EME3: Cynigion Cyflogaeth ar Safleoedd Dyranedig

Include the site as an employment allocation within the RLDP.

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Mrs N Andreu and Mr A Davies to
prepare and submit an Alternative Allocation Report for the allocation of land at
adjoining Cillefwr Industrial Estate, Carmarthen for the purposes of employment
related development in the forthcoming replacement Carmarthenshire Local
Development Plan (LDP).
1.2 This statement has been prepared in line with the Authority’s published site
assessment and selection documents. The contents of this Statement therefore
address each point raised within these documents as well as ensuring that it
complies with regards to the guidance and requirements of Planning Policy Wales
(Edition 11) when it comes to the preparation of development plans and the allocation
of land for residential purposes as part of them.
1.3 The contents of this Statement therefore provide a comprehensive case for the
allocation of the land for residential development purposes, and it should also be
read in conjunction with the accompanying information and indicative drawing
package, as well as a sustainability assessment undertaken in-line with the
Authority’s requirements.

2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Candidate Site relates to a parcel of land measuring approximately 4.7 acres in
area, edged red on the plan and image below.
Plan A
Photograph 1
2.1.2 The Site currently consists of two parcels of level land, currently laid to grass, as can
be seen from the photograph below.
Photograph 2
2.1.3 Within the Site are a line of mature trees, which form part of the boundary treatment
between the two parcels of the Site. Further trees are then found along the Site’s
edges, contributing towards its boundary treatment together with stock proof fencing.
Just beyond its boundaries then lies the A40 trunk road to the north, St Clears Road
along its western boundary and the Carmarthen to Tenby rail line along its southern
boundary. Its remaining western boundary is then shared a small strip of woodland
owned by our Clients, with a further parcel of grazing land located beyond it.
2.1.4 Access to the Site is gained directly off St Clears Road via an existing gateway and
access ramp into the Site. As illustrated by the photographs below, visibility in both
directions at this point is good.
Photograph 3 Photograph 4
2.1.5 Under the provisions of the current Carmarthenshire LDP, the Site presently forms
part of the larger ‘West Carmarthen’ strategic site allocation, as illustrated below.
Plan B
2.1.6 The LDP Written Statement sets out that the allocation was expected to deliver a mix
of uses, including residential and employment related development. The Written
Statement is then supported by a comprehensive Supplementary Planning Guidance
document, within which two areas are indicated as being earmarked for employment
development – land shaded purple and hatched red (our Clients land) – as illustrated
in the plan below.
Plan C
2.1.7 As can be seen, the Alternative Allocation is well related to the existing and proposed
development form of the adjoining urban area and therefore continues to represent a
natural and logical location for the settlement’s expansion.
2.2 THE ADJOINING SETTLEMENT
2.2.1 As detailed above, the Alternative Allocation adjoins the existing built form of the
settlement of Carmarthen. Adjoining both its northern and southern boundaries are
two of the Town’s key transport arteries, with existing residential and employment
development beyond them.
2.2.2 Due to this position and close association with the existing built form, the Alternative
Allocation has excellent access to the range of community facilities and local services
the settlement of Carmarthen has to offer, with a number being within walking
distance of the Site. In addition, the Site is positioned directly off a key transport node
of the A40 Trunk Road, providing access to and from it in both an immediate and
regional sense.
2.2.3 This excellent level of accessibility is further heightened by the fact that there is a
Parc and Ride facility a short distance to the west of the Site, as well as a number of
bus stops served regularly by services providing access to the Town Centre and
beyond. The strong sustainable position of the Alternative Allocation should therefore
be given full consideration when considering potential future growth options.
2.2.4 In terms of planned growth, the proposed Alternative Allocation forms part of one of
the 3 identified Principal Centres within the 2nd Deposit LDP, in fact its largest -
Carmarthen. Within these areas, the majority of the County’s growth (particularly with
regards to employment) is expected to be accommodated within the Plan period.
2.2.5 Having undertaken a comprehensive review of the proposed allocations put forward
by the 2nd Deposit LDP for the Principal Centre in question, as well as those sites
currently allocated for employment development in the current LDP, we have
identified a number of significant concerns. The table below therefore provides details
of the current and proposed allocations for new employment development.
Current LDP 2nd Deposit LDP
Site
Reference Site Name
Site
Area
(Ha)
Site
Reference Site Name
Site
Area
(Ha)
GA1/E1 Cillefwr Industrial Estate 4.38 PrC1/E1 (i) LandWest of Cillefwr Road 2
GA1/MU1 West Carmarthen 5.45 PrC1/E1 (ii) Land North of Alltycnap Road 1.215
GA1/MU2 Pibwrlwyd 15.5 PrC1/E1 (iii) Land South of Alltycnap Road 0.952
PrC1/MU1 West Carmarthen 4.53
PrC1/MU2 Pibrlwyd 8.95
PrC1/SS1 Yr Egin 1.04
Total: 25.33 Total: 18.687
Table 1
2.2.6 The first and most concerning issue highlighted from the above figures is that the
Replacement LDP proposes that the land available for employment development
purposes and so economic growth in Carmarthen Town during the Plan period be
reduced by almost 7ha – over 25% compared to current provision. This is a
significant reduction from the role the County Town was considered to have in the
County’s economy since the adoption of the current LDP, despite the Town’s current
population and the Replacement LDPs aspirations for its growth. This imbalance is
clearly unsustainable.
2.2.7 The above is of further concern when the overall allocation of employment land within
the County is considered. Under the provisions of Policy SP 7, the 2nd Deposit LDP
advises that 71.21 ha of land is to be allocated within the County during the Plan
period for employment development purposes. As a result and despite its strategic
and sustainable position, approximately only 25% of the total land allocated in the
Replacement LDP is to positioned within the County Town. This imbalance again is
clearly unsustainable, particularly when its sustainable transport attributes are taken
into consideration.
2.2.8 As a result of the above, it is considered that further land such as the Site owned by
our Clients should be allocated for employment development purposes to address the
above highlighted imbalance, to ensure the Plan can be regarded as being ‘sound’.

3.0 THE PROPOSAL
3.0.1 As part of the requirements for the promotion of sites for employment development,
this Statement is accompanied by an indicative layout for a potential employment
development scheme that could be developed on the site. It should be emphasised
that the accompanying layout is for illustrative purposes and that other design
solutions for the site could also be reached. Notwithstanding this, the accompanying
layout drawing has taken account of all the potential assets and constraints of the
site, as well as current Authority design guidance, and demonstrates that it is capable
of delivering a mix of units in a deliverable and sustainable manner. The following
information therefore expands on this principle.
3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Candidate Site be allocated in the forthcoming replacement
LDP for the purposes of employment development, together with areas to be retained
and managed for biodiversity enhancement purposes. As a result, the accompanying
illustrative layout (reproduced below) demonstrates that the Site is capable of
accommodating a range of new employment units to serve a variety of B1, B2 and B8
end-users, as well as its biodiversity assets.
Plan D
3.1.2 As illustrated above, the Site is capable of accommodating a mix of unit sizes and
types, ensuring that it is responsive to all existing and future needs of the businesses
in the local and wider area.
3.1.3 With regards then to access, the existing point off St Clears Road will be utilised and
altered if required. From this then, a new access road will be constructed to serve the
Site as a whole.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Any development of the Candidate Site for employment units would be served by
mains water, public sewer and electricity, connections to which we understand lie
within or in close proximity to the Site.
3.2.2 With regards then to surface water, it is considered that as a result of on-site
features, there would be a number of options available to any development of the site
in terms of its disposal, ensuring its development adheres to current regulatory
requirements.

