Polisi Strategol – SP 12: Creu Lleoedd a Lleoedd Cynaliadwy

Policy wording should be changed to 'To achieve this new development shall aim to:

The policy wording is too prescriptive as not all development will be able to deliver all of the listed items.

The requirement for SuDS is covered by existing separate legislation so does not need to be included in the policy requirements.

Policy point f) ‘Exhibit and demonstrate a clear understanding of the existing local landscape context, natural and built heritage, local character and sense of place.’
Proposed change to ‘Exhibit and demonstrate a clear understanding of the existing local landscape character, natural and built heritage, local context and sense of place; ensuring development proposals protect and, wherever possible, enhance these features.’

This change would deliver the key components of the New Strategy more convincingly in relation to this Policy, one of which is ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes.’ It would also deliver Strategic Objective 9 (SO9) more convincingly. SO9 aims ‘To protect and enhance the diverse character, distinctiveness, safety and vibrancy of the County’s communities by promoting a place making approach and a sense of place.’ Currently the specific phrase ‘protect and enhance’ only features in Strategic Policy SP14: Maintaining and Enhancing the Natural Environment which is only one component of the County’s diverse character. Variations of protect and enhance feature elsewhere in the written statement and there is benefit in bringing SP12 more into line with these.

POINT D must be more robust/ stringent in the light of a climate emergency with detailed requirements in the new SPG: on construction materials and techniques, embodied carbon, energy use following the energy hierarchy and all other elements to create holistic, sustainable and ecological developments. See requirements of Passivhaus, Living Building Challenge, LETI and WELL Building Standard.

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.

Proposed change to Policy point f) - ‘Exhibit and demonstrate a clear understanding of the existing local landscape character, natural and built heritage, local context and sense of place; ensuring development proposals protect and, wherever possible, enhance these features.’

Carmarthenshire Residents’ Action Group: Representations to the public consultation of the Second Deposit Revised Carmarthenshire Local Development Plan 2018-2033 and the Integrated Sustainability Assessment
We, Carmarthenshire Residents’ Action Group, are responding to the public consultation on the Carmarthenshire Local Development Plan 2018-2033 (Second Deposit) (‘Revised LDP’) to raise concerns with regard to the plan making process in relation to landscape(s) within the LDP’s geographical area. We request several changes to the plan on the basis that we consider the plan not to be sound and request the opportunity to make representations during the examination process.1
This letter contains a series of comments and objections in relation to landscape policies, and approach to policy making with regard to landscapes, within Carmarthenshire’s Revised LDP drafting process, including the Integrated Sustainability Appraisal (‘ISA’).
This letter also consolidates a series of comments made via the online comments portal on the proposed Revised LDP. It refers Carmarthenshire’s Forward Planning Department and, in due course, the appointed Examination Planning Inspector, to Carmarthenshire Residents Action Group’s petition to maintain the Special Landscape Areas within the 2018-2033 LDP. This petition has raised 438 signatures, details of which are contained within Appendix 1 of this letter.
A strong objection is raised, backed by significant local support, to the removal of Carmarthenshire’s locally designated Special Landscape Areas within the Revised LDP. Objections are also raised with regard to the replacement landscape related policies in the second Deposit Revised LDP with materially weakened policies compared to the existing 2006-2021 LDP (‘Current LDP’). The letter also raises concerns with regard to the assessment carried out in the ISA as it pertains to the Sustainability Objective on Landscape.
Our representations are set out as follows:
1. Objection to the removal of Special Landscape Areas from the Revised LDP;
2. Inadequate Evidence Base;
3. Revised LDP Policies;
4. Specific suggested amendments to Revised LDP Policies;
5. Adequacy of the assessment Integrated Sustainability Appraisal as it concerns Landscape; and,
6. Conclusion
1 It is noted that Welsh Government Local development plan examinations: procedure guidance (28 November 2022) states in paragraph 1.7 that ‘Those who have sought changes to the submitted plan or plan revisions and have indicated that they would like to speak must be invited to the hearings.’

