yw pris tŷ cyfartalog mewn wardiau gwledig fel Llangeler a £206,150 yng Nghil-y-cwm (ym mis Chwefror 2019), ac felly mae argaeledd a lleoliad tai addas ar draws y sir yn allweddol. Mae’r Grŵp Gorchwyl yn croesawu dull y Cyngor, a’r cynnydd y mae wedi ei wneud hyd yn hyn trwy ‘Gynllun Cyflenwi Tai Fforddiadwy 2016–2020 Sir Gaerfyrddin’, i gyflawni ei ymrwymiad i sefydlu 1,000 o gartrefi fforddiadwy ychwanegol yn y sir, a darparwyd 700 eisoes naill ai drwy brynu tai addas drwy’r farchnad breifat neu gynorthwyo’r gwaith o adeiladu cartrefi newydd. Mae angen cyflawni’r ymrwymiad hwn yn llawn a’i ddatblygu ymhellach trwy waith Cartrefi Croeso, a sefydlwyd gan Gyngor Sir Caerfyrddin fel cwmni hyd braich i fynd i’r afael ag angen tai lleol trwy ddatblygu cartrefi newydd i’w gwerthu a’u rhentu. Bydd gan y cwmni bwyslais cryf ar gynyddu’r ddarpariaeth o gartrefi addas ar draws y sir ac yn enwedig mewn cymunedau gwledig. Mae hefyd yn bwysig fod y Cyngor yn ceisio datblygu ei gyflenwad o dai cyngor ymhellach ac mae’r Grŵp Gorchwyl wedi ei galonogi’n fawr fod cynigion yn cael eu datblygu i adeiladu hyd at 900 o dai cyngor newydd i gael eu lleoli ar draws y sir yn unol ag angen lleol.
3.2.6 Tua 950 yw nifer yr ail gartrefi sydd mewn perchnogaeth yn Sir Gaerfyrddin. Mae hon yn nifer sylweddol ynddi ei hun ond mae’n sylweddol is na chyfraddau yn Sir Benfro (3,000), Ceredigion (2,000) a Gwynedd (4,800). Er bod cynghorau eraill wedi cyflwyno mesurau i gynyddu cyfraddau treth gyngor ar ail gartrefi, ceir bwlch mewn deddfwriaeth genedlaethol ar hyn o bryd sy’n golygu y gall perchnogion ail gartrefi newid o’r dreth gyngor i dreth fusnes. Er bod y Cyngor yn ymwybodol o effaith negyddol bosibl ail gartrefi ar hyfywedd cymunedau gwledig, mae angen datrys y problemau deddfwriaethol cyn i’r Cyngor ystyried ei safbwynt ar gyfraddau treth gyngor ar gyfer ail gartrefi yn y dyfodol.



Argymhellion
8 I lobïo Llywodraeth Cymru i ddiwygio polisi cynllunio cenedlaethol, ac yn benodol:
a. TAN 6 i alluogi dull mwy hyblyg o ddatblygu mewn ardaloedd gwledig, yn enwedig mewn ardaloedd y tu allan i aneddiadau a nodwyd, a
b. TAN 20 o ran sicrhau bod effaith unrhyw ddatblygiad ar y Gymraeg yn ofynnol fel ystyriaeth berthnasol, fel y nodir yn Neddf Cynllunio 2015, a bod ei statws mewn deddfwriaeth yn cael ei adlewyrchu yn y TAN.

9 I lobïo Llywodraeth Cymru i ddiwygio polisi cynllunio (yn rhan o TAN 6) o ran adeiladu ail annedd ar ffermydd sefydledig gan nad yw’r gofynion cyfredol yn ymwneud â dangos incwm o’r fferm i ganiatáu datblygiad yn ddilys mwyach. O gofio natur newidiol amaethyddiaeth yn y presennol a’r dyfodol a goblygiadau posibl Brexit, bydd yn rhaid i incwm o’r fferm gael ei ategu gan incwm o ffynonellau eraill, h.y. aelodau teulu estynedig yn cymryd cyflogaeth y tu allan i leoliad y fferm. Felly, mae angen ystyried cyfanswm incwm yr aelwyd, fel uned deuluol, yn hytrach nag incwm y fferm yn unig.
10 Bod y Cyngor yn sicrhau bod y Cynllun Datblygu Lleol diwygiedig yn:
a. caniatáu datblygiad preswyl a busnes o faint priodol mewn ardaloedd cymunedau llai yn ôl yr angen
b. caniatáu cymysgedd priodol o ddeiliadaethau mewn datblygiadau preswyl, yn seiliedig ar angen tai lleol
c. caniatáu’r dyraniad priodol o dai fforddiadwy mewn ardaloedd gwledig
d. caniatáu datblygiad twristiaeth a busnes mewn ardaloedd gwledig i gynorthwyo cefnogi datblygiad ac arallgyfeirio yn y dyfodol

11 Bod y Cyngor yn diwygio ei bolisi cynllunio i ganiatáu cyfeiriad at ffermdy newydd / wedi ei ailddatblygu neu annedd sy’n gysylltiedig ag eiddo amaethyddol fel y gellir ei leoli ar bellter rhesymol y tu allan i’r buarth gweithredol er mwyn sicrhau y gellir rhoi sylw dyledus i:
a. Ystyriaethau iechyd a diogelwch;
b. Bioddiogelwch; ac
c. Lleihau’r perygl o filheintiau (clefydau y gellir eu trosglwyddo rhwng pobl ac anifeiliaid, e.e. TB).

12 Bod y Cyngor yn ymchwilio i ymarferoldeb caniatáu sefydlu/creu tyddynnau newydd mewn ardaloedd gwledig, y tu allan i aneddiadau a nodwyd, yn seiliedig ar angen lleol a’r cyfraniad cadarnhaol posibl at gynaliadwyedd economaidd, cymdeithasol, diwylliannol ac amgylcheddol y gymuned leol.
13 Bod y Cyngor yn parhau i gefnogi a datblygu ymhellach ei gynllun uchelgeisiol, sef Cynllun Cyflenwi Tai Fforddiadwy Sir Gaerfyrddin, ar ôl 2020 i sicrhau parhad argaeledd cynyddol tai fforddiadwy yn y sir ac i sicrhau bod y cynigion ar gyfer adeiladu tai cyngor newydd yn adlewyrchu anghenion tai lleol mewn ardaloedd gwledig.

Amend Plan

Submitted on behalf of all Plaid Cymru Councillors on Carmarthenshire County Council – April 2023