4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 Any potential biodiversity assets the Site may include have been given full
consideration with regards to exploring its potential for employment development.
This has included the proposed retention and management of existing site boundary
features.
4.1.2 The Alternative Site has been assessed against data held on the “Magic” website
which details statutory and non-statutory National and Local sites of ecological
importance. Plan E below provides an extract of those records applied to the
Carmarthen locality. The red star denotes the position of the Alternative Site.
Plan E
4.1.3 As can be seen from the above, the Alternative Allocation does not form part of and
neither is it near any national or local designations. The nearest designation is the
River Tywi SSSI/SAC, but due to the intervening distance and topography, the
development of the Alternative Alocation will not have any detrimental impact on this
feature.
4.2 HISTORICAL ASSETS
4.2.1 Below is an extract from the ‘Archwilio’ website that represents a resource for the
Historic Environment Records of Wales, with the Alternative Allocation indicated by a
red star.
Plan F
4.2.2 As can be seen, neither the Alternative Site nor immediately adjoining element of the
settlement includes any Scheduled Ancient Monuments, Listed Buildings or
Conservation Area’s. As a result, the development of the Site would not have any
detrimental impact on the setting or interest of any nearby historical asset.
4.3 ENVIRONMENTAL CONSTRAINTS
4.3.1 The area of the Alternative Allocation would not include any elements at risk of
flooding in terms of the Development Advice Maps or those produced by Natural
Resources Wales, as illustrated by the plans below (Alternative Allocation indicated
by the red star).
Plan G
(Development Advice Maps)
Plan H
(Flood Maps for Planning)
4.3.2 Due to its greenfield nature, the Alternative Allocation has no ground contamination
related constraints.

5.0 NATIONAL PLANNING POLICY CONSIDERATIONS
5.0.1 In the preparation of any development plan, consideration must be given to national
policy and guidance. At present, this takes the form of Planning Policy Wales (PPW)
(Edition 11) and a series of Technical Advice Notes (TAN) that deal with a range of
topic areas.
5.1 EMPLOYMENT LAND SUPPLY
5.1.1 With regards to the provision of land for employment use, Paragraph 5.4.1 of PPW
sets out that “The planning system should ensure that the growth of output and
employment in Wales as a whole is not constrained by a shortage of land for
economic use.”. Paragraph 5.4.3 goes on then to require that:
“Planning authorities should support the provision of sufficient land to meet the needs
of the employment market at both a strategic and local level. Development plans
should identify employment land requirements, allocate an appropriate mix of sites to
meet need and provide a framework for the protection of existing employment sites.”.
5.1.2 As detailed in previous sections of this Statement, the Replacement LDP proposes a
significant reduction in the level of land available to accommodate employment
development in the Town of Carmarthen during the Plan period. On a local level, the
Replacement LDP proposes a significant growth in the Town’s population through the
proposed housing allocations. However, and despite this, the same document
proposes a reduction of over 25% of the land available for new job opportunities to
this new element of its population.
5.1.3 From a wider and more strategic perspective, Carmarthen represents the County’s
principal settlement that has a range of transport links to all areas of the County, the
M4 corridor and the key transport arteries to the commercial ports of Pembrokeshire.
Again, despite these sustainable attributes, only 25% of the total land allocated for
employment development in the County is proposed to be located at Carmarthen.
5.1.4 The above imbalances are clearly at odds with the guidance and objectives of
national planning policy in terms of both local and national growth. In contrast and
quite clearly, the allocation of the Alternative Allocation for employment development
would help address these imbalances, through the provision of a deliverable and
sustainable new source of economic land.

6.0 CONCLUSION
6.1 Although currently undeveloped, the Alternative Allocation forms a logical extension
to an existing settlement, being well related to it and being positioned at a location
within the wider landscape to not form a prominent or logical part of the surrounding
open countryside.
6.2 In addition to the above, the Site lies on part of the County Borough’s key
transportation network and is accessible not only by private vehicle, but also by the
regularly served public transport network. This provides it with a good level of access
for potential customers and employees from the settlement of Carmarthen, as well as
those further afield, ensuring therefore that the Alternative Allocation will make a
positive contribution to both national and local sustainable development objectives.
6.3 In tandem to the above, the development of the Site will also address the imbalances
in employment land provision identified in this report, not only in terms of the local
area, but also in terms of a County wide perspective. Carmarthen represents the
County’s key settlement, but the current employment land provisions are not
capitalising or strengthening this role, in direct conflict therefore with the objectives of
the Replacement LDP.
6.4 With the Alternative Allocation having no access, ground condition, flood risk,
hydrological, ecological, archaeological or land ownership related constraints, its
delivery if allocated is assured. Combined therefore with its locational characteristics,
the Site in question represents a sustainable candidate for future employment
development.
6.5 In view of the above and information provided in this Statement, it is respectfully
requested that the Alternative Allocation in question be designated for employment
development.

Include site within the plan.

Dear Forward Planning Manager,

I am writing to you with regards to the second deposit Carmarthenshire LDP.

I note the revised plan reduces the number employment areas around Carmarthen, in particular, the site referred to in the attached.

Aside from the fact that when building a large number of domestic dwellings it makes obvious sense to also build facilities for employment, the fact that this area is so conveniently close to such a populated area means it not only has the potential to greatly improve peoples lives in so many ways but also has the incredible benefit of Carbon emissions from travel being greatly reduced. I know that the Welsh government are extremely committed to Carbon reduction.

Please find attached some comments which I absolutely subscribe to and would very much like you to read. Many people have spoken to me about this voicing their concerns, it clearly is causing some strength of feeling.

How can it make sense to force yet more people to commute to Cross Hands, Swansea and Cardiff? We should be focusing on making West Carmarthen an employment hub to sustain local people.

See attached supporting document for further statement.