1. Objection to the removal of the Special Landscape Areas from the Revised LDP
‘The use of non-statutory designations such as Special Landscape Areas to protect areas of landscape value has long been a policy tool within the UK planning system. They have been seen by local planning authorities as a means of protecting sensitive landscapes and in developing an understanding and awareness of those features and characteristics that give a locality its sense of place.’2
Carmarthenshire’s 18 Special Landscape Areas (‘SLAs’) listed under Policy EQ6 in the Current LDP have not been carried forward into the Revised LDP.
We recognise that SLAs are a local non-statutory designation, however these areas are an acknowledged designation which carries weight within the Current LDP as a standalone policy. SLAs are also acknowledged and given weight within neighbouring Local Planning Authority (‘LPA’) LDPs.3 The weight given to the SLA designations is recognised across Appeal decisions by the Planning Inspectorate and in Planning Inspectorate recommendations with regard to Development Consent Order applications.4
We object to the Second Deposit LDP on the basis of the removal of the SLAs and request that SLAs are reintroduced into the Revised LDP, either as a standalone policy or that provision is made within the new Policy BHE2: Landscape Character.
This could be achieved by an amendment to Policy BHE2: Landscape Character to add wording as follows:
Proposals must take account of Carmarthenshire’s locally designated Special Landscape Areas (as set out in Appendix X (Appendix 4 of the Current LDP) and shown on the Policies Map). Development proposals will only be permitted where there is no significant adverse impact, including cumulative impact, on the character and quality of the landscape. Development proposals should aim to protect and enhance the features for which the SLA has been designated.
Where appropriate, a Landscape Impact Assessment will be required to assess and justify the impact of the development on Landscape Character and/or the designated area.
In exceptional circumstances, where development is necessary and could result in a significant landscape impact, appropriate mitigation and enhancement measures should be provided, including the undergrounding of associated infrastructure where possible.
Our suggested wording is similar to the City of Swansea LDP which was successfully adopted following Examination in February 2019.5 Appendix 4 of the Current LDP would remain relevant to the Revised LDP and could be brought across, with edits as necessary to increase the robustness of the assessment of the area’s character. SLAs could be added back into the Policies Map, with minor boundary edits as necessary.
2 Bridgend County Borough Council, Designation of Special Landscape Areas, March 2010
3 City of Swansea LDP (adopted February 2019), Ceredigion LDP (adopted 2013)
4 Including, but not solely, APP/M6825/A/12/2189697, APP/M6825/X/13/515763 & APP/M6825/X/13/515764; and Brechfa Forest Connection DCO application ref EN020016;
5 https://www.swansea.gov.uk/article/9914/Swansea-Local-Development-Plan-2010-2025-LDP

Reasons for retention
The retention of the SLAs in the Revised LDP is well supported, with 438 people resident within the county signing Carmarthenshire Residents’ Action Group’s petition.
We argue that the retention of the SLAs is important to fulfil to objectives of the LDP and question if the SLAs are removed if the plan meets its Sustainability Objectives on Landscape set against the baseline criteria. We do not consider that a robust, proportionate and credible case has been set out by the LPA for the removal of this landscape designation. We consider that the removal of the SLAs significantly weakens the Revised LDP’s SO9 regarding sense of place and impacts Carmarthenshire’s planning framework in terms of delivering on sustainable development on the basis of the Well-being of Future Generations Act.
By designating SLAs it is easier for communities, visitors and tourists to engage with the highest value landscapes of Carmarthenshire. The SLA designations are reflective of the local value communities place on these landscapes in a manner not captured in the replacement Policy BHE2: Landscape Character. This revised policy places too much reliance on LANDMAP assessment. Whilst LANDMAP is an excellent tool for those engaged with the planning process, it is harder to engage with than the specifically designated SLAs which have clear and geographical boundaries capturing the outstanding and high quality landscapes of Carmarthenshire. The removal of the SLAs, and their removal from the Polices Map, invariably makes it makes it harder for specific communities and the wider public to engage with the LDP and weakens community representations as part of the planning consultation processes for individual development applications.
We consider that the SLAs improve the delivery of the Revised LDP objectives. Natural Resources Wales (‘NRW’) states that ‘there may be more than one role for an identified SLA: To recognise and protect (through development management) locally valued landscapes important for their distinctive character, qualities and sense of place / bro; To influence positive landscape planning. […]; To raise understanding and appreciation of the importance of local landscapes by communities, visitor and the wider public.’ The SLAs currently provide these roles and retaining them in the Revised LDP would better meet the LDP and ISA Objectives.
The developmental pressures on the landscape have not weakened in the time between the Current LDP adoption and the Revised LDP drafting. The Current LDP Appendix 4 assessment of SLAs specifically states in relation to the Tywi Valley, that ‘Inappropriate development continues to threaten the conservation of this outstanding landscape, hence the reason for its designation.’ We do not see that these reasons for designation have weakened. However, if the LPA consider otherwise, then the evidence of this decision making process should be published.
Planning Policy Wales 11 (‘PPW11’) paragraphs 6.3.12 and 6.3.13 relate to the characteristics of local landscapes. These paragraphs highlight the ability for LPAs to designate SLAs. Paragraph 6.3.13 states that ‘Planning authorities should apply these designations where there is good reason to believe that normal planning policies cannot provide the necessary protection.’ Given that pressures on the landscape have not weakened and that the existing SLAs have proven weight in the planning determination process, we consider that the removal of the SLAs in the Revised LDP runs contrary to this part of PPW11.