SECOND REVISED LOCAL DEVELOPMENT PLAN 2018 - 2033
CYNGOR SIR GÂR
RESPONSE TO PUBLIC CONSULTATION March/April 2023
This document attempts to measure the aims of the LDP against the specific proposals as regards RURAL
DEVELOPMENT, SUSTAINABLE RURAL COMMUNITIES and the WELSH LANGUAGE.
It is compiled from the point of view of Local Members who attempt to build strong rural communities
within the limitations presented in the Local Development Plan and the the Planning environment.
Critical issues faced by rural communities at this time include:
• De-population – loss of young people, leading to loss of young families, leading to loss of
generation of children and further young people – a cycle which rural communities cannot control
nor influence;
• Altered demographic – increasing purchase and occupation of residential dwellings by older
couples or individuals, either retired or preparing for retirement, both local and from afar –
ultimately leading to “retirement villages”;
• Market forces – demand of older generations who have the means to purchase a rural lifestyle
pushing property prices beyond the reach of younger working families;
• Media marketing – “lifestyle” programming on TV and other media encouraging urban dwellers to
aspire to idyllic rural locations thus squeezing local lower earners from access to the local market;
• Tourism – economic considerations from the (sporadic) visitor industry is prioritised above the
economic contribution of (permanent) rural residential working families;
• Yr Iaith Gymraeg – Planning Statements placing the Welsh Language in a priority position while
Planning Policy failing to protect or develop Welsh Language rural strongholds;
• Community – traditional rural community structures breaking due to fragmented demographic,
contrasting cultures and consequential loss of cultural heritage;
• Community Services – lack of young families stepping into and running the voluntary community
services such as sports clubs, PTAs, Church/Chapel groups, social events etc.;
• The Family – breakdown of “family care cycle”. While young families are not living near their
parents, care of the elderly by the younger generation and childcare by the older generation
cannot be provided, resulting in isolation and additional pressures on Care Services.
• Local Culture – not necessarily being recognised or acknowledged by new demographic. Absence of
younger generation to inherit and exercise local culture and tradition resulting in their demise and
disappearance.
How can the LDP support ordinary people in ordinary rural communities to develop their economy,
language and culture?
TAN 6: 2.1.2 “Planning authorities should assess the needs and priorities of rural communities. They
should interrogate published sources of information such as the Wales Rural Observatory, and if
necessary commission research to identify rural economic and social conditions and needs.”
The Wales Rural Observatory ceased to exist in 2014. The most recent report on rural communities was
published in 2013. Many of the issues above were identified at that time:
“A common concern … was that disproportionately high housing prices, fuelled by demand for
commuting, second homes, holiday homes and retirement accommodation, was taking owner
occupation beyond the reach of many people resulting in young people and young families being
driven out of the communities where they worked or had grown up.”
Ten years later, however, these issues remain unaddressed in national and local policies.
2
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
As recommended, Carmarthenshire County Council has commissioned its own research to identify rural
needs:
MOVING RURAL CARMARTHENSHIRE FORWARD – Report and Recommendations of the Carmarthenshire
Rural Affairs Task Group – June 2019:
“As a local authority we cannot directly influence decisions that are made in Cardiff, London and
Brussels but we can strongly urge our representatives to do whatever they can to safeguard the
future of rural Carmarthenshire and rural Wales. This is essential so that future generations can
live, work and spend their leisure time in communities where valued traditions can be maintained,
but are also resilient enough to adapt to an ever-changing social and economic landscape. This
report seeks to encapsulate that crucial balance between preservation and progression.”
There is a disconnect between the recommendations in the MOVING RURAL CARMARTHENSHIRE
FORWARD report – supporting the efforts of local people to maintain and develop rural communities –
and the inflexibility of the planning framework.
_____________________________________________________________________________________
OBSERVATIONS AND CONSIDERATIONS ON
SPECIFIC ASPECTS OF THE LDP
(A number of observations and considerations are common to more than one Strategic Policy)
LDP: HOM3 - Homes in Rural Villages
11.90 This part of the Plan's rural policy framework seeks to establish a flexible but controlled approach to
the delivery of new homes within those (Rural Villages) settlements. The Plan utilises a criteria-based
assessment to define small scale housing opportunities in rural villages and to meet the need for new
homes in rural parts of Carmarthenshire at a scale and at locations which maintain the essential character
of the countryside.
PPW Housing 4.2.1: Planning authorities must understand all aspects of the housing market in their
areas, which will include the requirement, supply and delivery of housing. This will allow planning
authorities to develop evidence-based market and affordable housing policies in their development
plans and make informed development management decisions that focus on the creation and
enhancement of Sustainable Places.
TAN 2.2.1: Many rural communities can accommodate development, particularly to meet local needs.
New development can help to generate wealth to support local services, ensuring that communities are
sustainable in the long term. A key question for the planning authority, when identifying sites in the
development plan or determining planning applications, is whether the proposed development
enhances or decreases the sustainability of the community. In particular, planning authorities should
support developments that would help to achieve a better balance between housing and employment,
encouraging people to live and work in the same locality.
Observations:
• The policies exert much control but very little flexibility within rural settlements.
• The “character of the countryside” is not defined in planning terms. It seems to refer to the
appearance of the countryside while it should, in fact, refer to all aspects of rural life. It is the
biodiversity, the nature, the traditions and, primarily, the local knowledge of the history and culture
of that part of the countryside which forms the character.
• If we lose the local residents then we lose that knowledge and protection.
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• The criteria-based assessment prioritises maintaining the character of the countryside above
maintaining a local community.
• The policies fail to recognise the contribution of the local community to maintaining the character of
the countryside through its knowledge, traditions and protective practices.
CONSIDERATIONS:
• To apply additional flexibility to policies for rural villages to allow the needs of the
community to be met.
• To acknowledge the role of village residents in the enhancement and protection of the
“character of the countryside”.
• To measure the contribution a development makes to the well-being of the community
as opposed to considering only the perceived potential harm.
• To assess and recognise the scale of development required in rural villages to secure their
future as community strongholds.
LDP: HOM3 - Guidance on Acceptable Plots
Infill sites within these rural villages will take priority over other locations;
Where appropriate, sites adjoining a rural village are also acceptable. Such sites will be required to adjoin
the boundary of one property which forms part of the rural village group. All proposals which adjoin a group
(as opposed to infill sites) will be required to demonstrate the following:
• there is an existing physical or visual feature which provides a boundary for the group -
reducing pressure for unacceptable ribbon development or rural sprawl;
• where such a feature does not exist, there should be potential for such a feature to be provided
so long as it is in character with the scale and appearance of the group;
• Proposals located in open fields adjoining a group, which have no physical features to provide
containment will not be considered acceptable.
Observations:
• While infill sites should take priority over other locations, this should not exclude other locations.
• These rigid limitations appear logical in theory, but they are not practical in many rural settlements.
• The limitations do not take into account variances in our local topography.
CONSIDERATIONS:
1. To consider further potential development capacity in and around rural villages.
2. To apply rounding-off of boundaries to include capacity which logically allows sensitive
development.
3. To evidence actual harm against the potential for community benefit in setting and
respecting development boundaries.
LDP: HOM3 - Housing within development limits
Proposals which exceed the 10% cap above the number of existing homes in the settlement, as at the LDP
base date, will not be permitted except where they conform to Policy AHOM1 in relation to the provision of
affordable homes.
Observations:
• A settlement of 100 houses may only grow by 10 homes during the life of the LDP.
• A hamlet of 10 homes may only grow by 1 home during the life of the LDP.
• The rigidity of the 10% cap is not sympathetic to the aspiration to build sustainable rural
communities.
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• While an exception is provided for Affordable Housing, the needs of a community may also include
market housing such as bungalows, “downsize” accommodation and dwellings to fit growing
families.
• If the linguistic and cultural vitality of rural villages is encouraged to grow from the inside, then rigid
caps are not appropriate.
CONSIDERATIONS:
1. To measure each application for a residential dwelling on its merits in the context of its
community, not only the context of development boundaries.
2. To assess the potential for development within or bordering the development limits in
the context of the particular settlement, and provide flexibility of boundaries where the
geography/topography does not allow expansion.
3. To provide for exceptions where affordable/local needs housing cannot be
accommodated within or bordering the development limits.
4. To consider the need for market housing to meet the needs of those who will not qualify
for Affordable Housing.
5. To remove the 10% cap above the number of existing homes in the settlement.
LDP: HOM4: Homes in Non-Defined Rural Settlements
Proposals for new single homes in settlements, hamlets and groups of dwellings which are not identified
under Strategic Policy SP3 will be permitted where they meet a local need for affordable housing and
conform to the following:
• It represents sensitive infill development of a small gap within an otherwise continuous built-up
frontage; or, is an appropriate rounding off of the development pattern;
• The development is of a scale that is consistent with the character of the area;
• The proposal will not result in an intrusive development in the landscape, and will not introduce a
fragmented development pattern;
• The size of the property reflects the specific need for an affordable dwelling in terms of the size of
the house and the number of bedrooms;
• That the occupancy of the dwelling is restricted both on first occupation and in perpetuity to those
who have a need for an affordable dwelling.
11.93 There are a notable number of small settlements or groups of dwellings throughout the County which
have not been defined within the settlement framework, and as such do not have development limits.
11.94 It is also noted that such provision needs to be delivered within the backdrop of a national agenda
centred on sustainability with placemaking at its heart. In this respect reference is made to the provisions of
PPW Ed.11 which requires that all residential development away from existing settlements or centres be
strictly controlled. The policy therefore in reflecting the provisions of national policy restricts local
affordable need dwellings in rural areas to established groups of dwellings.
PPW Strategic Placemaking 3.44: Consideration should be given to whether specific interventions from
the public and/or private sector, such as regeneration strategies or funding, are required to help deliver
the strategy and specific development proposals.
PPW Development in the Countryside 3.60: Development in the countryside should be located within
and adjoining those settlements where it can best be accommodated in terms of infrastructure, access,
habitat and landscape conservation. Infilling or minor extensions to existing settlements may be
acceptable, in particular where they meet a local need for affordable housing or it can be
demonstrated that the proposal will increase local economic activity. However, new building in the
open countryside away from existing settlements or areas allocated for development in development
plans must continue to be strictly controlled.
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PPW Housing Delivery 4.2.24: In the open countryside, away from established settlements recognised
in development plans or away from other areas allocated for development, the fact that a single house
on a particular site would be unobtrusive is not, by itself, a good argument in favour of permission;
such permissions could be granted too often, to the overall detriment of the character of an area.
11.95 Whilst the Revised LDP is supported by a robust evidence base it is acknowledged that details of
housing need changes over time. Affordable housing proposals will be required to submit evidence
demonstrating the specific local need and ensure that the proposal provides for the size, type and tenure of
houses required. Proposals to meet speculative local need application will not be considered, rather they
should relate to an identified need from individuals/families within the specific area.
11.96 Where available, local housing needs surveys should be utilised in providing this evidence.
Alternatively, other forms of evidence may be considered appropriate including Strategic Housing Market
Area Assessments and local needs/Lettings registers.
Observations:
• Each regulation is based on geography and existing development patterns. The “protection” of the
settlement image takes priority over the actual needs of local people.
• There is no provision at all for dwellings which are not Affordable Housing. Not all local people need
Affordable Housing, but they have Local Housing Needs for a variety of reasons.
• Small Settlements or Groups of Dwellings are common in our rural countryside. While needing to be
“controlled”, exceptions should be possible where there is evidenced local need.
• Such exceptions should not be limited to Affordable Housing as many mature members of the
community do not qualify. Older members of the community have a strong need to remain in their
community for reasons of health, mental health and social interaction.
• Box-ticking to qualify for Local Needs does not always allow local people to express their unique
needs or to argue their case outside the specific requirements.
• While Local Needs/Letting registers may confirm the needs of young families seeking housing, many
members of the community who have local needs are excluded from housing registers.
• Retiring local farmers or other rural workers will not qualify for Affordable Housing in their life-long
community. No provision is possible for families or individuals who need to stay within their support
network in Non-Defined Rural Settlements.
CONSIDERATIONS:
1. To prioritise the needs of the people and the community over the visual or conceptual image
of the settlement.
2. To use the actual housing needs of applicants to drive the policy, not devise a policy which
excludes the very housing needs it is intended to address.
3. To provide some capacity with the policy for those who do not qualify for Affordable
Housing but whose needs are equally important.
4. To define what “too often” means in granting permissions in the open countryside, and
consider the local needs of individuals above non-defined caps.
5. To consider the need within the community for young families, not only the need of a family
to live in a location.
6. To provide a needs-assessment which is not exclusively a “box-ticking” exercise.
7. To prioritise matching the needs of individuals with the needs of the community over
reducing numbers on Housing Registers.
LDP: AHOM2 - Affordable Housing - Exceptions Sites
Proposals for 100% affordable housing development on sites adjoining the Development Limits of defined
settlements (Tiers 1-3 in Policy SP3), will, in exceptional circumstances be permitted where it is to meet a
genuine identified local need (as defined within the Glossary of Terms) and where:
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• The site represents a logical extension to the development limits and is of a scale appropriate, and
in keeping with the character of the settlement;
• The benefits of the initial affordability will be retained for all subsequent occupants;
• It is of a size, scale and design compatible with an affordable dwelling and available to low or
moderate income groups;
• There are no market housing schemes within the settlement, or projected to be available which
include a requirement for affordable housing.
TAN 6: 2.2.4: They (planners) should also ensure that any sites identified for development are effectively
available and likely to be brought forward for development by the owner. This is particularly important in
smaller settlements, where a limited number of landowners may control land supply
TAN 2: 10.12: It is important that there is adequate housing provision in rural areas to meet the needs
of local people and to contribute to the delivery of sustainable communities. Development plans must
set out how planning at the local level will contribute to meeting identified rural affordable housing
needs.
TAN 2: 10.16 Local planning authorities must set out in their development plan their definition of ‘local
need’ for affordable housing in rural areas, within the overall aim of contributing to the delivery of
sustainable communities. This can include:
• existing households needing separate accommodation in the area;
• people whose work provides essential services and who need to live closer to the local
community;
• people with a family connection or long standing links with the local community; and
• people with a job offer in the locality who require affordable housing.
For some of these categories the area within which needs will be considered ‘local’ must also be
defined in the development plan. This may include:
• the village or group of villages;
• the community council area;
• an electoral ward or group of wards;
• the local authority area.
TAN 2: 10.14 Rural exception sites are not appropriate for market housing.
11.124 An affordable dwelling must be compatible with WG's Design Quality Requirement standards to limit its
size, scale and design to ensure that the dwelling falls within a reasonable and acceptable affordable dwelling
cost for future occupants. In exceptional circumstances, a departure from these standards may be considered
appropriate where they are to meet the occupant's needs and are clearly evidenced and justified.
Observations:
• Availability of land dictates the potential for Exception Sites.
• While Exception Sites provide the potential for Affordable Housing adjoining Local Development
boundaries, this may not be possible in many rural villages.
• The topography of our area does not always permit development outside existing settlements and
steep gradients make affordable construction unviable.
• Where land may be available, other factors may not meet requirements such as Highways, SAB
assessments etc. thus limiting the potential for development.
• Non-availability of land in and around Defined and Non-Defined Rural Settlements results in no housing
to meet local needs.
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• There are natural boundaries between communities which dictate social interaction. A nearby
community, across a river or motorway, may be more alien to a local individual than a town twenty
miles further afield.
• There is no provision at all for market housing in many rural settlements. If you don’t qualify for Local
Needs, or there is no Local Needs capacity in your community – you can’t live there.
• The size, scale and design of Affordable Housing cannot accommodate a growing family, especially
where children are not all of the same gender and vary in age.
• “Exceptional Circumstances” may not be so exceptional. Some quite ordinary circumstances exclude
local people from qualifying for Local Need.
• Young families wishing to return to their area to bring up their children and who have owned a
home in another area will not qualify for Affordable Housing, but cannot afford open market
housing.
• There is no guidance on what constitutes an “exception”. The policy accommodates nuclear families
with 2.4 children. There is no provision for Blended Families whose needs are more varied and
extensive.
CONSIDERATIONS:
1. To acknowledge that Exception Sites are at the discretion of local landowners, access/highways
restrictions, SAB requirements and other limiting factors.
2. Where no Exception Sites can be identified, to exercise flexibility in considering alternative sites
which may deviate from the current permitted sites.
3. Where particular individual “locality” needs are identified, to consider applications for nonaffordable
housing development in the interest of the individual, the family and the community.
4. To consider the definition of “local” in the context of the individual and the community rather
than by a radius of concentric miles.
5. To assess the needs of growing families when calculating the size, scale and design of Affordable
Housing in order to provide long-term security and a decent quality of life.
6. To acknowledge the housing aspirations of young families in rural areas as a material planning
consideration.
LDP: EME4 - Employment Proposals on Non-Allocated Sites
Proposals for employment development on non-allocated sites, but within the development limits of a
defined settlement will be permitted where:
• it is demonstrated that no other suitable existing or allocated employment sites or previously
developed land can reasonably accommodate the proposal;
• the development proposals are of an appropriate scale and form, and are not detrimental to the
respective character and appearance of the townscape/ landscape;
• The development is compatible with its location and with neighbouring uses.
Employment proposals outside the development limits of a defined settlement (Policy SP3) will be permitted
where:
• The proposal is directly related to a settlement or hamlet; or
• The proposal is supported by a business case which demonstrates that its location is justified; and
• The proposal is of an appropriate scale, size and design.
11.165 For proposals outside the development limits of a defined settlement, they must show that they are
directly related to a settlement or hamlet, or supported by a business case which justifies its location. The
Plan recognises that small-scale enterprises have a vital role to play in the rural economy and contribute to
both local and national competitiveness and prosperity. Many commercial and light manufacturing
activities can be appropriately located in rural areas without causing unacceptable disturbance or other
adverse effects. In this respect, the development of small businesses would address any local need for
employment accommodation.
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PPW: The Rural Economy 5.6.4 To unlock the full potential of rural areas, planning authorities should
adopt a positive approach to employment arising from foundation and innovative and technology
based sectors, including research and development, in addition to employment arising from the
traditional agriculture, forestry and leisure sectors. Proposals for diversification, new startups and
micro-businesses should also be encouraged, where appropriate, to generate new job and wealthcreating
opportunities.
TAN 6: 2.2.2: Development plans should define local need taking into account the social, economic and
environmental characteristics of the area. Where possible existing definitions of local need,
for example affordable housing to meet local need, should be adopted, or if necessary modified
to include other land uses.
Observations:
• There is no connection provided between Employment on Non-allocated Sites and the needs of rural
villages to remain sustainable. Living and working within the community is vital to its existence.
• Some capacity has to be provided to acknowledge the place of small-scale businesses within rural
communities. There is no provision for small-scale commercial enterprises.
• The increase in home-working needs to be supported by flexibility across all genres of employment.
Additional space may be needed – inside and outside development limits – to accommodate future
working practices.
• This will be mitigated by reduction in travel and healthier work-life balances, thus meeting the aims
of our well-being goals.
CONSIDERATIONS:
1. To apply flexibility in meeting the needs of local people to work within their community.
2. To provide working spaces which accommodate local employment in areas outside or
without development limits.
3. To encourage satellite working as and when technology permits during the lifetime of the
LDP.
LDP: SP 8 - Welsh Language and Culture
The Plan supports development proposals which safeguard, promote and enhance the interests of the
Welsh language and culture in the County. Development proposals which have a detrimental impact on the
vitality and viability of the Welsh language and culture will not be permitted unless the impact can be
mitigated. All development proposals subject to WL1, will be expected to identify measures which enhance
the interests of the Welsh language and culture.
11.174 The Plan seeks to 'promote the Welsh language and culture'[59] and is committed to contributing to
the Welsh Government's long-term aim of achieving 1 million Welsh speakers by 2050[60]. To deliver on this
aim, the Council will support, promote, and enhance the Welsh language as a viable community language
by ensuring that there are sufficient and proportionate employment and housing opportunities to sustain
both the rural and urban communities in the County and by implementing an effective monitoring
framework. In doing so, the Plan seeks to ensure that the local population have the opportunity to remain in
Carmarthenshire rather than leave in search of work opportunities and housing, as well as the opportunity
to return. Through aiming for sustainable growth, the Plan will also maximise opportunities for non-Welsh
speakers who move to the County to be integrated into community life at a scale and pace that will not
undermine the vitality and viability of the Welsh language and culture.
11.177 The Plan also seeks to safeguard, promote, and enhance the Welsh language in Carmarthenshire
through other relevant policy objectives, namely through the provision of housing and affordable housing,
promoting a vibrant economy and employment opportunities and the provision and retention of community
facilities, amongst others.
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TAN 20: 1.4.8 Section 70(2) of the Town and Country Planning Act 1992 (TCPA) clarifies that
considerations relating to the use of the Welsh language may be taken into account when determining
applications for planning permission, so far as they are material to the application. This may apply to
any application in any part of Wales. This provision does not give any additional weight to the Welsh
language above any other material consideration.
LDP: WL1 - Welsh Language and New Developments
All development proposals throughout Carmarthenshire will be required to safeguard, promote and
enhance the Welsh language … Proposals which do not accord with the Plan's housing trajectory will be
required to provide a phasing plan outlining the timescales for delivering the homes proposed on the site
and demonstrate that they would not have a negative impact upon the Welsh language which cannot be
mitigated.
11.178 The Welsh Language Action Plan sets out the measures to be taken to safeguard, promote and
enhance the Welsh language. The Welsh Language Action Plan should also outline how the development
proposes to make a positive contribution towards the community's Welsh language groups. This could,
amongst others, include providing support and funding towards organisations and bodies that provide
activities, facilities and education for Welsh speakers and learners, and support and funding towards Welsh
language classes. Welsh Language Impact Assessments (WLIA) will be required to outline the anticipated
impacts of the proposed development upon the Welsh language in the County. The Welsh Language
Supplementary Planning Guidance[61] provides further guidance on when a WLIA is required, clarifying
what constitutes a large scale development, as well as how to produce a WLIA.
11.182 The ISA of the LDP is required to assess the likely effects of the LDP upon the Welsh language. This is
done iteratively at key stages throughout the Plan's production. The likely anticipated effects are presented
in the ISA report, and further information is available within the LDP's evidence base.
TAN 20: 3.3.2 Evidence from the language impact assessment may be material to the application and
may inform whether measures to mitigate or enhance the impacts of the development on the use of
the Welsh language should be applied.
Welsh Language County Strategic Forum: “Language planning work within the LDP process, particularly
the development of a new methodology to measure the impact of land use on the Welsh language” notes
a “Lack of national guidance and dependable information on the impact of construction on the Welsh
language in terms of numbers of permitted locations for house building and their geographical locations.”
Carmarthenshire Welsh Language Promotion Strategy 2023 – 2028: p.7 Despite the positive contribution
of all the above policies, a number of factors that most adversely affect the Welsh language in
Carmarthenshire remain outside their scope. The affordability of housing for local young people for
example is largely influenced by the open market and private sector profits. The same is true with regard
to the influx of older people from outside Wales into Welsh-speaking communities. After the first
Strategy's efforts to work with estate agents to try to gain useful information to address this problem, it
must be recognised that it is only Welsh Government who are in a position to meaningfully influence these
factors. We look forward to working together on innovative efforts by the government in this area of work
and to explore new law-making forces that could mitigate harmful effects on the Welsh language.
Welsh Government: CYMRAEG 2050: a Million Welsh Speakers: Development and the Welsh language -
p.63: The land use planning system should contribute to the vitality of the Welsh language by creating
suitable conditions for thriving, sustainable communities, supported by an awareness of the relevant
principles of language planning. Decisions regarding the type, scale and exact location of developments
within a specific community has the potential to have an effect on language use, and as a result on the
sustainability and vitality of the language. This calls for strengthening the relationship between language
planning and land use planning.
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Cyngor Sir Gâr: Notice of Motion 10.7.2019 (unanimously supported): “This council believes that the
whole of Carmarthenshire is an ‘area of linguistic sensitivity and significance’ and that the planning system
has a crucial role to play in supporting the Welsh language across the county. To this end, we believe that
the language should be a Material Planning Consideration in all applications for the development of five or
more houses in rural areas and ten or more in urban areas in every community, irrespective of the
percentage of Welsh speakers.
Observations:
• Cyngor Sir Gâr’s Notice of Motion identifies the whole county as an area of linguistic sensitivity and
as such should be recognised as a positive material consideration in rural areas.
• In reality, the Plan does not acknowledge the importance of small rural communities in its
safeguarding and enhancement of the Welsh Language. Many of our rural villages are the
strongholds of first-language Welsh-speakers and form the foundation of Welsh language and
culture throughout the county. Welsh speakers are concentrated in these areas, but the ability of
young families to live and work within these communities is limited by the Plan and other regulatory
factors.
• The Plan addresses two aspects of Welsh-language safeguarding:
a) It requires assessments on the impact of developments on the Welsh language;
b) It provides for activities, facilities and education which promote the Welsh language;
• The Plan does not provide for sensitive development within the small community strongholds of the
language. Welsh-speakers who cannot build or buy within their villages, or in the surrounding areas,
cannot support the language in their native communities.
• Local people may have access to land which would reduce costs and make the building of their own
home viable. Proportionate development on private land should be made possible where
appropriate.
• Rural Welsh-language villages need proactive policies to offer accommodation in the community –
both to young families in need of Affordable Housing and to those requiring market housing.
• Assessments of the likely effects of the LDP on the Welsh language will depend on the detail
available and be data-led.
• Pre-planning Welsh-language Assessments are appropriate for larger developments in service
centres and towns, however, external assessments do not evidence the actual prosperity of the
language in small villages and communities.
• Welsh-language impact assessments are commissioned by the applicant and may not always be
independent.
• A reversal of thought is required so that the needs of the Welsh language influences the LDP rather
than the LDP attempting to react to perceived needs.
• The data on Welsh-speakers in Carmarthenshire has not yet been based on the 2021 Census and is
out of date.
• There is very little planning guidance attached to the Welsh Government policy to achieve one million
Welsh speakers by 2050.
• While the CYMRAEG 2050 policy calls for strengthening the relationship between language planning and
land use planning, Welsh Government’s own planning policies make this impossible.
CONSIDERATIONS:
1. To recognise the Linguistic Sensitivity of the whole county and the potential of rural
communities to increase the number of Welsh-speakers if supported proactively through the
LDP.
2. To move from assessing impact to providing positive measures to develop Welsh-language
strongholds.
3. To acknowledge that strict controls on market housing in rural areas harms Welsh-language
communities.
4. Where development is evidenced through local need, to balance the potential visual harm to
rural areas against the potential benefit to language and culture.
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5. To provide a body to conduct Welsh-language impact assessments which is independent of
the applicant and the Local Planning Authority.
6. To re-assess Welsh-language impact policies as soon as the 2021 Census data is available.
7. To recognise the need for Welsh Government to explore new approaches to planning in