Include Marelli Land as part of the employment allocation PrC2/E2(i)

A Deposit Revised LDP Representation was made on 01/10/20 to include land in the ownership of the Welsh Government (WG) and adjoining land in the ownership of Calsonic Kansei (Now Marelli) to be allocated as employment land. The land in the ownership of WG is shown as proposed employment land in the 2nd Deposit Revised Carmarthenshire Local Development Plan 2018-2033. However, the Marelli Land is not. This representation is for the Marelli land to be also allocated for employment use.
WG own the freehold interest in an undeveloped site of circa 12 acres situated on the Dafen Industrial Park, Llanelli, an established commercial/industrial location. In 2022, surveys and ground investigation works were undertaken with the aim of preparing a master plan and a planning application. This landholding adjoins a further undeveloped site to the north under the ownership of Marelli (as shown edged red on the first attached plan). Together, the two sites (totalling approximately 25 acres, (shown edged red on the second attached plan) lie on the edge of the existing and proposed employment areas at Dafen Industrial Park, comprising approx. 56 acres of B1, B2 and B8 allocated land, the vast majority of which is developed.
Dafen Industrial Park is considered a sustainable location, situated approximately 1 mile to the North East of Llanelli Town Centre and is easily accessed via Llethri Road, which links to the A4138 and in turn to the M4 motorway via junction 48. It
accommodates a range of established occupiers including Marelli, Prima Foods
UK and Yodel.
The Welsh Governments Property Development Plan (PDP) recognises that there
is a shortage of readily available sites for industrial/commercial development
throughout Wales and considers that the Marelli (in addition to the WG land)
should be allocated for development within the emerging Carmarthenshire LDP
for B1, B2 and B8 use.
The PDP seeks to deliver approximately 1.6 million sq. ft. of new premises and
450 acres of investment ready employment sites across Wales over the next
seven years. WG consider that this site would make a valuable contribution to the
overall employment land supply required to achieve the PDP’s overarching
objectives.
In addition to the Investment already being made to being forward the WG land for
employment use, WG has commenced negotiations to acquire the Marelli land.
Following acquisition, it aims to undertake surveys and ground investination works
on this land, in the same way that has already occured on the WG land. This
would allow a master plan to be prepared for the two areas and ensure that the
development layout better accommodates development on the two areas.
Policy 28 of Future Wales (the National Plan for Wales) sets out that Swansea Bay
and Llanelli is a National Growth Area, with text highlighting that “Local
Development Plans should recognise the National Growth Area as the focus for
strategic economic and housing growth”. This is also recognised in Strategic Policy
1 of the Deposit LDP.
In summary, WG considers that the Marelli land represents a suitable and
sustainable location for development. Development on this site will strive to meet
the goals of of the WBFGA and policy 28 of Future Wales. The site is also
considered to align with key objectives of WG’s PDP and therefore will meet the
requirements for appropriate WG funding required to provide the necessary site
infrastructure for future private and public sector commercial /industrial
investment. As such, WG considers its proposals for this site are viable and
deliverable within the next Plan period and would meet all the tests for soundness
required for inclusion within the LDP.

Include the site as an employment allocation within the LDP.