Compatibility with Policy and Guidance
In addition to the point with regard to PPW 11 above, our view is that the SLAs are wholly compatible with the Revised LDP, the proposed Policy BHE2: Landscape Character and can be seamlessly incorporated into this policy, or alternatively, the existing policy could be retained in the Revised LDP.
NRW LANDMAP Guidance Note 1: LANDMAP and Special Landscape Areas 2017, endorses a dual approach to landscape management, in line with our suggested edits to the Revised LDP Policy BHE2: Landscape Character. On page 3 of the document, it is stated that ‘in this dual approach, all landscapes will be underpinned equally by LANDMAP […] but in addition to this, landscapes of high local importance will be specifically identified as a SLA with additional guidance being produced for these key landscapes’.
We recognise that there is potential tension between the SLA designation of Llanllwni Mountain SLA and the Cothi Valley SLA, and that these areas are also within the Pre-Assessed Area for Wind Energy in Future Wales 2040 the National Development Plan (‘NDP’). We argue that the SLA designation of these areas is not in conflict with the NDP, including Policies 17 and 18. However, we recognise that this is an area of the Revised LDP which may benefit from further exploration at Examination and we would appreciate an invitation to make representations on this issue.

2. Inadequate Evidence Base
The Issues, Vision and Options paper makes it clear that this 2018-2033 LDP is a review of the previous LDP and not a new local plan (para 1.3, page 2, Issues, Vision and Options Topic Paper, February 2023). There is a general expectation in plan making that evidence is front-loaded. As the Revised LDP revises the Current LDP, it is reasonable to expect that the entire removal of locally designated SLA from the plan should be carried out on a sound, evidence backed, basis. Statements by the LPA during the plan making process did not indicate that SLAs would be removed from the plan at Review or Preferred Strategy stages. The weakening of the landscape policies and the removal of SLAs was not revealed until the publication of the First Deposit LDP in early 2020. Prior to the publication of the First Deposit LDP, the LPA indicated that further evidence would be published if the policy were to be changed.
The 2006-2021 LDP Review Report 2018 did not raise concerns about the effectiveness of the SLA Policy, giving it a green colour coding indicating the policy target was being achieved or exceeded. The report stated in paragraph 9.141 that ‘The Plan identifies Special Landscape Areas (SLAs) within Policy EQ6. These were identified following a formal assessment of the landscape qualities of the County and are a non-statutory designation. It is noted that the policy places an emphasis on enhancement and improvement. There may be opportunities to supplement and/or review the supporting evidence for this policy and explore those wider linkages (e.g. the renewable energy policies and those design related policies).’
Further, Appendix 1 of the Review Report reviewing specific policies states that in relation to Policy EQ6 SLAs that ‘Whilst no fundamental changes are envisaged, the policy will respond to contextual (including legislative and policy changes), factual and evidential changes as well as those resulting from any revisions to the strategy.’ This wording is a standard response to policies which were expected to be kept in the Revised LDP close to their current form. It is difficult to ascertain how the
removal of the SLAs does not constitute a fundamental change, to a degree where evidence justifying this change would reasonably be expected to be published.
Following on from the review, the Preferred Strategy was published in 2019. The Preferred Strategy gave no indication of the intention to remove the SLAs from the Deposit Plan and gave significant indication that landscape policies would remain strong within the Revised LDP. Issue 8 of the LDP issues is ‘Rich landscape or townscape qualities’; the Vision states that ‘rich cultural and environmental qualities are valued and respected’; paragraph 10.19 states that ‘the LDP will promote the principles of sustainability by: Protecting and enhancing biodiversity, townscapes and landscapes’; ‘A New Strategy – Key Components’ paragraph 10.20 states that ‘the key components of the strategy are as follows:’ one of which is to ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes’.6
Given these statements, it would not be unreasonable to expect that the SLA policy would remain in the Revised LDP, particularly given specific reference to the protection of high value landscapes. The means of recognising and protecting the areas of outstanding and high value landscapes in the LPA’s geographical area is specifically the Current LDP’s SLA policy.