rural areas in order to enable local Welsh Language Strategies to be implemented and to
enable CYMRAEG 2050 to be a realistic possibility.
LDP: SP11 - The Visitor Economy: Respecting the County's social, economic and environmental fabric.
11.234 All parts of the County possess qualities that contribute to the overall sense of place. These include
landscape, nature conservation, social fabric and built environment. These are assets which must be
protected for our future generations and cannot be unduly compromised by tourism related development.
11.235 There should also be an emphasis on providing quality in all aspects of a proposal. In considering the
acceptability of proposals, consideration will be given to location, siting, design and scale, access to the
primary and core highway network and the impact of any resultant traffic generation. Furthermore, the
extent to which the site is serviceable by public transport, walking and cycling are important considerations.
Proposals should reflect the character and appearance of the area with appropriate landscaping and
screening utilised as required.
11.239 The County's rural areas are well placed to accommodate proposals for high quality and sustainable
proposals that are of an appropriate scale. Proposals should respect the County's assets whilst supporting
vibrant rural communities.
11.240 Some tourism related developments, by their very nature, must be located in the countryside. It is
important that these developments do not have any significant negative impact on the landscape, natural
environment, or amenity. In terms of the detailed policies for the Revised LDP, the emphasis is on providing
clarification on the two notable challenges and opportunities facing the visitor economy in Carmarthenshire
which are attractions (somewhere to go) and accommodation (somewhere to stay).
LDP: VE2 - Holiday Accommodation
Proposals for high quality serviced accommodation, including appropriate extensions to existing
accommodation, will be permitted where they are located within, or directly related to a defined settlement
(Policy SP3).
Proposals for serviced and self-catering accommodation that are located outside of the above locations will
only be permitted where they consist of the re-use and adaptation (including conversion) of existing
buildings in conjunction with policy RD4.
All proposals set out above should reflect and respect the role and function and sense of place of the area,
most notably in terms of scale, type, character, design, layout and appearance - as well as those uses
already located in the vicinity of the site.
11.247 Where planning permission is given for permanent holiday accommodation, the Council will
consider the attachment of conditions restricting the use to holiday accommodation only. Seasonal
occupancy conditions may also be used to prevent the permanent residential occupation of such
accommodation. In addition, in areas where the prevalence of second homes and holiday homes are known
to be a serious issue within communities, the Council will consider placing restrictions upon permitted
development rights to change existing dwellings to holiday homes and second homes.
LDP: VE4 - Static Caravan and Chalet Sites and Permanent Alternative Camping Accommodation:
Proposals for new Static Caravan and Chalet Sites will be permitted where:
• they are within or directly related to a defined settlement (Policy SP3), or, they are located or
demonstrate a spatial and functional relationship with a relevant existing tourism facility or
attraction;
• they are of high quality in terms of design, layout and appearance, and will not have an
unacceptable adverse effect upon the surrounding landscape and/or townscape;
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• they will not lead to a significant and unacceptable intensification in the provision of sites in the
locality;
Proposals for the enhancement and extension of existing sites will be permitted where:
• it will increase the vitality, sustainability and environmental quality of the site;
• it will not result in an unacceptable increase in the density of units and/or the overall scale of the
site.
• it will not have an unacceptable harm on the surrounding landscape, seascape and / or townscape;
• it provides (where appropriate) for the significant improvement of the overall quality, appearance
and setting of the site.
11.256 This policy recognises that appropriate high-quality proposals should be supported. This recognises
the need to provide a diverse accommodation offer in terms of providing a range and choice of places to
stay within the County.
TAN13: TOURISM – Published in 1997, this document is woefully inadequate to address the needs of
accommodating visitors in 2023 and the future.
Observations:
• “The County’s rural areas are well placed to accommodate proposals for high quality and
sustainable proposals that are of an appropriate scale” suggests that tourism developments take
priority over residential developments. Nowhere does the Plan refer to residential development
located in the countryside in such positive terms, but tourism is accommodated with flexibility.
• The re-use and adaptation (including conversion) of existing buildings outside a settlement is
permitted for visitor accommodation but not for housing for local people.
• No evidence is provided to illustrate why holiday accommodation is considered to have less impact
on the countryside than residential dwellings. This in no way suggests that there be should be
competition between both uses, but it is not clear how holiday accommodation makes a greater
contribution to sustainable communities than housing for local people.
• A “spatial and functional relationship with a relevant existing tourism facility or attraction” includes
the open countryside. If static Caravans and Glamping Pods are of a scale, layout and design
appropriate to the setting, and if properly screened, such developments provide diversification
income to rural areas while providing much needed visitor accommodation.
• The rigidity of travel planning restrictions where public transport is not readily available bars much
unintrusive development.
• While Static Caravan, Chalet and Glamping Pod Sites in rural areas are subject to rigid planning
regulation, the ownership and use of these units as second homes prevents the purchase of
residential family dwellings for holiday purposes. This helps protect traditional rural homes from
second home use, while purchasing a chalet on a park is far less costly as a second home than
purchasing a house.
CONSIDERATIONS:
1. To question if the visitor economy is prioritised over local needs, and consider both
community benefits on equal terms.
2. In light of the recent policy on Second Homes/Holiday Homes Council Tax Premium, to
consider permitting residential use of existing holiday accommodation in the open
countryside which may no longer remain viable.
3. To recognise that small, well-designed accommodation sites in the open countryside provide
diversification opportunities to farming communities and contribute to the local economy.
4. To encourage well-sited Static Caravan, Chalet and Glamping Pod Sites in areas heavily
affected by second home use as an attractive option to potential second home purchasers.
5. To provide a balance of residential and tourism accommodation in rural areas to encourage
mutual support between communities and visitor economy.
6. To replace TAN13 with guidance which is appropriate and relevant to the life of the Plan.
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LDP: SP 12 - Placemaking and Sustainable Places
11.269 The Act means that public bodies such as local authorities must work to ensure that developments
should acknowledge and seek to improve the economic, social, environmental, and cultural well-being of an
area.
Observations:
• With regards to social and cultural well-being, there is no provision for placing small rural
communities at the centre of policy, or for building the policies around the needs of village
communities.
CONSIDERATIONS:
1. To recognise the place of small communities in achieving the aims of the Well-being and
Future Generations Act.
2. To allow rural communities to improve and grow on a par with urban communities.
LDP: SP 13 - Rural Development
11.366 The rural settlements of the County have an important role to play in improving the sustainability of
the wider geographical area in which they are located as well as the County's overall sustainability. The
Plan's strategy and settlement hierarchy reflects the significant role which the rural communities play
through supporting growth of a proportionate scale which can make a positive contribution towards the
long-term sustainability of the rural economy and rural communities.
11.367 Proportionate and sensitive development can provide the level of growth required to retain and
enhance the services and facilities provided in the County's rural settlements. It can also serve to safeguard
and promote the Welsh language in rural areas and enhance rural employment opportunities. However, the
Plan seeks to ensure that development and growth does not have negative impacts upon a community's
sustainability. Key to this is ensuring that development is not permitted at a scale or rate which would affect
the community's ability to absorb and adapt to growth and change. This is imperative when considering the
impacts which development can have upon the local infrastructure, the vitality of the Welsh language and
the sustainability of the countryside and natural environment.
11.368 National planning policy has historically sought to restrict unnecessary development in countryside
locations, principally to prevent sporadic and unsustainable growth and to maximise use of infrastructure,
resources and services more commonly available in established urban areas.
11.369 Whilst this principle remains relevant and applicable, there is an enhanced recognition of the
countryside as a place of work, as a home for many, a place to visit for others and a vital ecosystem for
everyone. The Plan is committed to addressing and safeguarding the needs of rural communities. To this
end, the Council established a Rural Affairs Task Group with the aim of assessing the needs of rural
communities and taking positive steps to address these. This Plan supports the aims and outcomes from the
Task Group principally through policies relating to the provision of housing and affordable housing; the
economy and employment; the Welsh language, and the natural environment. Development proposals will
need to demonstrate that they accord with these policies as well as the provisions of national planning
policy.
PPW: Placemaking in Rural Areas 3.38: The countryside is a dynamic and multi-purpose resource. In
line with sustainable development and the national planning principles and in contributing towards
placemaking outcomes, it must be conserved and, where possible, enhanced for the sake of its
ecological, geological, physiographic, historical, archaeological, cultural and agricultural value and for
its landscape and natural resources. The need to conserve these attributes should be balanced against
the economic, social and recreational needs of local communities and visitors. Fostering adaptability
and resilience will be a key aim for rural places in the face of the considerable challenge of maintaining
the vibrancy of communities and availability of services as well as contributing to the Cohesive
Communities well-being goal.
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11.373 This understanding of diversity is reflected within PPW in its consideration of sustainable transport
requirements. It recognises there is a need to reflect different approaches to sustainable transport in
defining growth within rural settlements.
TAN 6: 2.2.3 Where development proposals are intended to meet local needs, planning authorities
should recognise that a site may be acceptable even though it may not be accessible other than by the
private car. Development not intended to cater primarily for local needs should continue to be located
in market towns, local service centres or clusters of smaller settlements where a sustainable functional
linkage can be demonstrated and which are accessible by public transport.
Observations:
• “The Plan is committed to addressing and safeguarding the needs of rural communities” - the Plan
does not address the needs of rural communities.
• The Rural Affairs Task Group states that:
“There is of course a recognition of the need for sensitive consideration of a number of factors
when looking at development in rural areas but the Task Group feels that current planning
policy from Welsh Government does not give enough flexibility to enable development, based
on local need, in our most rural communities.”
• While the preservation of the countryside is important, the policy “moth-balls” rural villages as
static entities and “enhances” them by keeping them attractive to visit and view. The policies invite
people to observe the attractive characteristics – culture, tradition, Welsh-language without
attempting to develop these characteristics and make them sustainable.
• Sustainable transport policies are limiting the development of rural housing while they encourage
extending the development of holiday accommodation. The travel footprint of weekly visitors to
and around rural areas is not measured against the travel footprint of weekly activities of local
residents.
CONSIDERATIONS:
1. To place rural communities at the heart of the Strategic Policy.
2. To provide “…enough flexibility to enable development, based on local need, in our most
rural communities”.
3. To define “enhancement” in material terms as regards sustaining and developing the
language, culture and heritage of our rural areas.
LDP: Rural Enterprise Dwellings
11.379 As noted through national policy, a rural enterprise dwelling is required where it 'is to enable rural
enterprise workers to live at or close to their place of work'. This includes encouraging younger people to
manage farm businesses and supporting the diversification of established farms.
11.380 It is not the role or the intention of the Revised LDP to replicate the provisions of national planning
policy. Consequently, reference should be had to the provisions of PPW and Technical Advice Note 6 (TAN6)
in the determination of applications for new rural enterprise dwellings. National policy clearly states that
such proposals should be carefully examined to ensure that there is a genuine need.
11.381 Applications for rural enterprise dwellings should be accompanied by a rural enterprise dwelling
appraisal, with permission only granted where it provides conclusive evidence of the need for the dwelling.
TAN 6: 4.1.1 The Assembly Government’s vision for housing is for everyone in Wales to have the
opportunity to live in good quality, affordable housing, to be able to choose where they live and decide
whether buying or renting is best for them and their families. This vision is applicable to both urban
and rural areas.
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Observations:
• The bar for proving “conclusive evidence of the need for the dwelling” is uniquely high for Rural
Enterprise Dwellings in comparison with other housing categories. The amount of necessary
evidence and the years required to compile data makes such applications prohibitive.
• TAN6: 4.1.1 contradicts the lengthy and detailed restrictions placed on individuals and families
attempting to remain in their local community.
• The need to live near a rural enterprise should not be assessed on the employment needs of the
enterprise alone. Families support rural enterprises in many other ways, not only through their
employment on the site.
• Families in alternative fields of employment who have strong ties to the site should be encouraged
to remain within their traditional and cultural setting.
CONSIDERATIONS:
1. To bring the requirements of Rural Enterprise Dwellings in line with the requirements of
all other housing requirements – including urban housing and One Planet Development
housing.
2. To apply the same test of need for a rural enterprise dwelling as that for a dwelling on a
One Planet site.
3. To recognise the potential contribution of Rural Enterprise Dwellings to the sustainability
of language, culture and heritage.
4. To acknowledge that creating an additional dwelling on a rural enterprise site supports
the business and family whether or not the residents are in the employment of the
enterprise.
LDP: RD2 - Conversion and Re-Use of Rural Buildings for Residential Use
Proposals for the conversion and re-use of suitable rural buildings for residential use will be permitted
where:
• the existing use has ceased, and its re-use would not result in the need for an additional
building;
• the design and materials are of a high quality, and the form and bulk of the proposal, including
any extensions, curtilage and access arrangements are sympathetic to and respect: the
surrounding landscape, rural character of the area and the appearance of the original building;
• Proposals for extensions should be proportionate and reflective of the scale, character and
appearance of the original building;
• the original building is structurally sound and any rebuilding works, necessitated by poor
structural conditions and/ or the need for new openings in walls, do not involve substantial
reconstruction;
• where applicable, the architectural quality, character and appearance of the building is
safeguarded and its setting not unacceptably harmed.
TAN 6: 3.6.1 Whilst residential conversions have a minimal impact on the rural economy,
conversions for holiday use can contribute more and may reduce pressure to use other houses in the
area for holiday use.
Observations:
• While RD2 permits the conversion of suitable rural buildings for residential use, the majority of
these buildings lie outside the development limits of rural villages and therefore cannot be
permitted as residential dwellings.
• This excludes a number of surplus farm buildings from being converted to homes for young local
families, although they can be converted for holiday use.
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• It is asserted that residential conversions for holiday use can contribute more to the local economy.
Is there evidence that holiday accommodation contributes more to the local economy than
residential families? This statement does not consider factors such as holiday accommodation being
owned by individuals well outside the “local economy” and where the income goes directly out of
the local area, county or country.
• It does not consider the contribution a residential family makes to the local economy on a daily,
weekly and annual basis. A data-based study would provide evidence of this assertion.
CONSIDERATIONS:
1. To apply the same impact measurements of conversion to holiday cottages/barns on the
open countryside as to conversion to residential cottages/barns in the open countryside.
2. To provide evidence of the carbon footprint benefit of tourist against that of residents.
3. To permit re-use/conversion of surplus rural buildings for residential use side by side
with holiday use.
LDP: HOM7 - Renovation of Derelict or Abandoned Dwellings:
Proposals for the renovation of derelict or abandoned dwellings outside the Development Limits of a
defined settlement (Policy SP3) will be permitted where:
• It can be demonstrated that a significant part of the original structure is physically sound and
substantially intact requiring only a limited amount of structural remedial works;
• The building demonstrates and retains sufficient quality of architectural features and traditional
materials with no significant loss of the character and integrity of the original structure;
• There are no adverse effects on the setting or integrity of the historic environment.
11.104 The renovation of abandoned dwellings can make a small but important contribution to the needs of
an area. The architectural value of a number of derelict or abandoned dwellings often reflects the
traditional vernacular and should be recognised in the submission of such proposals. Extensions, access
requirements or other aspects associated with the proposal should be sympathetic to the character of the
original building and the landscape. Proposals which seek to make a positive contribution to the landscape
qualities of the area will be encouraged.
Observations:
• There is very little policy detail or guidance on the re-use of derelict dwellings or ruins to provide
homes for local families. The guidance for derelict dwellings is arbitrary and open to interpretation.
• Sir Gâr no longer has a “tradional vernacular” style of dwelling. Most modern houses have for
decades been built with breeze blocks. It is reasonable that farm buildings constructed from such
materials, possibly with re-facing, should be considered for adaptation as dwellings.
• As part of the Levelling Up strategy, the UK Government has consulted on the “Right to Regenerate”
bill which promises to re-use derelict buildings in public ownership, but not in private ownership.
• Farming unions are encouraging rural owners not to allow their property to fall into the
“Abandonment” category which will require full planning permission for re-instatement as a
residential dwelling.
CONSIDERATIONS:
1. To acknowledge the historic use of a derelict/abandoned dwelling in the open countryside in
order to return it to its traditional residential use.
2. In 2023, to recognise the reality of the nature of the construction of many 20th Century rural
buildings and consider their sensitive re-use as dwellings.
3. To encourage proposals which seek to make a positive contribution to the landscape
qualities of the area.
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RE-USE OF PLACES OF WORSHIP
11.450 Many elements of the County's built and historic environment are protected through legislation or
other policy provisions, and as such do not require policies in the revised LDP. The Plan does not therefore
include policies in relation to facets of the built heritage such as Scheduled Monuments as they are
adequately protected elsewhere.
TAN24: Historic Assets of Special Local Interest - 8.1 - Historic assets that the local planning authority
may consider to be of special local interest are not accompanied by any additional consent
requirements over and above those required for planning permission. However, if such assets are to
contribute successfully to the conservation or enhancement of local character their status needs to be
clear in the development management process. If a local planning authority chooses to identify historic
assets of special local interest, it must include policies for their preservation and enhancement in the
local development plan.
Managing Change to Listed Places of Worship in Wales – Welsh Government: 5.13 Closed or Closing
Places of Worship: Listed places of worship may have a continuing and valuable contribution to make
to the community even when they are no longer required for worship. Before they cease to be used for
worship, it is important that there is no unnecessary delay in finding alternative uses compatible with
the significance of the fabric, interior, contents and setting of the building.
CADW - Historic Assets Of Special Local Interest: Local planning authorities may choose to identify
historic assets of special local interest - known as ‘local listing’ … Local listing is important because it
provides the base for local planning authorities to develop policies for their protection and
enhancement. This means that local planning authorities can manage change through the planning
system so that local historic assets continue to contribute to the vitality of the area … Local listing also
provides an opportunity for a community to get involved in the identification of historic assets of
special local interest and in caring for them appropriately.
Observations:
• There is very little guidance on the functional re-use of chapels and churches in rural communities
apart from their historic surroundings and facades.
• Many church and chapel buildings in rural areas are converted for holiday/second home use. This is
not consistent with the interests of “local listing” to preserve the contextual integrity of the
community asset.
CONSIDERATIONS:
1. To acknowledge that the LDP could include measures to assess, secure and re-use closed
Places of Worship for the benefit of the community.
2. To encourage conversations between representatives of closing Places of Worship, planners
and the community before disposal of the asset.
3. To consider placing covenants on Chapels and Churches being converted to dwellings to
ensure they are permanent residential dwellings rather than second homes in order to
protect the historic integrity of the building for the future.
4. To require that CADW exercises flexibility in its approach to the re-use of local historic assets
so that they remain of value and interest to the community.
LDP: RD3 - Farm Diversification
Proposals for farm diversification developments which strengthen the rural economy will be permitted
where:
• It is compatible with, complements and supports the principal agricultural activities of the existing
working farm;
• It is of a scale and nature appropriate to the existing farm operation;
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• It has appropriate regard to the highways and transport infrastructure;
• It would not have an adverse impact on the character, setting and appearance of the area and the
surrounding landscape.
11.393 Diversification in rural areas can often add to the income streams and economic viability of farms,
strengthen the rural economy, and add to wider employment opportunities.
11.394 Farm diversification proposals are intended to supplement and support the continuation of the
existing farming activity. Proposals should be accompanied by evidence detailing a justification for the use
and its relationship with the existing farming activity.
11.396 In considering proposals for farm diversification it is acknowledged that their rural context means
that they cannot always be well served by public transport. Consequently, whilst its availability will be taken
into account when considering the nature and scale of the proposal, the potential for certain diversification
proposals which can only be accessible by private car is acknowledged. Such proposals should have regard
to the sustainable transport hierarchy.
Observations:
• While diversification in rural areas is encouraged, the capacity for young families to live and work on
rural sites outside development limits is severely restricted, bordering on the impossible. This is
detrimental to the sustainability of village communities.
• Many farm diversification plans are thwarted at the outset due to their rural siting, thus falling
under the myriad restrictions on development in the open countryside.
• The perceived negative aspects of potential development outweigh the likely positive impacts on
community sustainability.
CONSIDERATIONS:
1. To provide for local families who wish to remain in or return to their community to live and
work in their rural area.
2. To examine the potential community benefit as a material consideration.
3. To provide more flexibility in the sources of income which contribute to a rural enterprise to
allow spouses, partners and their progeny to remain in or return to their family homesteads.
GENERAL - MOVING RURAL CARMARTHENSHIRE FORWARD – Report and Recommendations of the
Carmarthenshire Rural Affairs Task Group – June 2019:
3.2.4: “The Council is currently in the process of revising its Local Development Plan and the Task Group
feels there is a need to redress the current balance to enable appropriate and suitable development
within our rural towns and communities. This development needs to be taken forward based on local
need rather than national targets and regulations. There should of course be a thorough consideration
and understanding of the impact that any residential or business development may have on the nature
and construct of rural communities, especially in terms of its possible positive or negative impact on
the Welsh language, and the size of development should also be comparative to the existing
community, but suitable development in our rural communities needs to be enabled in order to ensure
the sustainability of our rural communities going forward.”
Observations:
• The Task Group has analysed and attempted to address and evidence the critical issues
referenced above. However, it is apparent that the Local Development Plan continues to be led
by national targets and regulations rather than by genuine local need.
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WALES RURAL OBSERVATORY - 2013:
The Experiences and Aspirations of Young People in Rural Wales (2013) Housing availability and
affordability - Young families’ experiences of the local housing market in the study areas also indicated
that the current planning system was considered too regulatory and rigid, and often hindered the
development of simple solutions to rural housing needs.
The Experiences and Aspirations of Young People in Rural Wales (2013): Access to the decisionmaking
process - There is growing awareness and interest among the public and policy-makers of the
important and critical role that young people play in forming and sustaining sustainable communities.
This is particularly crucial in terms of rural communities, where the ageing population trend is
particularly marked and where there has been a steady decline in the proportion of the younger
population. Despite this, young people are too often excluded from the decision-making process.
Observations:
• The conclusion of this study summarises the issues faced in our rural communities. Although this
study was published in 2013 there is no evidence that these conclusions are considered in the
development of planning policies.
SUMMARY OF CONSIDERATIONS IN RESPECT OF THE SECOND REVISED LOCAL DEVELOPMENT PLAN
1. The Plan looks at rural communities from the outside. There is no recognition of the living,
breathing, day-to-day rural village. The Plan needs to reverse its perspective.
2. The needs of real people are secondary to ideas, policies, regulations and planning
aspirations. The needs of rural families should be the primary consideration.
3. The projected image of the countryside takes priority over the people who live in it. The
people who create, enhance, protect and conserve this image should be heard.
4. Prohibiting development in many rural communities is contrary to the planning presumption
to permit reasonable development in other geographic or demographic areas. The planning
presumption should be applied consistently across all areas.
5. The Plan does not consider the needs of local people who do not fit the Local Needs criteria.
Young professionals – teachers, nurses - who are not first-time buyers do not qualify for
Affordable Housing but can’t afford open market houses in their rural villages. The Plan
should apply the needs of the community as a material consideration and provide for all
young families.
6. Ordinary circumstances in urban areas are considered exceptional in rural areas. The Plan
should not mitigate against rural families and young people.
7. The social and economic benefits of small rural businesses are outweighed by the
requirement to project a particular image of the countryside. Small rural businesses are part
of the culture and inheritance of the countryside and should be encouraged within the Plan.
8. The Plan provides for projected damage to the Welsh language and culture in future
developments. It does not provide for the development of the Welsh language and culture
in its existing strongholds. The Plan is reactive to Welsh-language issues, not proactive. The
rural policies within the Plan should emanate from the Welsh-language strongholds to
achieve CYMRAEG 2050.
9. The Plan prioritises the visitor economy over local needs in rural communities. The tourist,
throughout the year, may eat, sleep and breathe the open countryside, but the local
resident may not. The Plan should provide for parity of opportunity between all rural
enterprises.
10. Amended Planning Use Classes (2022) requires that planning permission is needed to change
a residential dwelling to a holiday/second home. It will take many years for this amendment
to impact on rural house prices and availablity. The Plan should consider applying flexibility
while these factors bring some equity to housing availability in rural areas.
11. Placemaking and Sustainable Places policies are imposed on rural villages. The policies
should be formulated from the inside outwards, not the outside inwards.
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12. Active Travel and other Carbon Net Zero requirements prohibit residential dwellings in rural
areas. The Plan excuses the visitor industry from similar carbon footprints. The Plan should
apply the same standards to residents and visitors alike and encourage both to work side by
side to reach targets.
13. The requirements for Rural Enterprise Dwellings are practically impossible to meet. This
does not conform with aspirations for sustainable rural communities. The requirements for
ALL residential dwellings across rural areas should be applied equally.
14. Any initiative inside or outside village development boundaries which could benefit local
residents is likely to be prohibited. Strengthening communities should be a material
consideration when assessing local initiatives.
15. Villages without settlement boundaries will not be able to accommodate the needs of their
own residents. The Plan must provide opportunities for such communities to flourish.
Rural villages are not Still Photographs.
They create, motivate, initiate, provide and support like any other community.
It is imperative that the Future Wales National Plan 2040 and the Carmarthenshire Local Development
Plan 2018 – 2033 acknowledge and respect the identity and function of our rural communities.
_______________________________________________________________________________________
Compiled and submitted by Plaid Cymru County Councillors, Cyngor Sir Gâr – April 2023
Cyng. Liam Bowen Cyng. Kim Broom
Cyng. Mansel Charles Cyng. Andrew Davies
Cyng. Bryan Davies Cyng. Ann Davies
Cyng. Glynog Davies Cyng. Handel Davies
Cyng. Karen Davies Cyng. Llinos Mai Davies
Cyng. Terry Davies Cyng. Arwel Davies
Cyng. Alex Evans Cyng. Colin Evans
Cyng. Hazel Evans Cyng. Linda Evans
Cyng. Tyssul Evans Cyng. Deian Harries
Cyng. Ken Howell Cyng. Peter Hughes Griffiths
Cyng. Meinir James Cyng. Gareth John
Cyng. Carys Jones Cyng. Betsan Jones
Cyng. Hefin Jones Cyng. Alun Lenny
Cyng. Jean Lewis Cyng. Neil Lewis
Cyng. Dai Nicholas Cyng. Aled Vaughan Owen
Cyng. Denise Owen Cyng. Dorian Phillips
Cyng. Darren Price Cyng. Emlyn Schiavone
Cyng. Russell Sparks Cyng. Dai Thomas
Cyng. Gareth Thomas Cyng. Elwyn Williams
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APPENDIX
Many elements of our planning system create complex dilemmas for Local Members and particularly for
Planning Committee Members when performing our roles and respecting our responsibilities:
• The role of the Local Member is to make the ward community a better place to live and work – to
improve quality of life and to develop and support plans which enhance and protect the
community, the environment and our future generations.
• The responsibility of the Local Planning Member is to observe the legislation, regulations and
guidance which are set down on our behalf to maintain Order within our communities, the Local
Authority and beyond.
The conflict between Members’ roles and Planning Members’ responsibilities gives rise to situations
where councillors are forced to compromise one in favour of the other. The Local Member is regularly
faced with two options:
• To support officers’ recommendations which are damaging to their own community in order to
conform with legislation, or
• To reject officers’ recommendations and act contrary to legislation in order to protect their
residents’ well-being.
It is not possible to reconcile this conflict under current planning policies.