New Site Allocation – Former Penybont Farm, Cwmann
Please find enclosed, on behalf of and under instruction from our client, Datblygau Davies Developments, a detailed Site Representation, submitted to Carmarthenshire County Council for consideration for inclusion within the 2nd Revised Local Development Plan (LDP).
The site has not previously been submitted as a Candidate Site, and therefore these representations seek for the site to be included as a new employment allocation within the Revised LDP. Accordingly, an objection is also made to the Deposit Plan on the basis that the site is not included, and we would therefore request to be heard by the Inspector at Examination.
To enter the site for evaluation as a new allocation within the Plan preparation process, the following documentation is enclosed with this submission:
• Completed Representations Form;
• Site Location Plan (ref. LP01);
• Illustrative Layout (ref. A1 LA); and
• Flood Consequences Assessment (May 2018).
In addition to the enclosed documentation, a detailed case for the site’s allocation within the Revised LDP as an employment allocation is provided in the Addendum below - which is requested to be carefully and thoroughly taken into consideration in appraising the site’s credentials for inclusion within the new Plan.
In the absence of any methodology for the assessment of new allocations, we have reverted to the criteria and methodology outlined within the Site Assessment Methodology (September 2022). This outlines that the appraisal process consists of multiple stages, summarised as the following:
Carmarthenshire 2nd Revised Local Development Plan April 2023
Deposit Plan Representations
New Site Allocation – Former Penybont Farm, Cwmann Page 2 of 15 • Stage 1 – Initial Site Assessment
• Stage 2 – Detailed Site Assessment
o Stage 2a – Deliverability & Fundamental Constraints
o Stage 2b – Further Detailed Analysis of Sites
• Stage 3 – ISA & HRA
The representations have been structured to respond to the pertinent questions of Stages 1 and 2, in addition to provide a preliminary assessment against Stage 3, in order to evidence the suitability of the site as an employment allocation. It is considered that the site would make a valuable contribution to housing land supply within the County.
We look forward to hearing from you in due course. In the meantime, we hope and trust that all is in order with this submission. Please do not hesitate to contact us in the event that further information is required or considered beneficial.
Yours sincerely
Geraint John
Director
Geraint John Planning Ltd
Carmarthenshire 2nd Revised Local Development Plan April 2023
Deposit Plan Representations
New Site Allocation – Former Penybont Farm, Cwmann Page 3 of 15 Preface
The site is a parcel of previously developed land, approximately 1.5 hectares in size, located adjacent to the settlement of Cwmann at the intersection between the A485 and A482. The site formerly contained a farm house and outbuildings associated with Penybont Farm, but is now vacant, comprising an area of hardstanding and benefitting from existing access from the A485 (associated with planning permission ref. TMT/02448).
Aerial view of site
Street view of site and existing access
Carmarthenshire 2nd Revised Local Development Plan April 2023
Deposit Plan Representations
New Site Allocation – Former Penybont Farm, Cwmann Page 4 of 15 Part of the site is subject to several planning permissions for non-residential use, as summarised in the table below. Permission ref. TMT/0244 has been implemented through formation of the aforementioned site access and creation of hardstanding areas and footings, and remains extant as a result.
Application Ref Site Name Site Description Decision Decision Date
W/01002
Site of Former Penybont Farm, Cwmann, Carmarthenshire.
Service Station including forecourt sales building, petrol pumps and canopy, car wash bay and jet wash bay.
Approved
24/11/1997
TMT/02448
Site of Former Penybont Farm, Cwmann, Carmarthenshire.
Service Station including forecourt sales building, petrol pumps and canopy car wash & jet wash bay, renewal of W/01002.
Approved
21/11/2002
W/31378
Site of former Penybont Farm, Carmarthen Road, Cwmann, Carmarthenshire.
Proposed siting of a Neighbourhood Retail Convenience Store (Amendment to Planning Permission TMT/02448)
Approved
30/06/2022
The settlement of Cwmann is primarily residential, albeit also contains some retail and business premises, including the cluster of units located immediately to the east of the site. To the south and south-west of the site are residential dwellings and a former public house, and to the north and west are agricultural fields. The town of Lampeter is located less than 1 km to the north of the site, and contains a variety of facilities and services, including employment, education and retail uses.
A land use plan is provided below which shows the location of the site in respect of other principal non-residential uses (i.e. commercial / business / retail / employment premises):
Land use plan
Carmarthenshire 2nd Revised Local Development Plan April 2023
Deposit Plan Representations
New Site Allocation – Former Penybont Farm, Cwmann Page 5 of 15 Given its location adjacent to Cwmann and in close proximity to Lampeter, the site is located in both a sustainable and accessible location, being situated on two primary highway networks routes – the A482 and A485. The site is also readily accessible on foot via a wide footway which provides a continuous route to both Cwmann and Lampeter. Additionally, there are two bus stops within 100m of the site, which are serviced by two of the main bus services in the locality – number ‘585’, which provides services to Carmarthen, and the ‘T1’, providing regular services to Aberystwyth and Carmarthen via Lampeter.
New Site Allocation Representations
Stage 1 – Initial Site Assessment
Q1. Is the site compatible against the location of future growth presented in the Preferred Strategy.
The location of the site directly relates to a settlement identified as a Sustainable Village (Tier 3) within the Deposit Plan. The Plan seeks to apportion growth largely to the Tier 1-3 settlements. Whilst the Plan sets out a preference for residential development within the Tier 3 settlements, the site comprises previously development land which benefits from planning permissions (refs. TMT/02488 and W/31378) for non-residential use. As such, the development of non-residential use at this location is acceptable in principle. Moreover, as illustrated on the extract of the Proposals Map and Site Location Plan overleaf, the site has a clear physical relationship with Cwmann, and as such is located within a sustainable location.
Given the above, it is considered that the proposed allocation of the site for employment is compatible with the growth strategy, and specific consideration should be given to its inclusion as part of the Plan preparation accordingly.
Deposit LDP Proposals Map
Carmarthenshire 2nd Revised Local Development Plan April 2023
Deposit Plan Representations
New Site Allocation – Former Penybont Farm, Cwmann Page 6 of 15 Extract of Site Location Plan
Stage 2 – Detailed Site Assessment
Stage 2a – Deliverability & Fundamental Constraints
Q2. Can the site accommodate 5 or more dwellings?
The site is proposed for employment use, and comprises a total area of circa 1.5 hectares. As demonstrated by the submitted Illustrative Layout, the site can comfortably accommodate 23,000 sq ft of floorspace, along with access and parking, drainage and Green Infrastructure, with scope for future development. As such, the site is considered to be sufficient in size to be considered as an Alternative Site.
Q3. Is the site within, or directly relates to an identified settlement in Tiers 1-3 of the LDP Preferred Strategy?
Yes – as outlined above in greater detail, the site is located immediately adjoining the Tier 3 (Sustainable Villages) settlement of Cwmann.
Q4. Is the site located within a flood risk zone as identified in the TAN 15 Development Advice Maps (DAMs)?
The site is entirely contained within Flood Zone C2 on the Development Advice Map. However, the site is contained within Flood Zone 3 and Flood Zone 2 on the New Flood Map for Planning, which represents the latest flood risk modelling.
Carmarthenshire 2nd Revised Local Development Plan April 2023
Deposit Plan Representations
New Site Allocation – Former Penybont Farm, Cwmann Page 7 of 15 NRW Development Advice Map
NRW New Flood Map for Planning
The site has extant planning permission for a service station (ref. TMT/02448) and recent planning permission for a convenience store (ref. W/31378). A Flood Consequences Assessment (May 2018) by Francis Sant was submitted in support of ref. W/31378, in addition to extensive flood modelling work and dialogue held with Natural Resources Wales (NRW). The FCA set out the following conclusions:
Carmarthenshire 2nd Revised Local Development Plan April 2023
Deposit Plan Representations
New Site Allocation – Former Penybont Farm, Cwmann Page 8 of 15 ‘NRW's 2D hydraulic model suggest that part of the site is expected to remain flood free even during the Q1000 event although part of the site could be at risk during the Q100 event. To ensure that the site remains flood free during all considered events it is proposed to raise the site levels. To evaluate the impact the NRW TUFLOW model was obtained, amended, and ran with and without the scheme in place. Modelling showed that this had no detrimental impact on third parties (impact on flood depth less than 5mm). A flood free access from the site is also expected during the considered events.
The development is not expected to be at risk from tidal, surface water, or ground water flooding. It's also not expected to be at risk from reservoir failure.
A summary of the adherence of the development with the requirements of Section 7 and Appendix A1 of TAN 15 is summarised in Table 5.1.’
In summary, the FCA confirms that the proposed ‘use’ would not be highly vulnerable, and that the site is not expected to be at risk during any events. Flood proofing measures, as outlined within the FCA, would be adopted nonetheless, to protect the proposed development and ensure no wider flooding impacts.
NRW were ultimately satisfied with the findings of the FCA and that the proposals for a less vulnerable use would be acceptable in this location on flood risk grounds, with the adoption of mitigatory measures. Important to note is that this conclusion was drawn prior to consideration of the lesser flood risk indicated on the New Flood Map for Planning, which is to be adopted in the near future.
Given the above, it is not considered that flood risk represents an insurmountable constraint to development of the site, not least as it benefits from an extant and recent planning permissions. Notwithstanding this, a FCA would be submitted with any planning application.
Q5. Is the site located within or immediately adjacent to any sites for importance to nature conservation?
No – the site is not located within or immediately adjacent to any sites for importance to nature conservation, as corroborated by the interactive Constraints Map.
Q6. Is the site located within or immediately adjacent to any Scheduled Monuments?
No – review of Historic Wales mapping database shows that there are no Scheduled Ancient Monuments or Listed Buildings on or within the vicinity of the site.
Carmarthenshire 2nd Revised Local Development Plan April 2023
Deposit Plan Representations
New Site Allocation – Former Penybont Farm, Cwmann Page 9 of 15 The mapping does identify a Historic Environment Record on the site – the former Pen-Y-Bont Farmstead, albeit this has historically been demolished. As such, it is not considered that there are any heritage constraints to development.
Historic Wales mapping
Stage 2b – Further Detailed Analysis of Sites
Q7. Would development of the site be contrary to general planning principles?
The site represents a logical and proportional extension to the settlement boundary, being located immediately adjacent to the existing settlement limits of Cwmann. Whilst located within the ‘countryside’, the site is not subject to a Green Wedge designation, and as such development in this location would not lead to any coalescence of settlements. Moreover, the site comprises part previously developed land, which is preferred to greenfield in PPW11. On this basis, the site location is considered to conform with general planning principles.
Q8. Would development of the site result in detrimental impact on the character and setting of the settlement or its feature?
The site is not located within a designated landscape protection area (for example, Special Landscape Area), or within a Conservation Area or settlement with particular architectural merit. Being previously developed, the site has historically contained built form and therefore development in this location would not be out of character with the site and surrounds. Views of the site from the east, south and west are largely limited due to development and vegetation, whilst from the north and north-east, the site is viewed within the context of the existing built form. Accordingly, it is considered that with sensitive development, there would be no detrimental impact on the character or setting of Cwmann.
Q9. Will the proposal involve the re-use of suitable previously developed land/buildings?
Yes – the site comprises previously developed land – the former Penybont Farmhouse and outbuildings, which have been demolished historically. The site is now vacant, and occupied by a piece of hardstanding, representing an underused parcel of brownfield land.
Carmarthenshire 2nd Revised Local Development Plan April 2023