Furthermore, in response to a representation made on the Preferred Strategy, the LPA stated ‘The consideration of whether any Special Landscape Areas will be identified in the Revised LDP, along with any resultant evidential facets, will be a matter for the deposit LDP.’ [our emphasis].
In our view, it is reasonable to consider that prior to the First Deposit Plan publication that the full SLA policy, or a slightly revised version of it, would remain in place in the new LDP; or that evidence would be published alongside the Deposit Plan to justify removal of the SLA policy given the LPAs statements in the Plan Review and the response to the Preferred Strategy public consultation. Therefore, given the above timeline indicates a very late decision to remove the SLAs from the Revised LDP, we question whether the decision has been carried out with robust, proportionate and credible evidence.
What evidence has been used?
At the date of this letter, the LPA have not provided information within the Plan Evidence Base, as accessed online, for the decision to remove the SLAs from the LDP; nor the evidence that the new landscape Policy BHE2: Landscape Character sufficiently delivers on the aims of the New Strategy which includes the key component to protect and enhance high-value landscapes.
Assessments which have been published by the LPA in relation to Landscape Character are due to expire when the new LDP is adopted. These comprise existing assessments of the SLA areas in Appendix 4 of the Current LDP; there is a reference to NRW’s 48 broad scale, not locally specific, National Landscape Character Areas (NLCA), and the SLAs within the Placemaking and Design SPG (adopted 2016); and consideration of landscapes in the Carmarthenshire Wind Turbine Development Landscape Sensitivity and Capacity Study, prepared by Anthony Jellard Associates.
The SLAs are removed from the Revised LDP. The Placemaking and Design SPG is not slated to be carried forward with the new Revised LDP7. The current status of the Anthony Jellard study is unclear,
6 These parts of the Preferred Strategy are carried into the Second Deposit LDP, February 2023, and are found across Chapters 5-9.
7 See Appendix 3, Second Deposit LDP 2018-2033
it is referenced within the current Wind and Solar SPG; however this SPG is not intended to be carried forward as part of the Revised LDP. The removal of these assessments is likely to leave a gap with regard to the protection and enhancement of landscapes when the new Revised LDP is adopted.
Given the anticipated expiry of these assessments, it is not credible that they can form part of an evidence base for the creation of the Revised LDP policies. No evidence has been provided that any other assessments have been carried out in forming the LPAs landscape character policy or that NRW’s LANDMAP has been utilised to inform revised policy preparation. The Revised LDP states that a Landscape Character Assessment SPG is proposed to be adopted by Summer 2025, but as no draft has been published this does not form part of the evidence base. The target Revised LDP adoption date is Autumn 2024 and with the SPG proposed for Summer 2025, this leaves a significant gap around landscape policy guidance in the interim, even if the Landscape Character SPG is published on time.
The LPAs Cabinet Member for Planning has responded to a question on the evidence base by discussing assessment of development proposals utilising information contained within NRWs LANDMAP. However, this is an existing means of assessment in the Current LDP and will be retained as a means of assessing change to landscape in the Revised LDP, as such it does not make a difference to the baseline. Notably, the question asked to the Cabinet Member for Planning was with regard to the evidence around the formation of new Policy BHE2 and the removal of the SLAs, to which she did not furnish an answer. 8
Finally, the lack of published evidence relevant to the landscape policies of the Revised LDP appears to be in conflict with paragraph 6.3.21 of PPW 11, which states ‘Planning authorities should draw upon LANDMAP in the preparation of landscape plans and assessments needed to inform development plans, SPGs and the development management process. LANDMAP assessments should be published.’ [our emphasis]
In our view, the evidence base for the Revised LDP in terms of Landscape Policy is not sufficiently substantiated and we request that this is interrogated by the Inspector appointed for the Examination.