Amend the Plan

Submitted on behalf of all Plaid Cymru Councillors on Carmarthenshire County Council – April 2023

SECOND REVISED LOCAL DEVELOPMENT PLAN 2018 - 2033
CYNGOR SIR GÂR
RESPONSE TO PUBLIC CONSULTATION March/April 2023
This document attempts to measure the aims of the LDP against the specific proposals as regards RURAL
DEVELOPMENT, SUSTAINABLE RURAL COMMUNITIES and the WELSH LANGUAGE.
It is compiled from the point of view of Local Members who attempt to build strong rural communities
within the limitations presented in the Local Development Plan and the the Planning environment.
Critical issues faced by rural communities at this time include:
• De-population – loss of young people, leading to loss of young families, leading to loss of
generation of children and further young people – a cycle which rural communities cannot control
nor influence;
• Altered demographic – increasing purchase and occupation of residential dwellings by older
couples or individuals, either retired or preparing for retirement, both local and from afar –
ultimately leading to “retirement villages”;
• Market forces – demand of older generations who have the means to purchase a rural lifestyle
pushing property prices beyond the reach of younger working families;
• Media marketing – “lifestyle” programming on TV and other media encouraging urban dwellers to
aspire to idyllic rural locations thus squeezing local lower earners from access to the local market;
• Tourism – economic considerations from the (sporadic) visitor industry is prioritised above the
economic contribution of (permanent) rural residential working families;
• Yr Iaith Gymraeg – Planning Statements placing the Welsh Language in a priority position while
Planning Policy failing to protect or develop Welsh Language rural strongholds;
• Community – traditional rural community structures breaking due to fragmented demographic,
contrasting cultures and consequential loss of cultural heritage;
• Community Services – lack of young families stepping into and running the voluntary community
services such as sports clubs, PTAs, Church/Chapel groups, social events etc.;
• The Family – breakdown of “family care cycle”. While young families are not living near their
parents, care of the elderly by the younger generation and childcare by the older generation
cannot be provided, resulting in isolation and additional pressures on Care Services.
• Local Culture – not necessarily being recognised or acknowledged by new demographic. Absence of
younger generation to inherit and exercise local culture and tradition resulting in their demise and
disappearance.
How can the LDP support ordinary people in ordinary rural communities to develop their economy,
language and culture?
TAN 6: 2.1.2 “Planning authorities should assess the needs and priorities of rural communities. They
should interrogate published sources of information such as the Wales Rural Observatory, and if
necessary commission research to identify rural economic and social conditions and needs.”
The Wales Rural Observatory ceased to exist in 2014. The most recent report on rural communities was
published in 2013. Many of the issues above were identified at that time:
“A common concern … was that disproportionately high housing prices, fuelled by demand for
commuting, second homes, holiday homes and retirement accommodation, was taking owner
occupation beyond the reach of many people resulting in young people and young families being
driven out of the communities where they worked or had grown up.”
Ten years later, however, these issues remain unaddressed in national and local policies.
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As recommended, Carmarthenshire County Council has commissioned its own research to identify rural
needs:
MOVING RURAL CARMARTHENSHIRE FORWARD – Report and Recommendations of the Carmarthenshire
Rural Affairs Task Group – June 2019:
“As a local authority we cannot directly influence decisions that are made in Cardiff, London and
Brussels but we can strongly urge our representatives to do whatever they can to safeguard the
future of rural Carmarthenshire and rural Wales. This is essential so that future generations can
live, work and spend their leisure time in communities where valued traditions can be maintained,
but are also resilient enough to adapt to an ever-changing social and economic landscape. This
report seeks to encapsulate that crucial balance between preservation and progression.”
There is a disconnect between the recommendations in the MOVING RURAL CARMARTHENSHIRE
FORWARD report – supporting the efforts of local people to maintain and develop rural communities –
and the inflexibility of the planning framework.
_____________________________________________________________________________________
OBSERVATIONS AND CONSIDERATIONS ON
SPECIFIC ASPECTS OF THE LDP
(A number of observations and considerations are common to more than one Strategic Policy)
LDP: HOM3 - Homes in Rural Villages
11.90 This part of the Plan's rural policy framework seeks to establish a flexible but controlled approach to
the delivery of new homes within those (Rural Villages) settlements. The Plan utilises a criteria-based
assessment to define small scale housing opportunities in rural villages and to meet the need for new
homes in rural parts of Carmarthenshire at a scale and at locations which maintain the essential character
of the countryside.
PPW Housing 4.2.1: Planning authorities must understand all aspects of the housing market in their
areas, which will include the requirement, supply and delivery of housing. This will allow planning
authorities to develop evidence-based market and affordable housing policies in their development
plans and make informed development management decisions that focus on the creation and
enhancement of Sustainable Places.
TAN 2.2.1: Many rural communities can accommodate development, particularly to meet local needs.
New development can help to generate wealth to support local services, ensuring that communities are
sustainable in the long term. A key question for the planning authority, when identifying sites in the
development plan or determining planning applications, is whether the proposed development
enhances or decreases the sustainability of the community. In particular, planning authorities should
support developments that would help to achieve a better balance between housing and employment,
encouraging people to live and work in the same locality.
Observations:
• The policies exert much control but very little flexibility within rural settlements.
• The “character of the countryside” is not defined in planning terms. It seems to refer to the
appearance of the countryside while it should, in fact, refer to all aspects of rural life. It is the
biodiversity, the nature, the traditions and, primarily, the local knowledge of the history and culture
of that part of the countryside which forms the character.
• If we lose the local residents then we lose that knowledge and protection.
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• The criteria-based assessment prioritises maintaining the character of the countryside above
maintaining a local community.
• The policies fail to recognise the contribution of the local community to maintaining the character of
the countryside through its knowledge, traditions and protective practices.
CONSIDERATIONS:
• To apply additional flexibility to policies for rural villages to allow the needs of the
community to be met.
• To acknowledge the role of village residents in the enhancement and protection of the
“character of the countryside”.
• To measure the contribution a development makes to the well-being of the community
as opposed to considering only the perceived potential harm.
• To assess and recognise the scale of development required in rural villages to secure their
future as community strongholds.
LDP: HOM3 - Guidance on Acceptable Plots
Infill sites within these rural villages will take priority over other locations;
Where appropriate, sites adjoining a rural village are also acceptable. Such sites will be required to adjoin
the boundary of one property which forms part of the rural village group. All proposals which adjoin a group
(as opposed to infill sites) will be required to demonstrate the following:
• there is an existing physical or visual feature which provides a boundary for the group -
reducing pressure for unacceptable ribbon development or rural sprawl;
• where such a feature does not exist, there should be potential for such a feature to be provided
so long as it is in character with the scale and appearance of the group;
• Proposals located in open fields adjoining a group, which have no physical features to provide
containment will not be considered acceptable.
Observations:
• While infill sites should take priority over other locations, this should not exclude other locations.
• These rigid limitations appear logical in theory, but they are not practical in many rural settlements.
• The limitations do not take into account variances in our local topography.
CONSIDERATIONS:
1. To consider further potential development capacity in and around rural villages.
2. To apply rounding-off of boundaries to include capacity which logically allows sensitive
development.
3. To evidence actual harm against the potential for community benefit in setting and
respecting development boundaries.
LDP: HOM3 - Housing within development limits
Proposals which exceed the 10% cap above the number of existing homes in the settlement, as at the LDP
base date, will not be permitted except where they conform to Policy AHOM1 in relation to the provision of
affordable homes.
Observations:
• A settlement of 100 houses may only grow by 10 homes during the life of the LDP.
• A hamlet of 10 homes may only grow by 1 home during the life of the LDP.
• The rigidity of the 10% cap is not sympathetic to the aspiration to build sustainable rural
communities.
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• While an exception is provided for Affordable Housing, the needs of a community may also include
market housing such as bungalows, “downsize” accommodation and dwellings to fit growing
families.
• If the linguistic and cultural vitality of rural villages is encouraged to grow from the inside, then rigid
caps are not appropriate.
CONSIDERATIONS:
1. To measure each application for a residential dwelling on its merits in the context of its
community, not only the context of development boundaries.
2. To assess the potential for development within or bordering the development limits in
the context of the particular settlement, and provide flexibility of boundaries where the
geography/topography does not allow expansion.
3. To provide for exceptions where affordable/local needs housing cannot be
accommodated within or bordering the development limits.
4. To consider the need for market housing to meet the needs of those who will not qualify
for Affordable Housing.
5. To remove the 10% cap above the number of existing homes in the settlement.
LDP: HOM4: Homes in Non-Defined Rural Settlements
Proposals for new single homes in settlements, hamlets and groups of dwellings which are not identified
under Strategic Policy SP3 will be permitted where they meet a local need for affordable housing and
conform to the following:
• It represents sensitive infill development of a small gap within an otherwise continuous built-up
frontage; or, is an appropriate rounding off of the development pattern;
• The development is of a scale that is consistent with the character of the area;
• The proposal will not result in an intrusive development in the landscape, and will not introduce a
fragmented development pattern;
• The size of the property reflects the specific need for an affordable dwelling in terms of the size of
the house and the number of bedrooms;
• That the occupancy of the dwelling is restricted both on first occupation and in perpetuity to those
who have a need for an affordable dwelling.
11.93 There are a notable number of small settlements or groups of dwellings throughout the County which
have not been defined within the settlement framework, and as such do not have development limits.
11.94 It is also noted that such provision needs to be delivered within the backdrop of a national agenda
centred on sustainability with placemaking at its heart. In this respect reference is made to the provisions of
PPW Ed.11 which requires that all residential development away from existing settlements or centres be
strictly controlled. The policy therefore in reflecting the provisions of national policy restricts local
affordable need dwellings in rural areas to established groups of dwellings.
PPW Strategic Placemaking 3.44: Consideration should be given to whether specific interventions from
the public and/or private sector, such as regeneration strategies or funding, are required to help deliver
the strategy and specific development proposals.
PPW Development in the Countryside 3.60: Development in the countryside should be located within
and adjoining those settlements where it can best be accommodated in terms of infrastructure, access,
habitat and landscape conservation. Infilling or minor extensions to existing settlements may be
acceptable, in particular where they meet a local need for affordable housing or it can be
demonstrated that the proposal will increase local economic activity. However, new building in the
open countryside away from existing settlements or areas allocated for development in development
plans must continue to be strictly controlled.
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PPW Housing Delivery 4.2.24: In the open countryside, away from established settlements recognised
in development plans or away from other areas allocated for development, the fact that a single house
on a particular site would be unobtrusive is not, by itself, a good argument in favour of permission;
such permissions could be granted too often, to the overall detriment of the character of an area.
11.95 Whilst the Revised LDP is supported by a robust evidence base it is acknowledged that details of
housing need changes over time. Affordable housing proposals will be required to submit evidence
demonstrating the specific local need and ensure that the proposal provides for the size, type and tenure of
houses required. Proposals to meet speculative local need application will not be considered, rather they
should relate to an identified need from individuals/families within the specific area.
11.96 Where available, local housing needs surveys should be utilised in providing this evidence.
Alternatively, other forms of evidence may be considered appropriate including Strategic Housing Market
Area Assessments and local needs/Lettings registers.
Observations:
• Each regulation is based on geography and existing development patterns. The “protection” of the
settlement image takes priority over the actual needs of local people.
• There is no provision at all for dwellings which are not Affordable Housing. Not all local people need
Affordable Housing, but they have Local Housing Needs for a variety of reasons.
• Small Settlements or Groups of Dwellings are common in our rural countryside. While needing to be
“controlled”, exceptions should be possible where there is evidenced local need.
• Such exceptions should not be limited to Affordable Housing as many mature members of the
community do not qualify. Older members of the community have a strong need to remain in their
community for reasons of health, mental health and social interaction.
• Box-ticking to qualify for Local Needs does not always allow local people to express their unique
needs or to argue their case outside the specific requirements.
• While Local Needs/Letting registers may confirm the needs of young families seeking housing, many
members of the community who have local needs are excluded from housing registers.
• Retiring local farmers or other rural workers will not qualify for Affordable Housing in their life-long
community. No provision is possible for families or individuals who need to stay within their support
network in Non-Defined Rural Settlements.
CONSIDERATIONS:
1. To prioritise the needs of the people and the community over the visual or conceptual image
of the settlement.
2. To use the actual housing needs of applicants to drive the policy, not devise a policy which
excludes the very housing needs it is intended to address.
3. To provide some capacity with the policy for those who do not qualify for Affordable
Housing but whose needs are equally important.
4. To define what “too often” means in granting permissions in the open countryside, and
consider the local needs of individuals above non-defined caps.
5. To consider the need within the community for young families, not only the need of a family
to live in a location.
6. To provide a needs-assessment which is not exclusively a “box-ticking” exercise.
7. To prioritise matching the needs of individuals with the needs of the community over
reducing numbers on Housing Registers.
LDP: AHOM2 - Affordable Housing - Exceptions Sites
Proposals for 100% affordable housing development on sites adjoining the Development Limits of defined
settlements (Tiers 1-3 in Policy SP3), will, in exceptional circumstances be permitted where it is to meet a
genuine identified local need (as defined within the Glossary of Terms) and where:
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• The site represents a logical extension to the development limits and is of a scale appropriate, and
in keeping with the character of the settlement;
• The benefits of the initial affordability will be retained for all subsequent occupants;
• It is of a size, scale and design compatible with an affordable dwelling and available to low or
moderate income groups;
• There are no market housing schemes within the settlement, or projected to be available which
include a requirement for affordable housing.
TAN 6: 2.2.4: They (planners) should also ensure that any sites identified for development are effectively
available and likely to be brought forward for development by the owner. This is particularly important in
smaller settlements, where a limited number of landowners may control land supply
TAN 2: 10.12: It is important that there is adequate housing provision in rural areas to meet the needs
of local people and to contribute to the delivery of sustainable communities. Development plans must
set out how planning at the local level will contribute to meeting identified rural affordable housing
needs.
TAN 2: 10.16 Local planning authorities must set out in their development plan their definition of ‘local
need’ for affordable housing in rural areas, within the overall aim of contributing to the delivery of
sustainable communities. This can include:
• existing households needing separate accommodation in the area;
• people whose work provides essential services and who need to live closer to the local
community;
• people with a family connection or long standing links with the local community; and
• people with a job offer in the locality who require affordable housing.
For some of these categories the area within which needs will be considered ‘local’ must also be
defined in the development plan. This may include:
• the village or group of villages;
• the community council area;
• an electoral ward or group of wards;
• the local authority area.
TAN 2: 10.14 Rural exception sites are not appropriate for market housing.
11.124 An affordable dwelling must be compatible with WG's Design Quality Requirement standards to limit its
size, scale and design to ensure that the dwelling falls within a reasonable and acceptable affordable dwelling
cost for future occupants. In exceptional circumstances, a departure from these standards may be considered
appropriate where they are to meet the occupant's needs and are clearly evidenced and justified.
Observations:
• Availability of land dictates the potential for Exception Sites.
• While Exception Sites provide the potential for Affordable Housing adjoining Local Development
boundaries, this may not be possible in many rural villages.
• The topography of our area does not always permit development outside existing settlements and
steep gradients make affordable construction unviable.
• Where land may be available, other factors may not meet requirements such as Highways, SAB
assessments etc. thus limiting the potential for development.
• Non-availability of land in and around Defined and Non-Defined Rural Settlements results in no housing
to meet local needs.
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• There are natural boundaries between communities which dictate social interaction. A nearby
community, across a river or motorway, may be more alien to a local individual than a town twenty
miles further afield.
• There is no provision at all for market housing in many rural settlements. If you don’t qualify for Local
Needs, or there is no Local Needs capacity in your community – you can’t live there.
• The size, scale and design of Affordable Housing cannot accommodate a growing family, especially
where children are not all of the same gender and vary in age.
• “Exceptional Circumstances” may not be so exceptional. Some quite ordinary circumstances exclude
local people from qualifying for Local Need.
• Young families wishing to return to their area to bring up their children and who have owned a
home in another area will not qualify for Affordable Housing, but cannot afford open market
housing.
• There is no guidance on what constitutes an “exception”. The policy accommodates nuclear families
with 2.4 children. There is no provision for Blended Families whose needs are more varied and
extensive.
CONSIDERATIONS:
1. To acknowledge that Exception Sites are at the discretion of local landowners, access/highways
restrictions, SAB requirements and other limiting factors.
2. Where no Exception Sites can be identified, to exercise flexibility in considering alternative sites
which may deviate from the current permitted sites.
3. Where particular individual “locality” needs are identified, to consider applications for nonaffordable
housing development in the interest of the individual, the family and the community.
4. To consider the definition of “local” in the context of the individual and the community rather
than by a radius of concentric miles.
5. To assess the needs of growing families when calculating the size, scale and design of Affordable
Housing in order to provide long-term security and a decent quality of life.
6. To acknowledge the housing aspirations of young families in rural areas as a material planning
consideration.
LDP: EME4 - Employment Proposals on Non-Allocated Sites
Proposals for employment development on non-allocated sites, but within the development limits of a
defined settlement will be permitted where:
• it is demonstrated that no other suitable existing or allocated employment sites or previously
developed land can reasonably accommodate the proposal;
• the development proposals are of an appropriate scale and form, and are not detrimental to the
respective character and appearance of the townscape/ landscape;
• The development is compatible with its location and with neighbouring uses.
Employment proposals outside the development limits of a defined settlement (Policy SP3) will be permitted
where:
• The proposal is directly related to a settlement or hamlet; or
• The proposal is supported by a business case which demonstrates that its location is justified; and
• The proposal is of an appropriate scale, size and design.
11.165 For proposals outside the development limits of a defined settlement, they must show that they are
directly related to a settlement or hamlet, or supported by a business case which justifies its location. The
Plan recognises that small-scale enterprises have a vital role to play in the rural economy and contribute to
both local and national competitiveness and prosperity. Many commercial and light manufacturing
activities can be appropriately located in rural areas without causing unacceptable disturbance or other
adverse effects. In this respect, the development of small businesses would address any local need for
employment accommodation.
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PPW: Welsh Government Planning Policy Wales – Edition 11 2021
PPW: The Rural Economy 5.6.4 To unlock the full potential of rural areas, planning authorities should
adopt a positive approach to employment arising from foundation and innovative and technology
based sectors, including research and development, in addition to employment arising from the
traditional agriculture, forestry and leisure sectors. Proposals for diversification, new startups and
micro-businesses should also be encouraged, where appropriate, to generate new job and wealthcreating
opportunities.
TAN 6: 2.2.2: Development plans should define local need taking into account the social, economic and
environmental characteristics of the area. Where possible existing definitions of local need,
for example affordable housing to meet local need, should be adopted, or if necessary modified
to include other land uses.
Observations:
• There is no connection provided between Employment on Non-allocated Sites and the needs of rural
villages to remain sustainable. Living and working within the community is vital to its existence.
• Some capacity has to be provided to acknowledge the place of small-scale businesses within rural
communities. There is no provision for small-scale commercial enterprises.
• The increase in home-working needs to be supported by flexibility across all genres of employment.
Additional space may be needed – inside and outside development limits – to accommodate future
working practices.
• This will be mitigated by reduction in travel and healthier work-life balances, thus meeting the aims
of our well-being goals.
CONSIDERATIONS:
1. To apply flexibility in meeting the needs of local people to work within their community.
2. To provide working spaces which accommodate local employment in areas outside or
without development limits.
3. To encourage satellite working as and when technology permits during the lifetime of the
LDP.
LDP: SP 8 - Welsh Language and Culture
The Plan supports development proposals which safeguard, promote and enhance the interests of the
Welsh language and culture in the County. Development proposals which have a detrimental impact on the
vitality and viability of the Welsh language and culture will not be permitted unless the impact can be
mitigated. All development proposals subject to WL1, will be expected to identify measures which enhance
the interests of the Welsh language and culture.
11.174 The Plan seeks to 'promote the Welsh language and culture'[59] and is committed to contributing to
the Welsh Government's long-term aim of achieving 1 million Welsh speakers by 2050[60]. To deliver on this
aim, the Council will support, promote, and enhance the Welsh language as a viable community language
by ensuring that there are sufficient and proportionate employment and housing opportunities to sustain
both the rural and urban communities in the County and by implementing an effective monitoring
framework. In doing so, the Plan seeks to ensure that the local population have the opportunity to remain in
Carmarthenshire rather than leave in search of work opportunities and housing, as well as the opportunity
to return. Through aiming for sustainable growth, the Plan will also maximise opportunities for non-Welsh
speakers who move to the County to be integrated into community life at a scale and pace that will not
undermine the vitality and viability of the Welsh language and culture.
11.177 The Plan also seeks to safeguard, promote, and enhance the Welsh language in Carmarthenshire
through other relevant policy objectives, namely through the provision of housing and affordable housing,
promoting a vibrant economy and employment opportunities and the provision and retention of community
facilities, amongst others.
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TAN 20: 1.4.8 Section 70(2) of the Town and Country Planning Act 1992 (TCPA) clarifies that
considerations relating to the use of the Welsh language may be taken into account when determining
applications for planning permission, so far as they are material to the application. This may apply to
any application in any part of Wales. This provision does not give any additional weight to the Welsh
language above any other material consideration.
LDP: WL1 - Welsh Language and New Developments
All development proposals throughout Carmarthenshire will be required to safeguard, promote and
enhance the Welsh language … Proposals which do not accord with the Plan's housing trajectory will be
required to provide a phasing plan outlining the timescales for delivering the homes proposed on the site
and demonstrate that they would not have a negative impact upon the Welsh language which cannot be
mitigated.
11.178 The Welsh Language Action Plan sets out the measures to be taken to safeguard, promote and
enhance the Welsh language. The Welsh Language Action Plan should also outline how the development
proposes to make a positive contribution towards the community's Welsh language groups. This could,
amongst others, include providing support and funding towards organisations and bodies that provide
activities, facilities and education for Welsh speakers and learners, and support and funding towards Welsh
language classes. Welsh Language Impact Assessments (WLIA) will be required to outline the anticipated
impacts of the proposed development upon the Welsh language in the County. The Welsh Language
Supplementary Planning Guidance[61] provides further guidance on when a WLIA is required, clarifying
what constitutes a large scale development, as well as how to produce a WLIA.
11.182 The ISA of the LDP is required to assess the likely effects of the LDP upon the Welsh language. This is
done iteratively at key stages throughout the Plan's production. The likely anticipated effects are presented
in the ISA report, and further information is available within the LDP's evidence base.
TAN 20: 3.3.2 Evidence from the language impact assessment may be material to the application and
may inform whether measures to mitigate or enhance the impacts of the development on the use of
the Welsh language should be applied.
Welsh Language County Strategic Forum: “Language planning work within the LDP process, particularly
the development of a new methodology to measure the impact of land use on the Welsh language” notes
a “Lack of national guidance and dependable information on the impact of construction on the Welsh
language in terms of numbers of permitted locations for house building and their geographical locations.”
Carmarthenshire Welsh Language Promotion Strategy 2023 – 2028: p.7 Despite the positive contribution
of all the above policies, a number of factors that most adversely affect the Welsh language in
Carmarthenshire remain outside their scope. The affordability of housing for local young people for
example is largely influenced by the open market and private sector profits. The same is true with regard
to the influx of older people from outside Wales into Welsh-speaking communities. After the first
Strategy's efforts to work with estate agents to try to gain useful information to address this problem, it
must be recognised that it is only Welsh Government who are in a position to meaningfully influence these
factors. We look forward to working together on innovative efforts by the government in this area of work
and to explore new law-making forces that could mitigate harmful effects on the Welsh language.
Welsh Government: CYMRAEG 2050: a Million Welsh Speakers: Development and the Welsh language -
p.63: The land use planning system should contribute to the vitality of the Welsh language by creating
suitable conditions for thriving, sustainable communities, supported by an awareness of the relevant
principles of language planning. Decisions regarding the type, scale and exact location of developments
within a specific community has the potential to have an effect on language use, and as a result on the
sustainability and vitality of the language. This calls for strengthening the relationship between language
planning and land use planning.
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Cyngor Sir Gâr: Notice of Motion 10.7.2019 (unanimously supported): “This council believes that the
whole of Carmarthenshire is an ‘area of linguistic sensitivity and significance’ and that the planning system
has a crucial role to play in supporting the Welsh language across the county. To this end, we believe that
the language should be a Material Planning Consideration in all applications for the development of five or
more houses in rural areas and ten or more in urban areas in every community, irrespective of the
percentage of Welsh speakers.
Observations:
• Cyngor Sir Gâr’s Notice of Motion identifies the whole county as an area of linguistic sensitivity and
as such should be recognised as a positive material consideration in rural areas.
• In reality, the Plan does not acknowledge the importance of small rural communities in its
safeguarding and enhancement of the Welsh Language. Many of our rural villages are the
strongholds of first-language Welsh-speakers and form the foundation of Welsh language and
culture throughout the county. Welsh speakers are concentrated in these areas, but the ability of
young families to live and work within these communities is limited by the Plan and other regulatory
factors.
• The Plan addresses two aspects of Welsh-language safeguarding:
a) It requires assessments on the impact of developments on the Welsh language;
b) It provides for activities, facilities and education which promote the Welsh language;
• The Plan does not provide for sensitive development within the small community strongholds of the
language. Welsh-speakers who cannot build or buy within their villages, or in the surrounding areas,
cannot support the language in their native communities.
• Local people may have access to land which would reduce costs and make the building of their own
home viable. Proportionate development on private land should be made possible where
appropriate.
• Rural Welsh-language villages need proactive policies to offer accommodation in the community –
both to young families in need of Affordable Housing and to those requiring market housing.
• Assessments of the likely effects of the LDP on the Welsh language will depend on the detail
available and be data-led.
• Pre-planning Welsh-language Assessments are appropriate for larger developments in service
centres and towns, however, external assessments do not evidence the actual prosperity of the
language in small villages and communities.
• Welsh-language impact assessments are commissioned by the applicant and may not always be
independent.
• A reversal of thought is required so that the needs of the Welsh language influences the LDP rather
than the LDP attempting to react to perceived needs.
• The data on Welsh-speakers in Carmarthenshire has not yet been based on the 2021 Census and is
out of date.
• There is very little planning guidance attached to the Welsh Government policy to achieve one million
Welsh speakers by 2050.
• While the CYMRAEG 2050 policy calls for strengthening the relationship between language planning and
land use planning, Welsh Government’s own planning policies make this impossible.
CONSIDERATIONS:
1. To recognise the Linguistic Sensitivity of the whole county and the potential of rural
communities to increase the number of Welsh-speakers if supported proactively through the
LDP.
2. To move from assessing impact to providing positive measures to develop Welsh-language
strongholds.
3. To acknowledge that strict controls on market housing in rural areas harms Welsh-language
communities.
4. Where development is evidenced through local need, to balance the potential visual harm to
rural areas against the potential benefit to language and culture.
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5. To provide a body to conduct Welsh-language impact assessments which is independent of
the applicant and the Local Planning Authority.
6. To re-assess Welsh-language impact policies as soon as the 2021 Census data is available.