Deposit Plan Representations
New Site Allocation – Former Penybont Farm, Cwmann Page 10 of 15 Q10. Is the site accessible from the existing public highway?
Q11. Does the site have an available access point with adequate visibility?
Q12. Have any significant and evidenced highway issues been identified relating to the site?
A joint response is here provided to Qs. 10-12. The site benefits from an existing high-spec access from the A485, which was approved under planning permission ref. TMT/02448, and would be retained as part of any development proposals, in addition to consideration of a potential secondary access. The access has adequate visibility to the east and west, and is located sufficient distance from the junction with the A482.
The suitability of the existing access was assessed by the Local Highways Authority at the time of application, and was deemed to be acceptable on highways safety grounds. The proposed employment use would see lesser vehicle movements from the approved service station and retail store, and as such is considered to have capacity to accommodate development without any issues. A new transport assessment or similar would form part of any future planning application.
Q13. Does the site have a suitable access to public transport and/or active travel route?
The site is readily accessible on foot via a wide footway which provides a continuous route to both Cwmann and Lampeter. In terms of public transport, there is a bus stop located circa 50m to the existing entrance to the site, which is serviced by one of the main bus services in the locality – number ‘585’, which provides services to Carmarthen. There is another bus stop, approximately 70m to the south-west of the site, which is serviced by the ‘T1’, providing regular services to Aberystwyth and Carmarthen, via Lampeter. The site is therefore located within a sustainable location, and can be reasonably accessed via alternative means of transport to the public vehicle.
Q14. Is the site within a reasonable distance to areas of population and housing?
The site is located immediately adjacent to the settlement of Cwmann, within a residential and commercial mixed use area. Additionally, the site is located less than 1km from the town of Lampeter, and as such, has an accessible and sizeable employment pool.
Q17. Is the site located within or adjacent to a mineral buffer zone?
No – the LDP Constraints Map does not show that the site is located within or adjacent to a mineral buffer zone.
Q18. Is the site located within a Mineral Safeguarding Area?
The LDP Constraints Map indicates that the site lies within a Sandstone and Igneous Safeguarding Category 1 area. This is not considered to be a fundamental constraint to development as the resource is unlikely to be viable to extract, given the prior use of the site and proximity to existing residential properties.
Carmarthenshire 2nd Revised Local Development Plan April 2023
Deposit Plan Representations
New Site Allocation – Former Penybont Farm, Cwmann Page 11 of 15 LDP Constraints Map
Q19. Is the site within or immediately adjacent to an Air Quality Management Area (AQMA)?
No – the site is not located within or immediately adjacent to an AQMA, or an area affected by poor air quality.
Q20. Does the site contain high carbon soil e.g., peatlands?
The site is not known or thought to contain any high carbon soil, and this was not raised as an issue at the prior planning permissions.
Q21. Does the site contain high quality agricultural land (grade 1, 2, 3a)?
The Lle Agricultural Land Classification map site is partly classified as ‘urban’, and partly as ‘Grade 3a’. As such, the site does not contain any of the highest grade ‘Best and Most Versatile’ land. Moreover, the site (excluding the hardstanding) is currently only used for grazing, and therefore its development will not result in the loss of active agricultural land used for delivering crops for food and non-food uses.
LLE Aricutlural Land Classification map
Carmarthenshire 2nd Revised Local Development Plan April 2023
Deposit Plan Representations
New Site Allocation – Former Penybont Farm, Cwmann Page 12 of 15 Q22. Is the site located within or immediately adjacent to any Regionally Geological and Geomorphological Sites?
No – the LDP Constraints Map does not show that the site is located within or adjacent to a Regionally Geological or Geomorphological Sites.
Q23. Are there are significant concerns set out in the SFCA (Strategic Flood Consequences Assessment) – Stage 1 which could impact on the delivery of the site?
Please refer to discussion further above under Q4. in respect of flood risk.
Q24. Does the site have an available water connection?
Yes – the site is expected to have readily available water connections, given its previously developed status. Dwr Cymru Welsh Water confirmed the ability to provide a water supply to the site through their consultation responses to application ref. W/31378, in which no objection was raised.
Q25. Is the site within or adjacent to a phosphate sensitive SAC catchment?
The site is located within a Phosphorus Sensitive SAC Freshwater Catchment area. However, it is located within an area compliant with Phosphorus targets.
NRW Compliance Assessment map
Carmarthenshire 2nd Revised Local Development Plan April 2023
Deposit Plan Representations
New Site Allocation – Former Penybont Farm, Cwmann Page 13 of 15 Q26. Does the site have connections to other infrastructure requirements?
Yes – the site is expected to have readily available electricity and other infrastructure connections, given its previously developed status. Moreover, infrastructure providers (namely, Dwr Cymru Welsh Water, and Wales and West Utilities) raised no objection to proposed development ref. W/31378.
Q27. Does the location and/or scale of the site have the potential to have a detrimental impact on Welsh Language?
It is not considered that development of the site would lead to any adverse impacts on the Welsh Language due to the nature and scale of the development. An employment site in this location would provide employment opportunities for local residents. Notwithstanding this, further assessment of any potential impact on the Welsh Language would be provided with any planning application, as deemed necessary by the LPA.
Q28. Has the applicant provided sufficient evidence to show the development is deliverable and financially viable?
The site is also available for development, and has had some speculative prospective occupier interest. The site promoter is willing and able to submit the necessary viability information to demonstrate the financial viability of the site upon request. It is not considered likely that there will be any unforeseen or abnormal costs associated with development of the site, particularly in respect of contamination as the site has been restored/remediated following its previous use.
Q29. Has the applicant provided sufficient evidence to identify when the site will be bought forward for development?
Further detail and confirmation of the delivery of the site in respect of the Plan period can be provided by the site promoter, however it is envisaged that the site would be brought forward for development in the short term. The site promoter is actively looking to make the necessary planning applications in order for the site to be developed at the earliest opportunity – as demonstrated by the recent planning permission.
Summary
It has been demonstrated above that there are no insurmountable constraints to development of the site, which would represent an appropriate employment site and extension of the settlement boundary. Moreover, the site comprises previously developed land and benefits from an existing extant permission for a non-residential use. As such, the site should be considered a ‘reasonable’ option, and should progress to the Stage 3 assessment accordingly.
Stage 3 – ISA and HRA
ISA (Integrated Sustainability Appraisal)
An assessment of the sites performance against the Stage 1 and 2 criteria, has been undertaken in the table overleaf. This seeks to provide an overview of the effect of development of the site in achieving the Plan’s Sustainability objective, although it is of course acknowledged that the LPA would need to undertake their own assessment.
Carmarthenshire 2nd Revised Local Development Plan April 2023
Deposit Plan Representations
New Site Allocation – Former Penybont Farm, Cwmann Page 14 of 15 Consideration Yes / No ISA Score Stage 1 – Initial Assessment
1. Is the site compatible against the location of future growth presented in the Preferred Strategy?
✓ + Stage 2a – Initial Detailed Site Assessment
2. Can the site accommodate 5 or more dwellings?
N/A
3. Is the site within or directly related to a Tier 1-3 settlement in the Preferred Strategy?
✓
4. Is the site located within a flood risk zone as identified in the TAN 15 Development Advice Maps?
✓ -
5. Is the site located within or immediately adjacent to any sites designated for importance to nature conservation?
X +
6. Is the site located within or immediately adjacent to any Scheduled Monuments?
X + Stage 2b – Further Detailed Site Assessment
7. Would development of the site be contrary to general planning principles?
X
8. Would development of the site result in detrimental impact on the character and setting of the settlement or its feature?
X +
9. Will the proposal involve the re-use of suitable previously developed land/buildings?
✓ +
10. Is the site accessible from the existing public highway?
✓
11. Does the site have an available access point with adequate visibility?
✓
12. Have any significant and evidenced highway issues been identified relating to the site?
✓
13. Does the site have a suitable access to public transport and/or active travel route?
✓ +
14. Is the site within a reasonable distance to areas of population and housing?
✓ +
17. Is the site located within or adjacent to a mineral buffer zone?
X +
18. Is the site located within a Mineral Safeguarding Area?
✓ -
19. Is the site within or immediately adjacent to an Air Quality Management Area (AQMA)?
X +
20. Does the site contain high carbon soil e.g., peatlands?
X +
21. Does the site contain high quality agricultural land (grade 1, 2, 3a)?
✓ -
22. Is the site located within or immediately adjacent to any Regionally Geological and Geomorphological Sites?
X +
23. Are there are significant concerns set out in the SFCA (Strategic Flood Consequences Assessment) – Stage 1 which could impact on the delivery of the site?
-
-
24. Does the site have an available water connection?
✓
25. Is the site within or adjacent to a phosphate sensitive SAC catchment?
✓ -
26. Does the site have connections to other infrastructure requirements?
✓
27. Does the location and/or scale of the site have the potential to have a detrimental impact on Welsh Language?
X +
28. Has the applicant provided sufficient evidence to show the development is deliverable and financially viable?
✓
29. Has the applicant provided sufficient evidence to identify when the site will be bought forward for development?
✓
Carmarthenshire 2nd Revised Local Development Plan April 2023
Deposit Plan Representations
New Site Allocation – Former Penybont Farm, Cwmann Page 15 of 15 It is evident that the site scores well against all but few criteria, as listed below:
• Flood Risk;
• Mineral Safeguarding;
• Agricultural Land Classification; and
• SAC Catchment
As has been demonstrated earlier within this report (namely, in response to Questions 4, 18, 21 and 25 respectively), these issues would not be insurmountable to delivery of the site. Moreover, that the flood risk can be suitably overcome, as per the extant planning permission. Detailed and technical evidence and assessment work would be submitted with any planning application to support this conclusion.
In summary, and on balance, the site clearly scores well against the pertinent site assessment criteria, and therefore complies with multiple sustainability Objectives.
HRA (Habitats Regulations Assessment)
It is acknowledged that the Stage 3 assessment involves screening by the LPA of all potential allocations for any likely significant effects (alone and in-combination) on any European Sites – as outlined within the Habitats Regulations Report (January 2020).
As set out elsewhere in this submission, the site is not located within or adjacent to any nature conservation designations, including European Sites. The River Teifi, which has a SAC designation, is located further to the north of the site, approximately 200m at its closest point. However, there are no water courses or estuaries which flow in/out of the site, which forms the basis for the generic level of screening, as set out in the Report. Additionally, whilst the site does lie within a Phosphorus Sensitive SAC Freshwater Catchment area, this is indicated by the NRW Compliance Assessment map to be compliant with Phosphorus targets.
Whilst the LPA may deem that the site would need to go undergo further assessment, for the reasons above, it is considered that initial screening would conclude no likely significant effects on the River Teifi SAC resulting from development of the site itself.
Conclusions
We consider that the site ‘performs’ well against the defined assessment criteria and methodology, with no evident insurmountable constraints, obstacles, or failings.
Our client would be happy to discuss any aspect of the submission made and credentials of the site when your Authority (and the appointed Inspector in turn) comes to evaluate matters.
We respectfully urge you, for the reasons given herein and in the associated submitted information, to include the site put forward within the emerging LDP for a new employment allocation.