7. To recognise the need for Welsh Government to explore new approaches to planning in
rural areas in order to enable local Welsh Language Strategies to be implemented and to
enable CYMRAEG 2050 to be a realistic possibility.
LDP: SP11 - The Visitor Economy: Respecting the County's social, economic and environmental fabric.
11.234 All parts of the County possess qualities that contribute to the overall sense of place. These include
landscape, nature conservation, social fabric and built environment. These are assets which must be
protected for our future generations and cannot be unduly compromised by tourism related development.
11.235 There should also be an emphasis on providing quality in all aspects of a proposal. In considering the
acceptability of proposals, consideration will be given to location, siting, design and scale, access to the
primary and core highway network and the impact of any resultant traffic generation. Furthermore, the
extent to which the site is serviceable by public transport, walking and cycling are important considerations.
Proposals should reflect the character and appearance of the area with appropriate landscaping and
screening utilised as required.
11.239 The County's rural areas are well placed to accommodate proposals for high quality and sustainable
proposals that are of an appropriate scale. Proposals should respect the County's assets whilst supporting
vibrant rural communities.
11.240 Some tourism related developments, by their very nature, must be located in the countryside. It is
important that these developments do not have any significant negative impact on the landscape, natural
environment, or amenity. In terms of the detailed policies for the Revised LDP, the emphasis is on providing
clarification on the two notable challenges and opportunities facing the visitor economy in Carmarthenshire
which are attractions (somewhere to go) and accommodation (somewhere to stay).
LDP: VE2 - Holiday Accommodation
Proposals for high quality serviced accommodation, including appropriate extensions to existing
accommodation, will be permitted where they are located within, or directly related to a defined settlement
(Policy SP3).
Proposals for serviced and self-catering accommodation that are located outside of the above locations will
only be permitted where they consist of the re-use and adaptation (including conversion) of existing
buildings in conjunction with policy RD4.
All proposals set out above should reflect and respect the role and function and sense of place of the area,
most notably in terms of scale, type, character, design, layout and appearance - as well as those uses
already located in the vicinity of the site.
11.247 Where planning permission is given for permanent holiday accommodation, the Council will
consider the attachment of conditions restricting the use to holiday accommodation only. Seasonal
occupancy conditions may also be used to prevent the permanent residential occupation of such
accommodation. In addition, in areas where the prevalence of second homes and holiday homes are known
to be a serious issue within communities, the Council will consider placing restrictions upon permitted
development rights to change existing dwellings to holiday homes and second homes.
LDP: VE4 - Static Caravan and Chalet Sites and Permanent Alternative Camping Accommodation:
Proposals for new Static Caravan and Chalet Sites will be permitted where:
• they are within or directly related to a defined settlement (Policy SP3), or, they are located or
demonstrate a spatial and functional relationship with a relevant existing tourism facility or
attraction;
• they are of high quality in terms of design, layout and appearance, and will not have an
unacceptable adverse effect upon the surrounding landscape and/or townscape;
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• they will not lead to a significant and unacceptable intensification in the provision of sites in the
locality;
Proposals for the enhancement and extension of existing sites will be permitted where:
• it will increase the vitality, sustainability and environmental quality of the site;
• it will not result in an unacceptable increase in the density of units and/or the overall scale of the
site.
• it will not have an unacceptable harm on the surrounding landscape, seascape and / or townscape;
• it provides (where appropriate) for the significant improvement of the overall quality, appearance
and setting of the site.
11.256 This policy recognises that appropriate high-quality proposals should be supported. This recognises
the need to provide a diverse accommodation offer in terms of providing a range and choice of places to
stay within the County.
TAN13: TOURISM – Published in 1997, this document is woefully inadequate to address the needs of
accommodating visitors in 2023 and the future.
Observations:
• “The County’s rural areas are well placed to accommodate proposals for high quality and
sustainable proposals that are of an appropriate scale” suggests that tourism developments take
priority over residential developments. Nowhere does the Plan refer to residential development
located in the countryside in such positive terms, but tourism is accommodated with flexibility.
• The re-use and adaptation (including conversion) of existing buildings outside a settlement is
permitted for visitor accommodation but not for housing for local people.
• No evidence is provided to illustrate why holiday accommodation is considered to have less impact
on the countryside than residential dwellings. This in no way suggests that there be should be
competition between both uses, but it is not clear how holiday accommodation makes a greater
contribution to sustainable communities than housing for local people.
• A “spatial and functional relationship with a relevant existing tourism facility or attraction” includes
the open countryside. If static Caravans and Glamping Pods are of a scale, layout and design
appropriate to the setting, and if properly screened, such developments provide diversification
income to rural areas while providing much needed visitor accommodation.
• The rigidity of travel planning restrictions where public transport is not readily available bars much
unintrusive development.
• While Static Caravan, Chalet and Glamping Pod Sites in rural areas are subject to rigid planning
regulation, the ownership and use of these units as second homes prevents the purchase of
residential family dwellings for holiday purposes. This helps protect traditional rural homes from
second home use, while purchasing a chalet on a park is far less costly as a second home than
purchasing a house.
CONSIDERATIONS:
1. To question if the visitor economy is prioritised over local needs, and consider both
community benefits on equal terms.
2. In light of the recent policy on Second Homes/Holiday Homes Council Tax Premium, to
consider permitting residential use of existing holiday accommodation in the open
countryside which may no longer remain viable.
3. To recognise that small, well-designed accommodation sites in the open countryside provide
diversification opportunities to farming communities and contribute to the local economy.
4. To encourage well-sited Static Caravan, Chalet and Glamping Pod Sites in areas heavily
affected by second home use as an attractive option to potential second home purchasers.
5. To provide a balance of residential and tourism accommodation in rural areas to encourage
mutual support between communities and visitor economy.
6. To replace TAN13 with guidance which is appropriate and relevant to the life of the Plan.
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LDP: SP 12 - Placemaking and Sustainable Places
11.269 The Act means that public bodies such as local authorities must work to ensure that developments
should acknowledge and seek to improve the economic, social, environmental, and cultural well-being of an
area.
Observations:
• With regards to social and cultural well-being, there is no provision for placing small rural
communities at the centre of policy, or for building the policies around the needs of village
communities.
CONSIDERATIONS:
1. To recognise the place of small communities in achieving the aims of the Well-being and
Future Generations Act.
2. To allow rural communities to improve and grow on a par with urban communities.
LDP: SP 13 - Rural Development
11.366 The rural settlements of the County have an important role to play in improving the sustainability of
the wider geographical area in which they are located as well as the County's overall sustainability. The
Plan's strategy and settlement hierarchy reflects the significant role which the rural communities play
through supporting growth of a proportionate scale which can make a positive contribution towards the
long-term sustainability of the rural economy and rural communities.
11.367 Proportionate and sensitive development can provide the level of growth required to retain and
enhance the services and facilities provided in the County's rural settlements. It can also serve to safeguard
and promote the Welsh language in rural areas and enhance rural employment opportunities. However, the
Plan seeks to ensure that development and growth does not have negative impacts upon a community's
sustainability. Key to this is ensuring that development is not permitted at a scale or rate which would affect
the community's ability to absorb and adapt to growth and change. This is imperative when considering the
impacts which development can have upon the local infrastructure, the vitality of the Welsh language and
the sustainability of the countryside and natural environment.
11.368 National planning policy has historically sought to restrict unnecessary development in countryside
locations, principally to prevent sporadic and unsustainable growth and to maximise use of infrastructure,
resources and services more commonly available in established urban areas.
11.369 Whilst this principle remains relevant and applicable, there is an enhanced recognition of the
countryside as a place of work, as a home for many, a place to visit for others and a vital ecosystem for
everyone. The Plan is committed to addressing and safeguarding the needs of rural communities. To this
end, the Council established a Rural Affairs Task Group with the aim of assessing the needs of rural
communities and taking positive steps to address these. This Plan supports the aims and outcomes from the
Task Group principally through policies relating to the provision of housing and affordable housing; the
economy and employment; the Welsh language, and the natural environment. Development proposals will
need to demonstrate that they accord with these policies as well as the provisions of national planning
policy.
PPW: Placemaking in Rural Areas 3.38: The countryside is a dynamic and multi-purpose resource. In
line with sustainable development and the national planning principles and in contributing towards
placemaking outcomes, it must be conserved and, where possible, enhanced for the sake of its
ecological, geological, physiographic, historical, archaeological, cultural and agricultural value and for
its landscape and natural resources. The need to conserve these attributes should be balanced against
the economic, social and recreational needs of local communities and visitors. Fostering adaptability
and resilience will be a key aim for rural places in the face of the considerable challenge of maintaining
the vibrancy of communities and availability of services as well as contributing to the Cohesive
Communities well-being goal.
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11.373 This understanding of diversity is reflected within PPW in its consideration of sustainable transport
requirements. It recognises there is a need to reflect different approaches to sustainable transport in
defining growth within rural settlements.
TAN 6: 2.2.3 Where development proposals are intended to meet local needs, planning authorities
should recognise that a site may be acceptable even though it may not be accessible other than by the
private car. Development not intended to cater primarily for local needs should continue to be located
in market towns, local service centres or clusters of smaller settlements where a sustainable functional
linkage can be demonstrated and which are accessible by public transport.
Observations:
• “The Plan is committed to addressing and safeguarding the needs of rural communities” - the Plan
does not address the needs of rural communities.
• The Rural Affairs Task Group states that:
“There is of course a recognition of the need for sensitive consideration of a number of factors
when looking at development in rural areas but the Task Group feels that current planning
policy from Welsh Government does not give enough flexibility to enable development, based
on local need, in our most rural communities.”
• While the preservation of the countryside is important, the policy “moth-balls” rural villages as
static entities and “enhances” them by keeping them attractive to visit and view. The policies invite
people to observe the attractive characteristics – culture, tradition, Welsh-language without
attempting to develop these characteristics and make them sustainable.
• Sustainable transport policies are limiting the development of rural housing while they encourage
extending the development of holiday accommodation. The travel footprint of weekly visitors to
and around rural areas is not measured against the travel footprint of weekly activities of local
residents.
CONSIDERATIONS:
1. To place rural communities at the heart of the Strategic Policy.
2. To provide “…enough flexibility to enable development, based on local need, in our most
rural communities”.
3. To define “enhancement” in material terms as regards sustaining and developing the
language, culture and heritage of our rural areas.
LDP: Rural Enterprise Dwellings
11.379 As noted through national policy, a rural enterprise dwelling is required where it 'is to enable rural
enterprise workers to live at or close to their place of work'. This includes encouraging younger people to
manage farm businesses and supporting the diversification of established farms.
11.380 It is not the role or the intention of the Revised LDP to replicate the provisions of national planning
policy. Consequently, reference should be had to the provisions of PPW and Technical Advice Note 6 (TAN6)
in the determination of applications for new rural enterprise dwellings. National policy clearly states that
such proposals should be carefully examined to ensure that there is a genuine need.
11.381 Applications for rural enterprise dwellings should be accompanied by a rural enterprise dwelling
appraisal, with permission only granted where it provides conclusive evidence of the need for the dwelling.
TAN 6: 4.1.1 The Assembly Government’s vision for housing is for everyone in Wales to have the
opportunity to live in good quality, affordable housing, to be able to choose where they live and decide
whether buying or renting is best for them and their families. This vision is applicable to both urban
and rural areas.
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Observations:
• The bar for proving “conclusive evidence of the need for the dwelling” is uniquely high for Rural
Enterprise Dwellings in comparison with other housing categories. The amount of necessary
evidence and the years required to compile data makes such applications prohibitive.
• TAN6: 4.1.1 contradicts the lengthy and detailed restrictions placed on individuals and families
attempting to remain in their local community.
• The need to live near a rural enterprise should not be assessed on the employment needs of the
enterprise alone. Families support rural enterprises in many other ways, not only through their
employment on the site.
• Families in alternative fields of employment who have strong ties to the site should be encouraged
to remain within their traditional and cultural setting.
CONSIDERATIONS:
1. To bring the requirements of Rural Enterprise Dwellings in line with the requirements of
all other housing requirements – including urban housing and One Planet Development
housing.
2. To apply the same test of need for a rural enterprise dwelling as that for a dwelling on a
One Planet site.
3. To recognise the potential contribution of Rural Enterprise Dwellings to the sustainability
of language, culture and heritage.
4. To acknowledge that creating an additional dwelling on a rural enterprise site supports
the business and family whether or not the residents are in the employment of the
enterprise.
LDP: RD2 - Conversion and Re-Use of Rural Buildings for Residential Use
Proposals for the conversion and re-use of suitable rural buildings for residential use will be permitted
where:
• the existing use has ceased, and its re-use would not result in the need for an additional
building;
• the design and materials are of a high quality, and the form and bulk of the proposal, including
any extensions, curtilage and access arrangements are sympathetic to and respect: the
surrounding landscape, rural character of the area and the appearance of the original building;
• Proposals for extensions should be proportionate and reflective of the scale, character and
appearance of the original building;
• the original building is structurally sound and any rebuilding works, necessitated by poor
structural conditions and/ or the need for new openings in walls, do not involve substantial
reconstruction;
• where applicable, the architectural quality, character and appearance of the building is
safeguarded and its setting not unacceptably harmed.
TAN 6: 3.6.1 Whilst residential conversions have a minimal impact on the rural economy,
conversions for holiday use can contribute more and may reduce pressure to use other houses in the
area for holiday use.
Observations:
• While RD2 permits the conversion of suitable rural buildings for residential use, the majority of
these buildings lie outside the development limits of rural villages and therefore cannot be
permitted as residential dwellings.
• This excludes a number of surplus farm buildings from being converted to homes for young local
families, although they can be converted for holiday use.
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• It is asserted that residential conversions for holiday use can contribute more to the local economy.
Is there evidence that holiday accommodation contributes more to the local economy than
residential families? This statement does not consider factors such as holiday accommodation being
owned by individuals well outside the “local economy” and where the income goes directly out of
the local area, county or country.
• It does not consider the contribution a residential family makes to the local economy on a daily,
weekly and annual basis. A data-based study would provide evidence of this assertion.
CONSIDERATIONS:
1. To apply the same impact measurements of conversion to holiday cottages/barns on the
open countryside as to conversion to residential cottages/barns in the open countryside.
2. To provide evidence of the carbon footprint benefit of tourist against that of residents.
3. To permit re-use/conversion of surplus rural buildings for residential use side by side
with holiday use.
LDP: HOM7 - Renovation of Derelict or Abandoned Dwellings:
Proposals for the renovation of derelict or abandoned dwellings outside the Development Limits of a
defined settlement (Policy SP3) will be permitted where:
• It can be demonstrated that a significant part of the original structure is physically sound and
substantially intact requiring only a limited amount of structural remedial works;
• The building demonstrates and retains sufficient quality of architectural features and traditional
materials with no significant loss of the character and integrity of the original structure;
• There are no adverse effects on the setting or integrity of the historic environment.
11.104 The renovation of abandoned dwellings can make a small but important contribution to the needs of
an area. The architectural value of a number of derelict or abandoned dwellings often reflects the
traditional vernacular and should be recognised in the submission of such proposals. Extensions, access
requirements or other aspects associated with the proposal should be sympathetic to the character of the
original building and the landscape. Proposals which seek to make a positive contribution to the landscape
qualities of the area will be encouraged.
Observations:
• There is very little policy detail or guidance on the re-use of derelict dwellings or ruins to provide
homes for local families. The guidance for derelict dwellings is arbitrary and open to interpretation.
• Sir Gâr no longer has a “tradional vernacular” style of dwelling. Most modern houses have for
decades been built with breeze blocks. It is reasonable that farm buildings constructed from such
materials, possibly with re-facing, should be considered for adaptation as dwellings.
• As part of the Levelling Up strategy, the UK Government has consulted on the “Right to Regenerate”
bill which promises to re-use derelict buildings in public ownership, but not in private ownership.
• Farming unions are encouraging rural owners not to allow their property to fall into the
“Abandonment” category which will require full planning permission for re-instatement as a
residential dwelling.
CONSIDERATIONS:
1. To acknowledge the historic use of a derelict/abandoned dwelling in the open countryside in
order to return it to its traditional residential use.
2. In 2023, to recognise the reality of the nature of the construction of many 20th Century rural
buildings and consider their sensitive re-use as dwellings.
3. To encourage proposals which seek to make a positive contribution to the landscape
qualities of the area.
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RE-USE OF PLACES OF WORSHIP
11.450 Many elements of the County's built and historic environment are protected through legislation or
other policy provisions, and as such do not require policies in the revised LDP. The Plan does not therefore
include policies in relation to facets of the built heritage such as Scheduled Monuments as they are
adequately protected elsewhere.
TAN24: Historic Assets of Special Local Interest - 8.1 - Historic assets that the local planning authority
may consider to be of special local interest are not accompanied by any additional consent
requirements over and above those required for planning permission. However, if such assets are to
contribute successfully to the conservation or enhancement of local character their status needs to be
clear in the development management process. If a local planning authority chooses to identify historic
assets of special local interest, it must include policies for their preservation and enhancement in the
local development plan.
Managing Change to Listed Places of Worship in Wales – Welsh Government: 5.13 Closed or Closing
Places of Worship: Listed places of worship may have a continuing and valuable contribution to make
to the community even when they are no longer required for worship. Before they cease to be used for
worship, it is important that there is no unnecessary delay in finding alternative uses compatible with
the significance of the fabric, interior, contents and setting of the building.
CADW - Historic Assets Of Special Local Interest: Local planning authorities may choose to identify
historic assets of special local interest - known as ‘local listing’ … Local listing is important because it
provides the base for local planning authorities to develop policies for their protection and
enhancement. This means that local planning authorities can manage change through the planning
system so that local historic assets continue to contribute to the vitality of the area … Local listing also
provides an opportunity for a community to get involved in the identification of historic assets of
special local interest and in caring for them appropriately.
Observations:
• There is very little guidance on the functional re-use of chapels and churches in rural communities
apart from their historic surroundings and facades.
• Many church and chapel buildings in rural areas are converted for holiday/second home use. This is
not consistent with the interests of “local listing” to preserve the contextual integrity of the
community asset.
CONSIDERATIONS:
1. To acknowledge that the LDP could include measures to assess, secure and re-use closed
Places of Worship for the benefit of the community.
2. To encourage conversations between representatives of closing Places of Worship, planners
and the community before disposal of the asset.
3. To consider placing covenants on Chapels and Churches being converted to dwellings to
ensure they are permanent residential dwellings rather than second homes in order to
protect the historic integrity of the building for the future.
4. To require that CADW exercises flexibility in its approach to the re-use of local historic assets
so that they remain of value and interest to the community.
LDP: RD3 - Farm Diversification
Proposals for farm diversification developments which strengthen the rural economy will be permitted
where:
• It is compatible with, complements and supports the principal agricultural activities of the existing
working farm;
• It is of a scale and nature appropriate to the existing farm operation;
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• It has appropriate regard to the highways and transport infrastructure;
• It would not have an adverse impact on the character, setting and appearance of the area and the
surrounding landscape.
11.393 Diversification in rural areas can often add to the income streams and economic viability of farms,
strengthen the rural economy, and add to wider employment opportunities.
11.394 Farm diversification proposals are intended to supplement and support the continuation of the
existing farming activity. Proposals should be accompanied by evidence detailing a justification for the use
and its relationship with the existing farming activity.
11.396 In considering proposals for farm diversification it is acknowledged that their rural context means
that they cannot always be well served by public transport. Consequently, whilst its availability will be taken
into account when considering the nature and scale of the proposal, the potential for certain diversification
proposals which can only be accessible by private car is acknowledged. Such proposals should have regard
to the sustainable transport hierarchy.
Observations:
• While diversification in rural areas is encouraged, the capacity for young families to live and work on
rural sites outside development limits is severely restricted, bordering on the impossible. This is
detrimental to the sustainability of village communities.
• Many farm diversification plans are thwarted at the outset due to their rural siting, thus falling
under the myriad restrictions on development in the open countryside.
• The perceived negative aspects of potential development outweigh the likely positive impacts on
community sustainability.
CONSIDERATIONS:
1. To provide for local families who wish to remain in or return to their community to live and
work in their rural area.
2. To examine the potential community benefit as a material consideration.
3. To provide more flexibility in the sources of income which contribute to a rural enterprise to
allow spouses, partners and their progeny to remain in or return to their family homesteads.
GENERAL - MOVING RURAL CARMARTHENSHIRE FORWARD – Report and Recommendations of the
Carmarthenshire Rural Affairs Task Group – June 2019:
3.2.4: “The Council is currently in the process of revising its Local Development Plan and the Task Group
feels there is a need to redress the current balance to enable appropriate and suitable development
within our rural towns and communities. This development needs to be taken forward based on local
need rather than national targets and regulations. There should of course be a thorough consideration
and understanding of the impact that any residential or business development may have on the nature
and construct of rural communities, especially in terms of its possible positive or negative impact on
the Welsh language, and the size of development should also be comparative to the existing
community, but suitable development in our rural communities needs to be enabled in order to ensure
the sustainability of our rural communities going forward.”
Observations:
• The Task Group has analysed and attempted to address and evidence the critical issues
referenced above. However, it is apparent that the Local Development Plan continues to be led
by national targets and regulations rather than by genuine local need.
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WALES RURAL OBSERVATORY - 2013:
The Experiences and Aspirations of Young People in Rural Wales (2013) Housing availability and
affordability - Young families’ experiences of the local housing market in the study areas also indicated
that the current planning system was considered too regulatory and rigid, and often hindered the
development of simple solutions to rural housing needs.
The Experiences and Aspirations of Young People in Rural Wales (2013): Access to the decisionmaking
process - There is growing awareness and interest among the public and policy-makers of the
important and critical role that young people play in forming and sustaining sustainable communities.
This is particularly crucial in terms of rural communities, where the ageing population trend is
particularly marked and where there has been a steady decline in the proportion of the younger
population. Despite this, young people are too often excluded from the decision-making process.
Observations:
• The conclusion of this study summarises the issues faced in our rural communities. Although this
study was published in 2013 there is no evidence that these conclusions are considered in the
development of planning policies.
SUMMARY OF CONSIDERATIONS IN RESPECT OF THE SECOND REVISED LOCAL DEVELOPMENT PLAN
1. The Plan looks at rural communities from the outside. There is no recognition of the living,
breathing, day-to-day rural village. The Plan needs to reverse its perspective.
2. The needs of real people are secondary to ideas, policies, regulations and planning
aspirations. The needs of rural families should be the primary consideration.
3. The projected image of the countryside takes priority over the people who live in it. The
people who create, enhance, protect and conserve this image should be heard.
4. Prohibiting development in many rural communities is contrary to the planning presumption
to permit reasonable development in other geographic or demographic areas. The planning
presumption should be applied consistently across all areas.
5. The Plan does not consider the needs of local people who do not fit the Local Needs criteria.
Young professionals – teachers, nurses - who are not first-time buyers do not qualify for
Affordable Housing but can’t afford open market houses in their rural villages. The Plan
should apply the needs of the community as a material consideration and provide for all
young families.
6. Ordinary circumstances in urban areas are considered exceptional in rural areas. The Plan
should not mitigate against rural families and young people.
7. The social and economic benefits of small rural businesses are outweighed by the
requirement to project a particular image of the countryside. Small rural businesses are part
of the culture and inheritance of the countryside and should be encouraged within the Plan.
8. The Plan provides for projected damage to the Welsh language and culture in future
developments. It does not provide for the development of the Welsh language and culture
in its existing strongholds. The Plan is reactive to Welsh-language issues, not proactive. The
rural policies within the Plan should emanate from the Welsh-language strongholds to
achieve CYMRAEG 2050.
9. The Plan prioritises the visitor economy over local needs in rural communities. The tourist,
throughout the year, may eat, sleep and breathe the open countryside, but the local
resident may not. The Plan should provide for parity of opportunity between all rural
enterprises.
10. Amended Planning Use Classes (2022) requires that planning permission is needed to change
a residential dwelling to a holiday/second home. It will take many years for this amendment
to impact on rural house prices and availablity. The Plan should consider applying flexibility
while these factors bring some equity to housing availability in rural areas.
11. Placemaking and Sustainable Places policies are imposed on rural villages. The policies
should be formulated from the inside outwards, not the outside inwards.
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12. Active Travel and other Carbon Net Zero requirements prohibit residential dwellings in rural
areas. The Plan excuses the visitor industry from similar carbon footprints. The Plan should
apply the same standards to residents and visitors alike and encourage both to work side by
side to reach targets.
13. The requirements for Rural Enterprise Dwellings are practically impossible to meet. This
does not conform with aspirations for sustainable rural communities. The requirements for
ALL residential dwellings across rural areas should be applied equally.
14. Any initiative inside or outside village development boundaries which could benefit local
residents is likely to be prohibited. Strengthening communities should be a material
consideration when assessing local initiatives.
15. Villages without settlement boundaries will not be able to accommodate the needs of their
own residents. The Plan must provide opportunities for such communities to flourish.
Rural villages are not Still Photographs.
They create, motivate, initiate, provide and support like any other community.
It is imperative that the Future Wales National Plan 2040 and the Carmarthenshire Local Development
Plan 2018 – 2033 acknowledge and respect the identity and function of our rural communities.
_______________________________________________________________________________________
Compiled and submitted by Plaid Cymru County Councillors, Cyngor Sir Gâr – April 2023
Cyng. Liam Bowen Cyng. Kim Broom
Cyng. Mansel Charles Cyng. Andrew Davies
Cyng. Bryan Davies Cyng. Ann Davies
Cyng. Glynog Davies Cyng. Handel Davies
Cyng. Karen Davies Cyng. Llinos Mai Davies
Cyng. Terry Davies Cyng. Arwel Davies
Cyng. Alex Evans Cyng. Colin Evans
Cyng. Hazel Evans Cyng. Linda Evans
Cyng. Tyssul Evans Cyng. Deian Harries
Cyng. Ken Howell Cyng. Peter Hughes Griffiths
Cyng. Meinir James Cyng. Gareth John
Cyng. Carys Jones Cyng. Betsan Jones
Cyng. Hefin Jones Cyng. Alun Lenny
Cyng. Jean Lewis Cyng. Neil Lewis
Cyng. Dai Nicholas Cyng. Aled Vaughan Owen
Cyng. Denise Owen Cyng. Dorian Phillips
Cyng. Darren Price Cyng. Emlyn Schiavone
Cyng. Russell Sparks Cyng. Dai Thomas
Cyng. Gareth Thomas Cyng. Elwyn Williams
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APPENDIX
Many elements of our planning system create complex dilemmas for Local Members and particularly for
Planning Committee Members when performing our roles and respecting our responsibilities:
• The role of the Local Member is to make the ward community a better place to live and work – to
improve quality of life and to develop and support plans which enhance and protect the
community, the environment and our future generations.
• The responsibility of the Local Planning Member is to observe the legislation, regulations and
guidance which are set down on our behalf to maintain Order within our communities, the Local
Authority and beyond.
The conflict between Members’ roles and Planning Members’ responsibilities gives rise to situations
where councillors are forced to compromise one in favour of the other. The Local Member is regularly
faced with two options:
• To support officers’ recommendations which are damaging to their own community in order to
conform with legislation, or
• To reject officers’ recommendations and act contrary to legislation in order to protect their
residents’ well-being.
It is not possible to reconcile this conflict under current planning policies.

Amend Plan

Submitted on behalf of all Plaid Cymru Councillors on Carmarthenshire County Council – April 2023

SECOND REVISED LOCAL DEVELOPMENT PLAN 2018 - 2033
CYNGOR SIR GÂR
RESPONSE TO PUBLIC CONSULTATION March/April 2023
This document attempts to measure the aims of the LDP against the specific proposals as regards RURAL
DEVELOPMENT, SUSTAINABLE RURAL COMMUNITIES and the WELSH LANGUAGE.
It is compiled from the point of view of Local Members who attempt to build strong rural communities
within the limitations presented in the Local Development Plan and the the Planning environment.
Critical issues faced by rural communities at this time include:
• De-population – loss of young people, leading to loss of young families, leading to loss of
generation of children and further young people – a cycle which rural communities cannot control
nor influence;
• Altered demographic – increasing purchase and occupation of residential dwellings by older
couples or individuals, either retired or preparing for retirement, both local and from afar –
ultimately leading to “retirement villages”;
• Market forces – demand of older generations who have the means to purchase a rural lifestyle
pushing property prices beyond the reach of younger working families;
• Media marketing – “lifestyle” programming on TV and other media encouraging urban dwellers to
aspire to idyllic rural locations thus squeezing local lower earners from access to the local market;
• Tourism – economic considerations from the (sporadic) visitor industry is prioritised above the
economic contribution of (permanent) rural residential working families;
• Yr Iaith Gymraeg – Planning Statements placing the Welsh Language in a priority position while
Planning Policy failing to protect or develop Welsh Language rural strongholds;
• Community – traditional rural community structures breaking due to fragmented demographic,
contrasting cultures and consequential loss of cultural heritage;
• Community Services – lack of young families stepping into and running the voluntary community
services such as sports clubs, PTAs, Church/Chapel groups, social events etc.;
• The Family – breakdown of “family care cycle”. While young families are not living near their
parents, care of the elderly by the younger generation and childcare by the older generation
cannot be provided, resulting in isolation and additional pressures on Care Services.
• Local Culture – not necessarily being recognised or acknowledged by new demographic. Absence of
younger generation to inherit and exercise local culture and tradition resulting in their demise and
disappearance.
How can the LDP support ordinary people in ordinary rural communities to develop their economy,
language and culture?
TAN 6: 2.1.2 “Planning authorities should assess the needs and priorities of rural communities. They
should interrogate published sources of information such as the Wales Rural Observatory, and if
necessary commission research to identify rural economic and social conditions and needs.”
The Wales Rural Observatory ceased to exist in 2014. The most recent report on rural communities was
published in 2013. Many of the issues above were identified at that time:
“A common concern … was that disproportionately high housing prices, fuelled by demand for
commuting, second homes, holiday homes and retirement accommodation, was taking owner
occupation beyond the reach of many people resulting in young people and young families being
driven out of the communities where they worked or had grown up.”
Ten years later, however, these issues remain unaddressed in national and local policies.
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LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
As recommended, Carmarthenshire County Council has commissioned its own research to identify rural
needs:
MOVING RURAL CARMARTHENSHIRE FORWARD – Report and Recommendations of the Carmarthenshire
Rural Affairs Task Group – June 2019:
“As a local authority we cannot directly influence decisions that are made in Cardiff, London and
Brussels but we can strongly urge our representatives to do whatever they can to safeguard the
future of rural Carmarthenshire and rural Wales. This is essential so that future generations can
live, work and spend their leisure time in communities where valued traditions can be maintained,
but are also resilient enough to adapt to an ever-changing social and economic landscape. This
report seeks to encapsulate that crucial balance between preservation and progression.”
There is a disconnect between the recommendations in the MOVING RURAL CARMARTHENSHIRE
FORWARD report – supporting the efforts of local people to maintain and develop rural communities –
and the inflexibility of the planning framework.
_____________________________________________________________________________________
OBSERVATIONS AND CONSIDERATIONS ON
SPECIFIC ASPECTS OF THE LDP
(A number of observations and considerations are common to more than one Strategic Policy)
LDP: HOM3 - Homes in Rural Villages
11.90 This part of the Plan's rural policy framework seeks to establish a flexible but controlled approach to
the delivery of new homes within those (Rural Villages) settlements. The Plan utilises a criteria-based
assessment to define small scale housing opportunities in rural villages and to meet the need for new
homes in rural parts of Carmarthenshire at a scale and at locations which maintain the essential character
of the countryside.
PPW Housing 4.2.1: Planning authorities must understand all aspects of the housing market in their
areas, which will include the requirement, supply and delivery of housing. This will allow planning
authorities to develop evidence-based market and affordable housing policies in their development
plans and make informed development management decisions that focus on the creation and
enhancement of Sustainable Places.
TAN 2.2.1: Many rural communities can accommodate development, particularly to meet local needs.
New development can help to generate wealth to support local services, ensuring that communities are
sustainable in the long term. A key question for the planning authority, when identifying sites in the
development plan or determining planning applications, is whether the proposed development
enhances or decreases the sustainability of the community. In particular, planning authorities should
support developments that would help to achieve a better balance between housing and employment,
encouraging people to live and work in the same locality.
Observations:
• The policies exert much control but very little flexibility within rural settlements.
• The “character of the countryside” is not defined in planning terms. It seems to refer to the
appearance of the countryside while it should, in fact, refer to all aspects of rural life. It is the
biodiversity, the nature, the traditions and, primarily, the local knowledge of the history and culture
of that part of the countryside which forms the character.
• If we lose the local residents then we lose that knowledge and protection.
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LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
• The criteria-based assessment prioritises maintaining the character of the countryside above
maintaining a local community.
• The policies fail to recognise the contribution of the local community to maintaining the character of
the countryside through its knowledge, traditions and protective practices.
CONSIDERATIONS:
• To apply additional flexibility to policies for rural villages to allow the needs of the
community to be met.
• To acknowledge the role of village residents in the enhancement and protection of the
“character of the countryside”.
• To measure the contribution a development makes to the well-being of the community
as opposed to considering only the perceived potential harm.
• To assess and recognise the scale of development required in rural villages to secure their
future as community strongholds.
LDP: HOM3 - Guidance on Acceptable Plots
Infill sites within these rural villages will take priority over other locations;
Where appropriate, sites adjoining a rural village are also acceptable. Such sites will be required to adjoin
the boundary of one property which forms part of the rural village group. All proposals which adjoin a group
(as opposed to infill sites) will be required to demonstrate the following:
• there is an existing physical or visual feature which provides a boundary for the group -
reducing pressure for unacceptable ribbon development or rural sprawl;
• where such a feature does not exist, there should be potential for such a feature to be provided
so long as it is in character with the scale and appearance of the group;
• Proposals located in open fields adjoining a group, which have no physical features to provide
containment will not be considered acceptable.
Observations:
• While infill sites should take priority over other locations, this should not exclude other locations.
• These rigid limitations appear logical in theory, but they are not practical in many rural settlements.
• The limitations do not take into account variances in our local topography.
CONSIDERATIONS:
1. To consider further potential development capacity in and around rural villages.
2. To apply rounding-off of boundaries to include capacity which logically allows sensitive
development.
3. To evidence actual harm against the potential for community benefit in setting and
respecting development boundaries.
LDP: HOM3 - Housing within development limits
Proposals which exceed the 10% cap above the number of existing homes in the settlement, as at the LDP
base date, will not be permitted except where they conform to Policy AHOM1 in relation to the provision of
affordable homes.
Observations:
• A settlement of 100 houses may only grow by 10 homes during the life of the LDP.
• A hamlet of 10 homes may only grow by 1 home during the life of the LDP.
• The rigidity of the 10% cap is not sympathetic to the aspiration to build sustainable rural
communities.
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LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
• While an exception is provided for Affordable Housing, the needs of a community may also include
market housing such as bungalows, “downsize” accommodation and dwellings to fit growing
families.
• If the linguistic and cultural vitality of rural villages is encouraged to grow from the inside, then rigid
caps are not appropriate.
CONSIDERATIONS:
1. To measure each application for a residential dwelling on its merits in the context of its
community, not only the context of development boundaries.
2. To assess the potential for development within or bordering the development limits in
the context of the particular settlement, and provide flexibility of boundaries where the
geography/topography does not allow expansion.
3. To provide for exceptions where affordable/local needs housing cannot be
accommodated within or bordering the development limits.
4. To consider the need for market housing to meet the needs of those who will not qualify
for Affordable Housing.
5. To remove the 10% cap above the number of existing homes in the settlement.
LDP: HOM4: Homes in Non-Defined Rural Settlements
Proposals for new single homes in settlements, hamlets and groups of dwellings which are not identified
under Strategic Policy SP3 will be permitted where they meet a local need for affordable housing and
conform to the following:
• It represents sensitive infill development of a small gap within an otherwise continuous built-up
frontage; or, is an appropriate rounding off of the development pattern;
• The development is of a scale that is consistent with the character of the area;
• The proposal will not result in an intrusive development in the landscape, and will not introduce a
fragmented development pattern;
• The size of the property reflects the specific need for an affordable dwelling in terms of the size of
the house and the number of bedrooms;
• That the occupancy of the dwelling is restricted both on first occupation and in perpetuity to those
who have a need for an affordable dwelling.
11.93 There are a notable number of small settlements or groups of dwellings throughout the County which
have not been defined within the settlement framework, and as such do not have development limits.
11.94 It is also noted that such provision needs to be delivered within the backdrop of a national agenda
centred on sustainability with placemaking at its heart. In this respect reference is made to the provisions of
PPW Ed.11 which requires that all residential development away from existing settlements or centres be
strictly controlled. The policy therefore in reflecting the provisions of national policy restricts local
affordable need dwellings in rural areas to established groups of dwellings.
PPW Strategic Placemaking 3.44: Consideration should be given to whether specific interventions from
the public and/or private sector, such as regeneration strategies or funding, are required to help deliver
the strategy and specific development proposals.
PPW Development in the Countryside 3.60: Development in the countryside should be located within
and adjoining those settlements where it can best be accommodated in terms of infrastructure, access,
habitat and landscape conservation. Infilling or minor extensions to existing settlements may be
acceptable, in particular where they meet a local need for affordable housing or it can be
demonstrated that the proposal will increase local economic activity. However, new building in the
open countryside away from existing settlements or areas allocated for development in development
plans must continue to be strictly controlled.
5
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
PPW Housing Delivery 4.2.24: In the open countryside, away from established settlements recognised
in development plans or away from other areas allocated for development, the fact that a single house
on a particular site would be unobtrusive is not, by itself, a good argument in favour of permission;
such permissions could be granted too often, to the overall detriment of the character of an area.
11.95 Whilst the Revised LDP is supported by a robust evidence base it is acknowledged that details of
housing need changes over time. Affordable housing proposals will be required to submit evidence
demonstrating the specific local need and ensure that the proposal provides for the size, type and tenure of
houses required. Proposals to meet speculative local need application will not be considered, rather they
should relate to an identified need from individuals/families within the specific area.
11.96 Where available, local housing needs surveys should be utilised in providing this evidence.
Alternatively, other forms of evidence may be considered appropriate including Strategic Housing Market
Area Assessments and local needs/Lettings registers.
Observations:
• Each regulation is based on geography and existing development patterns. The “protection” of the
settlement image takes priority over the actual needs of local people.
• There is no provision at all for dwellings which are not Affordable Housing. Not all local people need
Affordable Housing, but they have Local Housing Needs for a variety of reasons.
• Small Settlements or Groups of Dwellings are common in our rural countryside. While needing to be
“controlled”, exceptions should be possible where there is evidenced local need.
• Such exceptions should not be limited to Affordable Housing as many mature members of the
community do not qualify. Older members of the community have a strong need to remain in their
community for reasons of health, mental health and social interaction.
• Box-ticking to qualify for Local Needs does not always allow local people to express their unique
needs or to argue their case outside the specific requirements.
• While Local Needs/Letting registers may confirm the needs of young families seeking housing, many
members of the community who have local needs are excluded from housing registers.
• Retiring local farmers or other rural workers will not qualify for Affordable Housing in their life-long
community. No provision is possible for families or individuals who need to stay within their support
network in Non-Defined Rural Settlements.
CONSIDERATIONS:
1. To prioritise the needs of the people and the community over the visual or conceptual image
of the settlement.
2. To use the actual housing needs of applicants to drive the policy, not devise a policy which
excludes the very housing needs it is intended to address.
3. To provide some capacity with the policy for those who do not qualify for Affordable
Housing but whose needs are equally important.
4. To define what “too often” means in granting permissions in the open countryside, and
consider the local needs of individuals above non-defined caps.
5. To consider the need within the community for young families, not only the need of a family
to live in a location.
6. To provide a needs-assessment which is not exclusively a “box-ticking” exercise.
7. To prioritise matching the needs of individuals with the needs of the community over
reducing numbers on Housing Registers.
LDP: AHOM2 - Affordable Housing - Exceptions Sites
Proposals for 100% affordable housing development on sites adjoining the Development Limits of defined
settlements (Tiers 1-3 in Policy SP3), will, in exceptional circumstances be permitted where it is to meet a
genuine identified local need (as defined within the Glossary of Terms) and where:
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LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
• The site represents a logical extension to the development limits and is of a scale appropriate, and
in keeping with the character of the settlement;
• The benefits of the initial affordability will be retained for all subsequent occupants;
• It is of a size, scale and design compatible with an affordable dwelling and available to low or
moderate income groups;
• There are no market housing schemes within the settlement, or projected to be available which
include a requirement for affordable housing.
TAN 6: 2.2.4: They (planners) should also ensure that any sites identified for development are effectively
available and likely to be brought forward for development by the owner. This is particularly important in
smaller settlements, where a limited number of landowners may control land supply
TAN 2: 10.12: It is important that there is adequate housing provision in rural areas to meet the needs
of local people and to contribute to the delivery of sustainable communities. Development plans must
set out how planning at the local level will contribute to meeting identified rural affordable housing
needs.
TAN 2: 10.16 Local planning authorities must set out in their development plan their definition of ‘local
need’ for affordable housing in rural areas, within the overall aim of contributing to the delivery of
sustainable communities. This can include:
• existing households needing separate accommodation in the area;
• people whose work provides essential services and who need to live closer to the local
community;
• people with a family connection or long standing links with the local community; and
• people with a job offer in the locality who require affordable housing.
For some of these categories the area within which needs will be considered ‘local’ must also be
defined in the development plan. This may include:
• the village or group of villages;
• the community council area;
• an electoral ward or group of wards;
• the local authority area.
TAN 2: 10.14 Rural exception sites are not appropriate for market housing.
11.124 An affordable dwelling must be compatible with WG's Design Quality Requirement standards to limit its
size, scale and design to ensure that the dwelling falls within a reasonable and acceptable affordable dwelling
cost for future occupants. In exceptional circumstances, a departure from these standards may be considered
appropriate where they are to meet the occupant's needs and are clearly evidenced and justified.
Observations:
• Availability of land dictates the potential for Exception Sites.
• While Exception Sites provide the potential for Affordable Housing adjoining Local Development
boundaries, this may not be possible in many rural villages.
• The topography of our area does not always permit development outside existing settlements and
steep gradients make affordable construction unviable.
• Where land may be available, other factors may not meet requirements such as Highways, SAB
assessments etc. thus limiting the potential for development.
• Non-availability of land in and around Defined and Non-Defined Rural Settlements results in no housing
to meet local needs.
7
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
• There are natural boundaries between communities which dictate social interaction. A nearby
community, across a river or motorway, may be more alien to a local individual than a town twenty
miles further afield.
• There is no provision at all for market housing in many rural settlements. If you don’t qualify for Local
Needs, or there is no Local Needs capacity in your community – you can’t live there.
• The size, scale and design of Affordable Housing cannot accommodate a growing family, especially
where children are not all of the same gender and vary in age.
• “Exceptional Circumstances” may not be so exceptional. Some quite ordinary circumstances exclude
local people from qualifying for Local Need.
• Young families wishing to return to their area to bring up their children and who have owned a
home in another area will not qualify for Affordable Housing, but cannot afford open market
housing.
• There is no guidance on what constitutes an “exception”. The policy accommodates nuclear families
with 2.4 children. There is no provision for Blended Families whose needs are more varied and
extensive.
CONSIDERATIONS:
1. To acknowledge that Exception Sites are at the discretion of local landowners, access/highways
restrictions, SAB requirements and other limiting factors.
2. Where no Exception Sites can be identified, to exercise flexibility in considering alternative sites
which may deviate from the current permitted sites.
3. Where particular individual “locality” needs are identified, to consider applications for nonaffordable
housing development in the interest of the individual, the family and the community.
4. To consider the definition of “local” in the context of the individual and the community rather
than by a radius of concentric miles.
5. To assess the needs of growing families when calculating the size, scale and design of Affordable
Housing in order to provide long-term security and a decent quality of life.
6. To acknowledge the housing aspirations of young families in rural areas as a material planning
consideration.
LDP: EME4 - Employment Proposals on Non-Allocated Sites
Proposals for employment development on non-allocated sites, but within the development limits of a
defined settlement will be permitted where:
• it is demonstrated that no other suitable existing or allocated employment sites or previously
developed land can reasonably accommodate the proposal;
• the development proposals are of an appropriate scale and form, and are not detrimental to the
respective character and appearance of the townscape/ landscape;
• The development is compatible with its location and with neighbouring uses.
Employment proposals outside the development limits of a defined settlement (Policy SP3) will be permitted
where:
• The proposal is directly related to a settlement or hamlet; or
• The proposal is supported by a business case which demonstrates that its location is justified; and
• The proposal is of an appropriate scale, size and design.
11.165 For proposals outside the development limits of a defined settlement, they must show that they are
directly related to a settlement or hamlet, or supported by a business case which justifies its location. The
Plan recognises that small-scale enterprises have a vital role to play in the rural economy and contribute to
both local and national competitiveness and prosperity. Many commercial and light manufacturing
activities can be appropriately located in rural areas without causing unacceptable disturbance or other
adverse effects. In this respect, the development of small businesses would address any local need for
employment accommodation.
8
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
PPW: The Rural Economy 5.6.4 To unlock the full potential of rural areas, planning authorities should
adopt a positive approach to employment arising from foundation and innovative and technology
based sectors, including research and development, in addition to employment arising from the
traditional agriculture, forestry and leisure sectors. Proposals for diversification, new startups and
micro-businesses should also be encouraged, where appropriate, to generate new job and wealthcreating