Amend the Plan to include the site.

Site Ref: 026-017

Address:
Parc Yr Onnen (land part of Penybont Farm, Johnstown)
Traveller’s Rest,
Johnstown

Hectares: 2.51 (extending to 6 hectares in total with adjoining neighbouring land)

Proposed use of site: Mixed use/Employment area

The proposed development area (identified above) was included in the adopted Local Development Plan (LDP) 2006-2021 and also in the first deposit of the 2018 - 2033 LDP due to its potential to greatly enhance and promote the sustainable development of the West Carmarthen LDP. We feel strongly that this is still the case and should continue to be included in the second deposit either as an employment or mixed use area. The following demonstrates some of the benefits of why it should continue to be included.

Firstly, I would like to record my displeasure at the lack of communication regarding the revised 2nd deposit LDP with landowners. It was only by chance that this had come to my attention, one week before the closing date for public consultation and comments to be submitted.

This is a self contained area which would not require community infrastructure and occupies a key position that would assist in its marketing and have minimum impact on residential areas.

The West Carmarthen LDP proposes 1300 residential houses, many of which are being or have been built and with such large housing development must come opportunities for employment within easy reach in order to meet sustainability and climate change carbon reduction requirements.

The site in total spans 6 hectares and lends itself to meet the requirement of sustainability and climate change and has many positive aspects to promote this end. This area is within easy walking distance of the 1300 new houses and has opportunity of reducing carbon input due to its immediate proximity to residential areas while at the same time remaining separate to not create any negative impact. It has public transport serving the local community and Carmarthen town, passing along its boundaries.

In terms of access, it already possesses a highways standard road on the western side of the site, projecting into the site for approximately 70 meters. This access road is within a matter of a few 100 meters of the A40 dual carriageway which in turn brings you to the M4 motorway on the outskirts of Carmarthen.

Services are available at the eastern end of the site with electricity pylons already on site which could provide the required energy provisions.

As a mixed use area this could not only provide employment to current Welsh speaking population but could also provide some facilities to promote the Welsh language.

The land consists of brown earth, only used as grazing land. It is not highly productive but was suitable for growing grass for limited grazing purposes.

The small stream that passes through the area has been identified as not falling within flood zones 2 and 3 as per environment agency modelling and we have written confirmation from NRW. The land on both the western and eastern side of the stream rises quite rapidly at 20 meters either side, therefore any flood risk would be limited to small areas either side of the stream and would not be included in the main area to be developed. This can be accommodated within any detailed plan for the site.

The site is not located within or immediately adjacent to any sites designated for importance to Nature Conservation or Sites of Special Scientific Interest.

In conclusion, the site is highly compatible with the growth presented in the deposit LDP. In particular, it would provide employment opportunities within easy reach of the proposed west Carmarthen development scheme and thereby conform with the requirements of sustainability and climate change.