opportunities.
TAN 6: 2.2.2: Development plans should define local need taking into account the social, economic and
environmental characteristics of the area. Where possible existing definitions of local need,
for example affordable housing to meet local need, should be adopted, or if necessary modified
to include other land uses.
Observations:
• There is no connection provided between Employment on Non-allocated Sites and the needs of rural
villages to remain sustainable. Living and working within the community is vital to its existence.
• Some capacity has to be provided to acknowledge the place of small-scale businesses within rural
communities. There is no provision for small-scale commercial enterprises.
• The increase in home-working needs to be supported by flexibility across all genres of employment.
Additional space may be needed – inside and outside development limits – to accommodate future
working practices.
• This will be mitigated by reduction in travel and healthier work-life balances, thus meeting the aims
of our well-being goals.
CONSIDERATIONS:
1. To apply flexibility in meeting the needs of local people to work within their community.
2. To provide working spaces which accommodate local employment in areas outside or
without development limits.
3. To encourage satellite working as and when technology permits during the lifetime of the
LDP.
LDP: SP 8 - Welsh Language and Culture
The Plan supports development proposals which safeguard, promote and enhance the interests of the
Welsh language and culture in the County. Development proposals which have a detrimental impact on the
vitality and viability of the Welsh language and culture will not be permitted unless the impact can be
mitigated. All development proposals subject to WL1, will be expected to identify measures which enhance
the interests of the Welsh language and culture.
11.174 The Plan seeks to 'promote the Welsh language and culture'[59] and is committed to contributing to
the Welsh Government's long-term aim of achieving 1 million Welsh speakers by 2050[60]. To deliver on this
aim, the Council will support, promote, and enhance the Welsh language as a viable community language
by ensuring that there are sufficient and proportionate employment and housing opportunities to sustain
both the rural and urban communities in the County and by implementing an effective monitoring
framework. In doing so, the Plan seeks to ensure that the local population have the opportunity to remain in
Carmarthenshire rather than leave in search of work opportunities and housing, as well as the opportunity
to return. Through aiming for sustainable growth, the Plan will also maximise opportunities for non-Welsh
speakers who move to the County to be integrated into community life at a scale and pace that will not
undermine the vitality and viability of the Welsh language and culture.
11.177 The Plan also seeks to safeguard, promote, and enhance the Welsh language in Carmarthenshire
through other relevant policy objectives, namely through the provision of housing and affordable housing,
promoting a vibrant economy and employment opportunities and the provision and retention of community
facilities, amongst others.
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LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
TAN 20: 1.4.8 Section 70(2) of the Town and Country Planning Act 1992 (TCPA) clarifies that
considerations relating to the use of the Welsh language may be taken into account when determining
applications for planning permission, so far as they are material to the application. This may apply to
any application in any part of Wales. This provision does not give any additional weight to the Welsh
language above any other material consideration.
LDP: WL1 - Welsh Language and New Developments
All development proposals throughout Carmarthenshire will be required to safeguard, promote and
enhance the Welsh language … Proposals which do not accord with the Plan's housing trajectory will be
required to provide a phasing plan outlining the timescales for delivering the homes proposed on the site
and demonstrate that they would not have a negative impact upon the Welsh language which cannot be
mitigated.
11.178 The Welsh Language Action Plan sets out the measures to be taken to safeguard, promote and
enhance the Welsh language. The Welsh Language Action Plan should also outline how the development
proposes to make a positive contribution towards the community's Welsh language groups. This could,
amongst others, include providing support and funding towards organisations and bodies that provide
activities, facilities and education for Welsh speakers and learners, and support and funding towards Welsh
language classes. Welsh Language Impact Assessments (WLIA) will be required to outline the anticipated
impacts of the proposed development upon the Welsh language in the County. The Welsh Language
Supplementary Planning Guidance[61] provides further guidance on when a WLIA is required, clarifying
what constitutes a large scale development, as well as how to produce a WLIA.
11.182 The ISA of the LDP is required to assess the likely effects of the LDP upon the Welsh language. This is
done iteratively at key stages throughout the Plan's production. The likely anticipated effects are presented
in the ISA report, and further information is available within the LDP's evidence base.
TAN 20: 3.3.2 Evidence from the language impact assessment may be material to the application and
may inform whether measures to mitigate or enhance the impacts of the development on the use of
the Welsh language should be applied.
Welsh Language County Strategic Forum: “Language planning work within the LDP process, particularly
the development of a new methodology to measure the impact of land use on the Welsh language” notes
a “Lack of national guidance and dependable information on the impact of construction on the Welsh
language in terms of numbers of permitted locations for house building and their geographical locations.”
Carmarthenshire Welsh Language Promotion Strategy 2023 – 2028: p.7 Despite the positive contribution
of all the above policies, a number of factors that most adversely affect the Welsh language in
Carmarthenshire remain outside their scope. The affordability of housing for local young people for
example is largely influenced by the open market and private sector profits. The same is true with regard
to the influx of older people from outside Wales into Welsh-speaking communities. After the first
Strategy's efforts to work with estate agents to try to gain useful information to address this problem, it
must be recognised that it is only Welsh Government who are in a position to meaningfully influence these
factors. We look forward to working together on innovative efforts by the government in this area of work
and to explore new law-making forces that could mitigate harmful effects on the Welsh language.
Welsh Government: CYMRAEG 2050: a Million Welsh Speakers: Development and the Welsh language -
p.63: The land use planning system should contribute to the vitality of the Welsh language by creating
suitable conditions for thriving, sustainable communities, supported by an awareness of the relevant
principles of language planning. Decisions regarding the type, scale and exact location of developments
within a specific community has the potential to have an effect on language use, and as a result on the
sustainability and vitality of the language. This calls for strengthening the relationship between language
planning and land use planning.
10
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
Cyngor Sir Gâr: Notice of Motion 10.7.2019 (unanimously supported): “This council believes that the
whole of Carmarthenshire is an ‘area of linguistic sensitivity and significance’ and that the planning system
has a crucial role to play in supporting the Welsh language across the county. To this end, we believe that
the language should be a Material Planning Consideration in all applications for the development of five or
more houses in rural areas and ten or more in urban areas in every community, irrespective of the
percentage of Welsh speakers.
Observations:
• Cyngor Sir Gâr’s Notice of Motion identifies the whole county as an area of linguistic sensitivity and
as such should be recognised as a positive material consideration in rural areas.
• In reality, the Plan does not acknowledge the importance of small rural communities in its
safeguarding and enhancement of the Welsh Language. Many of our rural villages are the
strongholds of first-language Welsh-speakers and form the foundation of Welsh language and
culture throughout the county. Welsh speakers are concentrated in these areas, but the ability of
young families to live and work within these communities is limited by the Plan and other regulatory
factors.
• The Plan addresses two aspects of Welsh-language safeguarding:
a) It requires assessments on the impact of developments on the Welsh language;
b) It provides for activities, facilities and education which promote the Welsh language;
• The Plan does not provide for sensitive development within the small community strongholds of the
language. Welsh-speakers who cannot build or buy within their villages, or in the surrounding areas,
cannot support the language in their native communities.
• Local people may have access to land which would reduce costs and make the building of their own
home viable. Proportionate development on private land should be made possible where
appropriate.
• Rural Welsh-language villages need proactive policies to offer accommodation in the community –
both to young families in need of Affordable Housing and to those requiring market housing.
• Assessments of the likely effects of the LDP on the Welsh language will depend on the detail
available and be data-led.
• Pre-planning Welsh-language Assessments are appropriate for larger developments in service
centres and towns, however, external assessments do not evidence the actual prosperity of the
language in small villages and communities.
• Welsh-language impact assessments are commissioned by the applicant and may not always be
independent.
• A reversal of thought is required so that the needs of the Welsh language influences the LDP rather
than the LDP attempting to react to perceived needs.
• The data on Welsh-speakers in Carmarthenshire has not yet been based on the 2021 Census and is
out of date.
• There is very little planning guidance attached to the Welsh Government policy to achieve one million
Welsh speakers by 2050.
• While the CYMRAEG 2050 policy calls for strengthening the relationship between language planning and
land use planning, Welsh Government’s own planning policies make this impossible.
CONSIDERATIONS:
1. To recognise the Linguistic Sensitivity of the whole county and the potential of rural
communities to increase the number of Welsh-speakers if supported proactively through the
LDP.
2. To move from assessing impact to providing positive measures to develop Welsh-language
strongholds.
3. To acknowledge that strict controls on market housing in rural areas harms Welsh-language
communities.
4. Where development is evidenced through local need, to balance the potential visual harm to
rural areas against the potential benefit to language and culture.
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5. To provide a body to conduct Welsh-language impact assessments which is independent of
the applicant and the Local Planning Authority.
6. To re-assess Welsh-language impact policies as soon as the 2021 Census data is available.
7. To recognise the need for Welsh Government to explore new approaches to planning in
rural areas in order to enable local Welsh Language Strategies to be implemented and to
enable CYMRAEG 2050 to be a realistic possibility.
LDP: SP11 - The Visitor Economy: Respecting the County's social, economic and environmental fabric.
11.234 All parts of the County possess qualities that contribute to the overall sense of place. These include
landscape, nature conservation, social fabric and built environment. These are assets which must be
protected for our future generations and cannot be unduly compromised by tourism related development.
11.235 There should also be an emphasis on providing quality in all aspects of a proposal. In considering the
acceptability of proposals, consideration will be given to location, siting, design and scale, access to the
primary and core highway network and the impact of any resultant traffic generation. Furthermore, the
extent to which the site is serviceable by public transport, walking and cycling are important considerations.
Proposals should reflect the character and appearance of the area with appropriate landscaping and
screening utilised as required.
11.239 The County's rural areas are well placed to accommodate proposals for high quality and sustainable
proposals that are of an appropriate scale. Proposals should respect the County's assets whilst supporting
vibrant rural communities.
11.240 Some tourism related developments, by their very nature, must be located in the countryside. It is
important that these developments do not have any significant negative impact on the landscape, natural
environment, or amenity. In terms of the detailed policies for the Revised LDP, the emphasis is on providing
clarification on the two notable challenges and opportunities facing the visitor economy in Carmarthenshire
which are attractions (somewhere to go) and accommodation (somewhere to stay).
LDP: VE2 - Holiday Accommodation
Proposals for high quality serviced accommodation, including appropriate extensions to existing
accommodation, will be permitted where they are located within, or directly related to a defined settlement
(Policy SP3).
Proposals for serviced and self-catering accommodation that are located outside of the above locations will
only be permitted where they consist of the re-use and adaptation (including conversion) of existing
buildings in conjunction with policy RD4.
All proposals set out above should reflect and respect the role and function and sense of place of the area,
most notably in terms of scale, type, character, design, layout and appearance - as well as those uses
already located in the vicinity of the site.
11.247 Where planning permission is given for permanent holiday accommodation, the Council will
consider the attachment of conditions restricting the use to holiday accommodation only. Seasonal
occupancy conditions may also be used to prevent the permanent residential occupation of such
accommodation. In addition, in areas where the prevalence of second homes and holiday homes are known
to be a serious issue within communities, the Council will consider placing restrictions upon permitted
development rights to change existing dwellings to holiday homes and second homes.
LDP: VE4 - Static Caravan and Chalet Sites and Permanent Alternative Camping Accommodation:
Proposals for new Static Caravan and Chalet Sites will be permitted where:
• they are within or directly related to a defined settlement (Policy SP3), or, they are located or
demonstrate a spatial and functional relationship with a relevant existing tourism facility or
attraction;
• they are of high quality in terms of design, layout and appearance, and will not have an
unacceptable adverse effect upon the surrounding landscape and/or townscape;
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• they will not lead to a significant and unacceptable intensification in the provision of sites in the
locality;
Proposals for the enhancement and extension of existing sites will be permitted where:
• it will increase the vitality, sustainability and environmental quality of the site;
• it will not result in an unacceptable increase in the density of units and/or the overall scale of the
site.
• it will not have an unacceptable harm on the surrounding landscape, seascape and / or townscape;
• it provides (where appropriate) for the significant improvement of the overall quality, appearance
and setting of the site.
11.256 This policy recognises that appropriate high-quality proposals should be supported. This recognises
the need to provide a diverse accommodation offer in terms of providing a range and choice of places to
stay within the County.
TAN13: TOURISM – Published in 1997, this document is woefully inadequate to address the needs of
accommodating visitors in 2023 and the future.
Observations:
• “The County’s rural areas are well placed to accommodate proposals for high quality and
sustainable proposals that are of an appropriate scale” suggests that tourism developments take
priority over residential developments. Nowhere does the Plan refer to residential development
located in the countryside in such positive terms, but tourism is accommodated with flexibility.
• The re-use and adaptation (including conversion) of existing buildings outside a settlement is
permitted for visitor accommodation but not for housing for local people.
• No evidence is provided to illustrate why holiday accommodation is considered to have less impact
on the countryside than residential dwellings. This in no way suggests that there be should be
competition between both uses, but it is not clear how holiday accommodation makes a greater
contribution to sustainable communities than housing for local people.
• A “spatial and functional relationship with a relevant existing tourism facility or attraction” includes
the open countryside. If static Caravans and Glamping Pods are of a scale, layout and design
appropriate to the setting, and if properly screened, such developments provide diversification
income to rural areas while providing much needed visitor accommodation.
• The rigidity of travel planning restrictions where public transport is not readily available bars much
unintrusive development.
• While Static Caravan, Chalet and Glamping Pod Sites in rural areas are subject to rigid planning
regulation, the ownership and use of these units as second homes prevents the purchase of
residential family dwellings for holiday purposes. This helps protect traditional rural homes from
second home use, while purchasing a chalet on a park is far less costly as a second home than
purchasing a house.
CONSIDERATIONS:
1. To question if the visitor economy is prioritised over local needs, and consider both
community benefits on equal terms.
2. In light of the recent policy on Second Homes/Holiday Homes Council Tax Premium, to
consider permitting residential use of existing holiday accommodation in the open
countryside which may no longer remain viable.
3. To recognise that small, well-designed accommodation sites in the open countryside provide
diversification opportunities to farming communities and contribute to the local economy.
4. To encourage well-sited Static Caravan, Chalet and Glamping Pod Sites in areas heavily
affected by second home use as an attractive option to potential second home purchasers.
5. To provide a balance of residential and tourism accommodation in rural areas to encourage
mutual support between communities and visitor economy.
6. To replace TAN13 with guidance which is appropriate and relevant to the life of the Plan.
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LDP: SP 12 - Placemaking and Sustainable Places
11.269 The Act means that public bodies such as local authorities must work to ensure that developments
should acknowledge and seek to improve the economic, social, environmental, and cultural well-being of an
area.
Observations:
• With regards to social and cultural well-being, there is no provision for placing small rural
communities at the centre of policy, or for building the policies around the needs of village
communities.
CONSIDERATIONS:
1. To recognise the place of small communities in achieving the aims of the Well-being and
Future Generations Act.
2. To allow rural communities to improve and grow on a par with urban communities.
LDP: SP 13 - Rural Development
11.366 The rural settlements of the County have an important role to play in improving the sustainability of
the wider geographical area in which they are located as well as the County's overall sustainability. The
Plan's strategy and settlement hierarchy reflects the significant role which the rural communities play
through supporting growth of a proportionate scale which can make a positive contribution towards the
long-term sustainability of the rural economy and rural communities.
11.367 Proportionate and sensitive development can provide the level of growth required to retain and
enhance the services and facilities provided in the County's rural settlements. It can also serve to safeguard
and promote the Welsh language in rural areas and enhance rural employment opportunities. However, the
Plan seeks to ensure that development and growth does not have negative impacts upon a community's
sustainability. Key to this is ensuring that development is not permitted at a scale or rate which would affect
the community's ability to absorb and adapt to growth and change. This is imperative when considering the
impacts which development can have upon the local infrastructure, the vitality of the Welsh language and
the sustainability of the countryside and natural environment.
11.368 National planning policy has historically sought to restrict unnecessary development in countryside
locations, principally to prevent sporadic and unsustainable growth and to maximise use of infrastructure,
resources and services more commonly available in established urban areas.
11.369 Whilst this principle remains relevant and applicable, there is an enhanced recognition of the
countryside as a place of work, as a home for many, a place to visit for others and a vital ecosystem for
everyone. The Plan is committed to addressing and safeguarding the needs of rural communities. To this
end, the Council established a Rural Affairs Task Group with the aim of assessing the needs of rural
communities and taking positive steps to address these. This Plan supports the aims and outcomes from the
Task Group principally through policies relating to the provision of housing and affordable housing; the
economy and employment; the Welsh language, and the natural environment. Development proposals will
need to demonstrate that they accord with these policies as well as the provisions of national planning
policy.
PPW: Placemaking in Rural Areas 3.38: The countryside is a dynamic and multi-purpose resource. In
line with sustainable development and the national planning principles and in contributing towards
placemaking outcomes, it must be conserved and, where possible, enhanced for the sake of its
ecological, geological, physiographic, historical, archaeological, cultural and agricultural value and for
its landscape and natural resources. The need to conserve these attributes should be balanced against
the economic, social and recreational needs of local communities and visitors. Fostering adaptability
and resilience will be a key aim for rural places in the face of the considerable challenge of maintaining
the vibrancy of communities and availability of services as well as contributing to the Cohesive
Communities well-being goal.
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11.373 This understanding of diversity is reflected within PPW in its consideration of sustainable transport
requirements. It recognises there is a need to reflect different approaches to sustainable transport in
defining growth within rural settlements.
TAN 6: 2.2.3 Where development proposals are intended to meet local needs, planning authorities
should recognise that a site may be acceptable even though it may not be accessible other than by the
private car. Development not intended to cater primarily for local needs should continue to be located
in market towns, local service centres or clusters of smaller settlements where a sustainable functional
linkage can be demonstrated and which are accessible by public transport.
Observations:
• “The Plan is committed to addressing and safeguarding the needs of rural communities” - the Plan
does not address the needs of rural communities.
• The Rural Affairs Task Group states that:
“There is of course a recognition of the need for sensitive consideration of a number of factors
when looking at development in rural areas but the Task Group feels that current planning
policy from Welsh Government does not give enough flexibility to enable development, based
on local need, in our most rural communities.”
• While the preservation of the countryside is important, the policy “moth-balls” rural villages as
static entities and “enhances” them by keeping them attractive to visit and view. The policies invite
people to observe the attractive characteristics – culture, tradition, Welsh-language without
attempting to develop these characteristics and make them sustainable.
• Sustainable transport policies are limiting the development of rural housing while they encourage