Any minimal flood risk and the high pressure gas pipe running through the site can be accommodated in any detailed plan for the area. Such an allocation would reinforce the employment provision and ensure a sustainable mixed use development is achieved. There could be no possible harm in its inclusion.

Include the site as an employment allocation within the LDP.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/031/002, seeking inclusion of their land for future residential and employment
development within the defined settlement limits of Cross Hands within the Replacement
Local Development Plan.
The Candidate Site comprises an undeveloped field enclosure set off the rear of a newly
formed operational yard at the rear of Continental Leisure Vehicles showrooms and service
garage at Heol Parc Mawr, upon the Cross Hands Business Park.
The Candidate Site aims to expand off the recently laid surfaced yard and expand the range
of employment opportunities in a north-east direction over undulated scrub land which
eventually reaches several hundred metres distant at the common rear boundary of
residential properties at Black Lion Road in Gorslas.
The 2018 Candidate Site proposed a mixed use of both employment and residential, with
both zones of use achieving vehicular access off the adjacent Cross Hands East Strategic
Employment Site (CHESES), via an extension of an estate road currently under formation as
part of the Phase 2 development of that neighbouring Council-owned site.
The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our clients’ submission, reasons why the site was not selected for inclusion within the draft
settlement limits of Cross Hands, as contained within the Deposit Draft.
We note that the submission successfully passed through the initial Assessment Stages,
being Stage 1 (site compatible against the location of future growth presented in the
Preferred Strategy), and Stage 2A (Initial Detailed Site Assessment). However, it did not
proceed past Stage 2b (Further Detailed Site Assessment) of the Council’s site assessment.
The Council have published reasons for non-inclusion, which are reported as follows:
Our clients have decided to review matters considering the above reasoning and concluded
to remove the element of residential development from the proposed scheme.
Consequently, they only now seek inclusion of land for employment purposes only within
the Deposit Draft of the LDP.
Our clients consider the LDP is “unsound” and should be changed, as it fails to meet the
tests for “soundness”, in that the Plan “is not appropriate”, and “will not deliver”, as defined
by the Planning Inspectorate’s LDP Examinations Procedural Guidance.
Specifically, our clients consider that the Second draft settlement limits for Cross Hands, as
defined under Policy SD1 “Settlement Limits”, should be amended to include the land as
edged in red upon the extract of the Proposals Map for Cross Hands as reproduced
below in Figure 1. The land should be allocated for Employment under Policy SP6
“Employment & The Economy” and EME3 “Employment Proposals on Allocated
Sites.”
Figure 1 – Extract from Proposals Map with Representation site edged in red
This formal representation letter supplements the following documents which comprise a
complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
- Location and Indicative Site Layout Plan
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits
1.0 Availability of Employment Land at Cross Hands
1.1 The Council consider that the only reason for the Candidate Site off Heol Parc Mawr
not being included within the draft Plan as an Employment Allocation is that they
believe that sufficient employment land is already available at Cross Hands to meet
future needs.
1.2 The proposals under this Representation seek the addition of circa 2.0 hectares (4.8
acres) of employment land to provide starter workshops and modest office space, for
which there is a dearth of available opportunities in the settlement. Cross Hands
forms a Principal Centre, being part of the Ammanford / Cross Hands Cluster as
defined within the draft LDP. Figure 2 below provides an extract of the indicative site
layout plan for this Representation site, which as clarified above now only includes for Employment Provision.

Figure 2 – Indicative Site Layout plan of Representation Site
The Cross Hands Cluster aims to provide Employment Land across a wide area, but
principally at Cross Hands East – Sites PrC3/E1 for 8 hectares and Cross Hands
West Food Park (PrC3/E2) for 7 hectares. A further 4.7 hectares is said to be
available at Cross Hands Business Park (Site PrC3/E3). Policy EME3 is reproduced
below in relation to Cross Hands sites:
Figure 3 – Sites Allocated for Employment under Policy EME3
The Council’s reasoning implies that Cross Hands is awash with employment land
opportunities. However, we submit that not all employment opportunities require large
serviced development plateaus as has been created at Cross Hands West Food
Park, and privately off Heol Stanllyd. Those sites are available for large scale new
industrial units, geared to a single user. This theme is also being promoted at Cross
Hands East, although the Council are being selective as to the type of employment
uses permissible upon that half-completed site. The Council seek Research &
Development, hi-technology and high specification engineering operations. Those
uses have been slow in coming forward at Cross Hands East.
1.4 What is immediately apparent at Cross Hands is the lack of opportunities for small to
medium sized businesses to secure business premises, be that workshops, office
units and modest warehousing units. This is notable at the Cross Hands Business
Workshops, which are owned by the Council, but have remained at capacity with no
vacancies for the last few years. Acer Court at Heol Parc Mawr is also full of tenants,
as is Llys-y-Barced, the modern offices at the south-eastern side of Heol Parc Mawr.
See attachments

No change to the Plan

Thank you for consulting Welsh Water, we welcome the opportunity to continue to engage in the LDP process and we offer the following representation for your consideration:
Issues Identification We note and welcome the inclusion of issue 23 regarding infrastructure capacity to support development. The availability of our infrastructure capacity is a key element – particularly in rural areas - in ensuring sustainable and viable development sites.
Strategic Objectives The availability or capacity of infrastructure is a key aspect in determining the sustainability of a settlement, therefore we support the inclusion of SO6 and SO14.
Strategic Growth and Spatial Options We note that the Council identifies a growth requirement of 8,822 new homes over the revised LDP period 2018-2033.
Preferred Spatial Option Whilst we are supportive of the hybrid option and are pleased to note that it acknowledges the need for development to be supported by a range of appropriate infrastructure, there will inevitably be certain areas – particularly in the more rural locations of the County – where water or sewerage infrastructure is limited in its availability.
Placemaking, Infrastructure and Cohesive Communities We welcome the sentiment of paragraph 9.43. Where there is insufficient infrastructure capacity and development wishes to connect in advance of our AMP capital investment, planning obligations or a commercial agreement are the most appropriate way in ensuring delivery of necessary supporting infrastructure. We also welcome the inclusion of paragraph 9.47 and further commentary can be found in respect of the policy INF4.
Policies
SG1: Regeneration and Mixed-Use Sites Please see appendix 1 for site allocation comments.
SG2: Reserve Sites We note that the reserve sites will only be released for development if the allocations fail to deliver the required growth, and that the decision to utilise the sites will be made as part of a formal plan review. As such we will be happy to provide comments regarding capacity to accommodate sites in due course.
SG3: Pembrey Peninsula Most of the peninsula is unsewered and does not have a water supply with only elements of the southeast of the peninsula currently served by either. As such, any proposals for development may require significant offsite water mains and sewers to connect to existing networks. Further to this, the Pembrey Wastewater Treatment Works (WwTW) that serves the southeast of the peninsula may require additional capacity to accommodate any further development and developers may need to fund reinforcement works at the WwTW.
HOM1: Housing Allocations Please see appendix 1 for site allocation comments.
SP6: Strategic Sites Given that both sites have extant planning permission we have nothing specific to advise.
EME3: Employment Proposals on Allocated Sites The following provisions are applicable to all individual development plots located within allocated employment sites:
• We will work with your authority to support sustainable economic development however your authority and potential developers should be aware that the obligations of a water and sewerage undertaker extends to ‘domestic’ supplies only. Where an employment allocation results in higher demands of water supply and/or trade effluent discharges we recommend and welcome early consultation with Dwr Cymru Welsh Water.
• The individual plots available for development can represent a substantial area of land for which the potential demands upon our assets are unknown at present. It is essential that we understand these demands to allow us to assess the impact on our assets. It may be necessary for water and/or sewerage hydraulic modelling assessments (HMAs) to be undertaken at the developer’s expense to establish where the proposed development could connect to the existing networks, and to identify any required infrastructure improvements.
• Water mains and/or sewerage infrastructure required for any potential development site can be acquired through the requisition provisions of the Water Industry Act 1991 (as amended).
• Welsh Water always has rights of access to its assets. Where there are water mains and/or sewers crossing sites then protection measures in respect of these assets will be required, usually in the form of an easement width or in some instances a diversion of the asset.
• If any development site gives rise to a new discharge (or alters an existing discharge) of trade effluent, directly or indirectly to the public sewerage system, then a Discharge Consent under Section 118 of the Water Industry Act 1991 is required from Welsh Water. Please note that the issuing of a discharge consent is independent of the planning process and a consent may be refused despite planning permission being granted.
SP9: Infrastructure The availability or capacity of infrastructure is key in determining a settlement’s sustainability as such we welcome the provisions of this policy in requiring development to ensure sufficient capacity is available or if not, that suitable arrangements are in place to provide the necessary capacity.
With specific regard to water and sewerage infrastructure, where there is insufficient capacity and where no reinforcement works are programmed within the respective AMP Capital Investment Programme, the requisition provisions can be entered into for water and sewerage network infrastructure. The requisition provisions do not apply to wastewater treatment works (WwTW) and planning obligations, or a commercial agreement, may be necessary.
We welcome the reference in the supporting text to Drainage and Wastewater Management Plans (DWMPs). Welsh Water is embarking on the preparation of developing Drainage and Wastewater Management Plans (DWMP) which Welsh Government may be minded making statutory in due course. Growth information is built into our DWMP and forms an important element of our planning which aims to understand how we will continue to deliver effective sewerage services and manage the proactive development of natural flood management for a growing population in the face of climate change and other challenges.
Critically the DWMP considers the impact of changing population on our assets and the subsequent effect to customers and on the environment. As such we believe that the DWMPs will play a role in delivering a holistic, prioritised approach to the management of our drainage and sewerage network in the years ahead, and will complement other planning documents including LDPs, the NDF, and SDPs. To maximise the potential benefits, we are continuing to work closely with our stakeholders and LPAs in the continued development of our DWMP.
INF1: Planning Obligations Where there is insufficient infrastructure capacity available to accommodate a site and development wishes to connect in advance of any AMP capital investment, planning obligations or a commercial agreement are the most appropriate way in ensuring delivery of necessary supporting infrastructure.
INF4: Llanelli Wastewater Treatment Surface Water Disposal We are supportive of the provisions of this policy and the supporting text; moreover, we are pleased to note that the matter has been given its own specific policy. We have also prepared a consultation response to the Burry Inlet SPG which provides further detail on this matter.
SP10: Gypsy and Traveller Provision - Please see appendix 1 for site allocation comments.

SP12: Placemaking and Sustainable Places We specifically welcome the inclusion of criteria k) in Policy SP12. Disposing of surface water in a sustainable manner ensures that it will not communicate with the public sewerage network, which protects the environment and ensures that there is sufficient capacity in the public sewerage network for foul-only flows from development sites. On the theme of SuDS, we welcome the inclusion of the supporting text at paragraphs 11.273 to 11.275 regarding the recently established SuDS Approval Boards (SABs).
PSD3: Green Infrastructure Network We welcome the provisions of this policy and the supporting text. The integration of SuDS as a Green Infrastructure asset is something that we are particularly supportive of.
SP16: Climate Change We are supportive of the inclusion of SuDS in new development and as such welcome the provisions of criterion b) of this policy.
CCH4: Water Quality and Protection of Water Resources we welcome the requirement in supporting paragraph 11.510 that the necessary infrastructure needs to be in place or will be provided to serve development however we would highlight that in cases where there are no plans in place for infrastructure improvements in our AMP investment programme, developers can pay for the necessary infrastructure themselves through the requisition provisions of the Water Industry Act (WIA) 1991 or via Planning Obligations Agreements under the TCPA 1990. It should be noted that the requisition provision of the WIA 1991 only applies to sewerage network reinforcement works, not to WwTW schemes. Funding to deliver reinforcement works at a WwTW can be delivered via Section 106 of the Town and Country Planning Act 1990.
In relation to improving water quality, we are investing an additional £60m specifically to reduce phosphate in the five failing Special Area of Conservation (SAC) rivers in our operating area. This includes schemes at Lampeter and Llanybydder WwTWs that are due for completion by March 2025. In the next investment period 2025 to 2030 (AMP8) we will target investment with the ambition that none of our WwTWs are the cause of ecological failure. Through our phosphorus investment plan, we will have removed 90% of the phosphorus load from our WwTWs discharging to failing SAC rivers, playing our part in allowing these special rivers to meet their water quality targets and to relieve pressure on development restrictions. We expect to complete this programme of work by 2032. Whilst our investment will remove a significant amount of phosphorus from our sewage, in most cases it will not result in SACs complying with the water quality targets on its own. This is not something that Welsh Water can do on its own and it will take the combined efforts of all the contributing sectors to achieve this.

We will be engaging with our regulators and local planning authorities through the Tywi and Teifi Nutrient Management Boards (NMB) which can provide the governance, strategic direction and local intelligence/decision making needed if we are to be successful in relieving the pressure on planning restrictions and restoring river quality.
With regard to supporting text in paragraph 11.516, there are several locations within the County where we abstract water that is treated prior to entering the public water supply network. As such, we fully support the provisions in the supporting text of this policy in preventing the degradation of water resources.

TRA1: Transport and Highways Infrastructure Improvements There may be locations where proposed developments / routes pass over public sewers and water mains. Under the Water Industry Act 1991 we have rights to always access our apparatus and protection measures in respect of these assets will be required either in the form of an easement width or a possible diversion of the asset. We welcome early engagement once further detail is available.
MR1: Minerals Proposals We welcome the inclusion of criterion e) and k) of this policy.
We hope that the above information will assist you as you continue to progress the LDP2 and would encourage the LPA to continue to liaise with Welsh Water at each stage of the process. In the meantime, should you require any further information please do not hesitate to contact us at Forward.Plans@dwrcymru.com or via telephone on 0800 917 2652.