extending the development of holiday accommodation. The travel footprint of weekly visitors to
and around rural areas is not measured against the travel footprint of weekly activities of local
residents.
CONSIDERATIONS:
1. To place rural communities at the heart of the Strategic Policy.
2. To provide “…enough flexibility to enable development, based on local need, in our most
rural communities”.
3. To define “enhancement” in material terms as regards sustaining and developing the
language, culture and heritage of our rural areas.
LDP: Rural Enterprise Dwellings
11.379 As noted through national policy, a rural enterprise dwelling is required where it 'is to enable rural
enterprise workers to live at or close to their place of work'. This includes encouraging younger people to
manage farm businesses and supporting the diversification of established farms.
11.380 It is not the role or the intention of the Revised LDP to replicate the provisions of national planning
policy. Consequently, reference should be had to the provisions of PPW and Technical Advice Note 6 (TAN6)
in the determination of applications for new rural enterprise dwellings. National policy clearly states that
such proposals should be carefully examined to ensure that there is a genuine need.
11.381 Applications for rural enterprise dwellings should be accompanied by a rural enterprise dwelling
appraisal, with permission only granted where it provides conclusive evidence of the need for the dwelling.
TAN 6: 4.1.1 The Assembly Government’s vision for housing is for everyone in Wales to have the
opportunity to live in good quality, affordable housing, to be able to choose where they live and decide
whether buying or renting is best for them and their families. This vision is applicable to both urban
and rural areas.
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Observations:
• The bar for proving “conclusive evidence of the need for the dwelling” is uniquely high for Rural
Enterprise Dwellings in comparison with other housing categories. The amount of necessary
evidence and the years required to compile data makes such applications prohibitive.
• TAN6: 4.1.1 contradicts the lengthy and detailed restrictions placed on individuals and families
attempting to remain in their local community.
• The need to live near a rural enterprise should not be assessed on the employment needs of the
enterprise alone. Families support rural enterprises in many other ways, not only through their
employment on the site.
• Families in alternative fields of employment who have strong ties to the site should be encouraged
to remain within their traditional and cultural setting.
CONSIDERATIONS:
1. To bring the requirements of Rural Enterprise Dwellings in line with the requirements of
all other housing requirements – including urban housing and One Planet Development
housing.
2. To apply the same test of need for a rural enterprise dwelling as that for a dwelling on a
One Planet site.
3. To recognise the potential contribution of Rural Enterprise Dwellings to the sustainability
of language, culture and heritage.
4. To acknowledge that creating an additional dwelling on a rural enterprise site supports
the business and family whether or not the residents are in the employment of the
enterprise.
LDP: RD2 - Conversion and Re-Use of Rural Buildings for Residential Use
Proposals for the conversion and re-use of suitable rural buildings for residential use will be permitted
where:
• the existing use has ceased, and its re-use would not result in the need for an additional
building;
• the design and materials are of a high quality, and the form and bulk of the proposal, including
any extensions, curtilage and access arrangements are sympathetic to and respect: the
surrounding landscape, rural character of the area and the appearance of the original building;
• Proposals for extensions should be proportionate and reflective of the scale, character and
appearance of the original building;
• the original building is structurally sound and any rebuilding works, necessitated by poor
structural conditions and/ or the need for new openings in walls, do not involve substantial
reconstruction;
• where applicable, the architectural quality, character and appearance of the building is
safeguarded and its setting not unacceptably harmed.
TAN 6: 3.6.1 Whilst residential conversions have a minimal impact on the rural economy,
conversions for holiday use can contribute more and may reduce pressure to use other houses in the
area for holiday use.
Observations:
• While RD2 permits the conversion of suitable rural buildings for residential use, the majority of
these buildings lie outside the development limits of rural villages and therefore cannot be
permitted as residential dwellings.
• This excludes a number of surplus farm buildings from being converted to homes for young local
families, although they can be converted for holiday use.
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• It is asserted that residential conversions for holiday use can contribute more to the local economy.
Is there evidence that holiday accommodation contributes more to the local economy than
residential families? This statement does not consider factors such as holiday accommodation being
owned by individuals well outside the “local economy” and where the income goes directly out of
the local area, county or country.
• It does not consider the contribution a residential family makes to the local economy on a daily,
weekly and annual basis. A data-based study would provide evidence of this assertion.
CONSIDERATIONS:
1. To apply the same impact measurements of conversion to holiday cottages/barns on the
open countryside as to conversion to residential cottages/barns in the open countryside.
2. To provide evidence of the carbon footprint benefit of tourist against that of residents.
3. To permit re-use/conversion of surplus rural buildings for residential use side by side
with holiday use.
LDP: HOM7 - Renovation of Derelict or Abandoned Dwellings:
Proposals for the renovation of derelict or abandoned dwellings outside the Development Limits of a
defined settlement (Policy SP3) will be permitted where:
• It can be demonstrated that a significant part of the original structure is physically sound and
substantially intact requiring only a limited amount of structural remedial works;
• The building demonstrates and retains sufficient quality of architectural features and traditional
materials with no significant loss of the character and integrity of the original structure;
• There are no adverse effects on the setting or integrity of the historic environment.
11.104 The renovation of abandoned dwellings can make a small but important contribution to the needs of
an area. The architectural value of a number of derelict or abandoned dwellings often reflects the
traditional vernacular and should be recognised in the submission of such proposals. Extensions, access
requirements or other aspects associated with the proposal should be sympathetic to the character of the
original building and the landscape. Proposals which seek to make a positive contribution to the landscape
qualities of the area will be encouraged.
Observations:
• There is very little policy detail or guidance on the re-use of derelict dwellings or ruins to provide
homes for local families. The guidance for derelict dwellings is arbitrary and open to interpretation.
• Sir Gâr no longer has a “tradional vernacular” style of dwelling. Most modern houses have for
decades been built with breeze blocks. It is reasonable that farm buildings constructed from such
materials, possibly with re-facing, should be considered for adaptation as dwellings.
• As part of the Levelling Up strategy, the UK Government has consulted on the “Right to Regenerate”
bill which promises to re-use derelict buildings in public ownership, but not in private ownership.
• Farming unions are encouraging rural owners not to allow their property to fall into the
“Abandonment” category which will require full planning permission for re-instatement as a
residential dwelling.
CONSIDERATIONS:
1. To acknowledge the historic use of a derelict/abandoned dwelling in the open countryside in
order to return it to its traditional residential use.
2. In 2023, to recognise the reality of the nature of the construction of many 20th Century rural
buildings and consider their sensitive re-use as dwellings.
3. To encourage proposals which seek to make a positive contribution to the landscape
qualities of the area.
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RE-USE OF PLACES OF WORSHIP
11.450 Many elements of the County's built and historic environment are protected through legislation or
other policy provisions, and as such do not require policies in the revised LDP. The Plan does not therefore
include policies in relation to facets of the built heritage such as Scheduled Monuments as they are
adequately protected elsewhere.
TAN24: Historic Assets of Special Local Interest - 8.1 - Historic assets that the local planning authority
may consider to be of special local interest are not accompanied by any additional consent
requirements over and above those required for planning permission. However, if such assets are to
contribute successfully to the conservation or enhancement of local character their status needs to be
clear in the development management process. If a local planning authority chooses to identify historic
assets of special local interest, it must include policies for their preservation and enhancement in the
local development plan.
Managing Change to Listed Places of Worship in Wales – Welsh Government: 5.13 Closed or Closing
Places of Worship: Listed places of worship may have a continuing and valuable contribution to make
to the community even when they are no longer required for worship. Before they cease to be used for
worship, it is important that there is no unnecessary delay in finding alternative uses compatible with
the significance of the fabric, interior, contents and setting of the building.
CADW - Historic Assets Of Special Local Interest: Local planning authorities may choose to identify
historic assets of special local interest - known as ‘local listing’ … Local listing is important because it
provides the base for local planning authorities to develop policies for their protection and
enhancement. This means that local planning authorities can manage change through the planning
system so that local historic assets continue to contribute to the vitality of the area … Local listing also
provides an opportunity for a community to get involved in the identification of historic assets of
special local interest and in caring for them appropriately.
Observations:
• There is very little guidance on the functional re-use of chapels and churches in rural communities
apart from their historic surroundings and facades.
• Many church and chapel buildings in rural areas are converted for holiday/second home use. This is
not consistent with the interests of “local listing” to preserve the contextual integrity of the
community asset.
CONSIDERATIONS:
1. To acknowledge that the LDP could include measures to assess, secure and re-use closed
Places of Worship for the benefit of the community.
2. To encourage conversations between representatives of closing Places of Worship, planners
and the community before disposal of the asset.
3. To consider placing covenants on Chapels and Churches being converted to dwellings to
ensure they are permanent residential dwellings rather than second homes in order to
protect the historic integrity of the building for the future.
4. To require that CADW exercises flexibility in its approach to the re-use of local historic assets
so that they remain of value and interest to the community.
LDP: RD3 - Farm Diversification
Proposals for farm diversification developments which strengthen the rural economy will be permitted
where:
• It is compatible with, complements and supports the principal agricultural activities of the existing
working farm;
• It is of a scale and nature appropriate to the existing farm operation;
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• It has appropriate regard to the highways and transport infrastructure;
• It would not have an adverse impact on the character, setting and appearance of the area and the
surrounding landscape.
11.393 Diversification in rural areas can often add to the income streams and economic viability of farms,
strengthen the rural economy, and add to wider employment opportunities.
11.394 Farm diversification proposals are intended to supplement and support the continuation of the
existing farming activity. Proposals should be accompanied by evidence detailing a justification for the use
and its relationship with the existing farming activity.
11.396 In considering proposals for farm diversification it is acknowledged that their rural context means
that they cannot always be well served by public transport. Consequently, whilst its availability will be taken
into account when considering the nature and scale of the proposal, the potential for certain diversification
proposals which can only be accessible by private car is acknowledged. Such proposals should have regard
to the sustainable transport hierarchy.
Observations:
• While diversification in rural areas is encouraged, the capacity for young families to live and work on
rural sites outside development limits is severely restricted, bordering on the impossible. This is
detrimental to the sustainability of village communities.
• Many farm diversification plans are thwarted at the outset due to their rural siting, thus falling
under the myriad restrictions on development in the open countryside.
• The perceived negative aspects of potential development outweigh the likely positive impacts on
community sustainability.
CONSIDERATIONS:
1. To provide for local families who wish to remain in or return to their community to live and
work in their rural area.
2. To examine the potential community benefit as a material consideration.
3. To provide more flexibility in the sources of income which contribute to a rural enterprise to
allow spouses, partners and their progeny to remain in or return to their family homesteads.
GENERAL - MOVING RURAL CARMARTHENSHIRE FORWARD – Report and Recommendations of the
Carmarthenshire Rural Affairs Task Group – June 2019:
3.2.4: “The Council is currently in the process of revising its Local Development Plan and the Task Group
feels there is a need to redress the current balance to enable appropriate and suitable development
within our rural towns and communities. This development needs to be taken forward based on local
need rather than national targets and regulations. There should of course be a thorough consideration
and understanding of the impact that any residential or business development may have on the nature
and construct of rural communities, especially in terms of its possible positive or negative impact on
the Welsh language, and the size of development should also be comparative to the existing
community, but suitable development in our rural communities needs to be enabled in order to ensure
the sustainability of our rural communities going forward.”
Observations:
• The Task Group has analysed and attempted to address and evidence the critical issues
referenced above. However, it is apparent that the Local Development Plan continues to be led
by national targets and regulations rather than by genuine local need.
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WALES RURAL OBSERVATORY - 2013:
The Experiences and Aspirations of Young People in Rural Wales (2013) Housing availability and
affordability - Young families’ experiences of the local housing market in the study areas also indicated
that the current planning system was considered too regulatory and rigid, and often hindered the
development of simple solutions to rural housing needs.
The Experiences and Aspirations of Young People in Rural Wales (2013): Access to the decisionmaking
process - There is growing awareness and interest among the public and policy-makers of the
important and critical role that young people play in forming and sustaining sustainable communities.
This is particularly crucial in terms of rural communities, where the ageing population trend is
particularly marked and where there has been a steady decline in the proportion of the younger
population. Despite this, young people are too often excluded from the decision-making process.
Observations:
• The conclusion of this study summarises the issues faced in our rural communities. Although this
study was published in 2013 there is no evidence that these conclusions are considered in the
development of planning policies.
SUMMARY OF CONSIDERATIONS IN RESPECT OF THE SECOND REVISED LOCAL DEVELOPMENT PLAN
1. The Plan looks at rural communities from the outside. There is no recognition of the living,
breathing, day-to-day rural village. The Plan needs to reverse its perspective.
2. The needs of real people are secondary to ideas, policies, regulations and planning
aspirations. The needs of rural families should be the primary consideration.
3. The projected image of the countryside takes priority over the people who live in it. The
people who create, enhance, protect and conserve this image should be heard.
4. Prohibiting development in many rural communities is contrary to the planning presumption
to permit reasonable development in other geographic or demographic areas. The planning
presumption should be applied consistently across all areas.
5. The Plan does not consider the needs of local people who do not fit the Local Needs criteria.
Young professionals – teachers, nurses - who are not first-time buyers do not qualify for
Affordable Housing but can’t afford open market houses in their rural villages. The Plan
should apply the needs of the community as a material consideration and provide for all
young families.
6. Ordinary circumstances in urban areas are considered exceptional in rural areas. The Plan
should not mitigate against rural families and young people.
7. The social and economic benefits of small rural businesses are outweighed by the
requirement to project a particular image of the countryside. Small rural businesses are part
of the culture and inheritance of the countryside and should be encouraged within the Plan.
8. The Plan provides for projected damage to the Welsh language and culture in future
developments. It does not provide for the development of the Welsh language and culture
in its existing strongholds. The Plan is reactive to Welsh-language issues, not proactive. The
rural policies within the Plan should emanate from the Welsh-language strongholds to
achieve CYMRAEG 2050.
9. The Plan prioritises the visitor economy over local needs in rural communities. The tourist,
throughout the year, may eat, sleep and breathe the open countryside, but the local
resident may not. The Plan should provide for parity of opportunity between all rural
enterprises.
10. Amended Planning Use Classes (2022) requires that planning permission is needed to change
a residential dwelling to a holiday/second home. It will take many years for this amendment
to impact on rural house prices and availablity. The Plan should consider applying flexibility
while these factors bring some equity to housing availability in rural areas.
11. Placemaking and Sustainable Places policies are imposed on rural villages. The policies
should be formulated from the inside outwards, not the outside inwards.
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12. Active Travel and other Carbon Net Zero requirements prohibit residential dwellings in rural
areas. The Plan excuses the visitor industry from similar carbon footprints. The Plan should
apply the same standards to residents and visitors alike and encourage both to work side by
side to reach targets.
13. The requirements for Rural Enterprise Dwellings are practically impossible to meet. This
does not conform with aspirations for sustainable rural communities. The requirements for
ALL residential dwellings across rural areas should be applied equally.
14. Any initiative inside or outside village development boundaries which could benefit local
residents is likely to be prohibited. Strengthening communities should be a material
consideration when assessing local initiatives.
15. Villages without settlement boundaries will not be able to accommodate the needs of their
own residents. The Plan must provide opportunities for such communities to flourish.
Rural villages are not Still Photographs.
They create, motivate, initiate, provide and support like any other community.
It is imperative that the Future Wales National Plan 2040 and the Carmarthenshire Local Development
Plan 2018 – 2033 acknowledge and respect the identity and function of our rural communities.
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Compiled and submitted by Plaid Cymru County Councillors, Cyngor Sir Gâr – April 2023
Cyng. Liam Bowen Cyng. Kim Broom
Cyng. Mansel Charles Cyng. Andrew Davies
Cyng. Bryan Davies Cyng. Ann Davies
Cyng. Glynog Davies Cyng. Handel Davies
Cyng. Karen Davies Cyng. Llinos Mai Davies
Cyng. Terry Davies Cyng. Arwel Davies
Cyng. Alex Evans Cyng. Colin Evans
Cyng. Hazel Evans Cyng. Linda Evans
Cyng. Tyssul Evans Cyng. Deian Harries
Cyng. Ken Howell Cyng. Peter Hughes Griffiths
Cyng. Meinir James Cyng. Gareth John
Cyng. Carys Jones Cyng. Betsan Jones
Cyng. Hefin Jones Cyng. Alun Lenny
Cyng. Jean Lewis Cyng. Neil Lewis
Cyng. Dai Nicholas Cyng. Aled Vaughan Owen
Cyng. Denise Owen Cyng. Dorian Phillips
Cyng. Darren Price Cyng. Emlyn Schiavone
Cyng. Russell Sparks Cyng. Dai Thomas
Cyng. Gareth Thomas Cyng. Elwyn Williams
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LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
APPENDIX
Many elements of our planning system create complex dilemmas for Local Members and particularly for
Planning Committee Members when performing our roles and respecting our responsibilities:
• The role of the Local Member is to make the ward community a better place to live and work – to
improve quality of life and to develop and support plans which enhance and protect the
community, the environment and our future generations.
• The responsibility of the Local Planning Member is to observe the legislation, regulations and
guidance which are set down on our behalf to maintain Order within our communities, the Local
Authority and beyond.
The conflict between Members’ roles and Planning Members’ responsibilities gives rise to situations
where councillors are forced to compromise one in favour of the other. The Local Member is regularly
faced with two options:
• To support officers’ recommendations which are damaging to their own community in order to
conform with legislation, or
• To reject officers’ recommendations and act contrary to legislation in order to protect their
residents’ well-being.
It is not possible to reconcile this conflict under current planning policies.

Newid fel y nodir
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Change as set out

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

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

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

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

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

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

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

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

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

Amend Plan

Whilst I fully agree with the proposals submitted by my colleague and fellow Councillor Carys Jones, I wish to submit that the allocation proposed for Drefach Felindre is limited and inadequate for the next ten years. In particular, the allocation of only three houses on the Waugilwen road should be doubled to six, which would accommodate future expansion of the village.

Submissions by Carys Jones - dealt with in another representation

Amend the Plan

Whilst I fully agree with the proposals submitted by my colleague and fellow Councillor Carys Jones, I wish to submit that the allocation proposed for Drefach Felindre is limited and inadequate for the next ten years. In particular, the allocation of only three houses on the Waugilwen road should be doubled to six, which would accommodate future expansion of the village.

Submissions by Carys Jones - dealt with in another representation

Amend Plan

Whilst I fully agree with the proposals submitted by my colleague and fellow Councillor Carys Jones, I wish to submit that the allocation proposed for Drefach Felindre is limited and inadequate for the next ten years. In particular, the allocation of only three houses on the Waugilwen road should be doubled to six, which would accommodate future expansion of the village.

Submissions by Carys Jones - dealt with in another representation