3. Revised LDP Policies
We argue that the Revised LDP policies are substantively weaker with regard to landscape protection and enhancement than the Current LDP Policies. Comparison of similar policies in relation to placemaking, sustainability, high quality design, landscapes and features of importance, landscape character and renewable energy, between the Current LDP and the Revised LDP, show fewer mentions of the need to ‘preserve or enhance’, that development ‘must’ meet certain criteria, that development ‘will only be permitted’ if specific criteria are met, and the clear setting out of designated Special Landscape Areas with the expectation that development should enhance or improve these areas.
This is in contrast to the Revised LDP which uses wording such as ‘should relate to’, maintaining ‘overall integrity’, ‘development shall demonstrate’, that ‘development must acknowledge’ and ‘demonstrate a clear understanding’. Whilst it is acknowledged that this can be a more positive way of forming LDP policies and there are good reasons for this approach, it would be erroneous to suggest
8https://democracy.carmarthenshire.gov.wales/ieListDocuments.aspx?CId=131&MId=6351&Ver=4 [accessed 14 April 2023]
that these changes do not make the Policies easier for development to be consented and weaker in some instances. In our view, this is notably the case with regard to landscape protections and most significantly the removal of a whole policy layer designating Special Landscape Areas. With regard to landscape there is a question if the Policies as currently drafted are sufficiently robust to deliver on the Issues, Vision and Objectives of the plan, as well as key components of the Strategy.
We appreciate that Policies SP12: Placemaking and Sustainable Places and BHE2: Landscape Character, do contain some landscape protections. However, with the removal of the designated SLAs the Revised LDP remains materially weaker with regard to the protection of Carmarthenshire’s highest quality landscapes (outstanding and high value). This is especially the case prior to the publication of the promised Landscape Character SPG, and without publication of this SPG in draft form before examination it is difficult to fully consider the likely strength of these policies.

4. Specific suggested amendments to Revised LDP Policies
In addition to the objection to the removal of the SLA policy and suggestions for its reintroduction, we have the following additional comments on the Revised LDP.

Object. Strategic Policy – SP12: Placemaking and Sustainable Places
Policy point f) ‘Exhibit and demonstrate a clear understanding of the existing local landscape context, natural and built heritage, local character and sense of place.’
Proposed change to ‘Exhibit and demonstrate a clear understanding of the existing local landscape character, natural and built heritage, local context and sense of place; ensuring development proposals protect and, wherever possible, enhance these features.’
This change would deliver the key components of the New Strategy more convincingly in relation to this Policy, one of which is ‘Protect and enhances the natural, historic and built conservation qualities of Carmarthenshire and its high value landscapes.’ It would also deliver Strategic Objective 9 (SO9) more convincingly. SO9 aims ‘To protect and enhance the diverse character, distinctiveness, safety and vibrancy of the County’s communities by promoting a place making approach and a sense of place.’ Currently the specific phrase ‘protect and enhance’ only features in Strategic Policy SP14: Maintaining and Enhancing the Natural Environment which is only one component of the County’s diverse character. Variations of protect and enhance feature elsewhere in the written statement and there is benefit in bringing SP12 more into line with these.

Object. PSD1: Effective Design Solution: Sustainability and Placemaking. Policy point d) states ‘Quality landscapes design solutions’, this appears to be a typo where ‘landscape’ fits better. In our view, for policy point d) to work effectively, either reference to a published Landscape Character SPG, or reference to NRW LANDMAP (especially the Visual and Sensory assessment layer) should be made within this Policy or in the accompanying notes. This would benefit from explicitly stating that it applies to all development, including infrastructure, Renewable and Low Carbon developments, as well as buildings, transport, excavation sites, and smaller scale landscape proposals in the private and public realm.

Object. BHE2: Landscape Character. The use of ‘overall’ in the policy substantively weakens its protection of the landscape character. We request that this word is removed. It is unclear in the current presentation of the policy if the onus is on the applicant to identify the landscape character of the ‘local area’ through their own assessment, or if NRWs LANDMAP data is to be used, or if the
LPAs own Landscape Character SPG is to be used. This should be more explicitly set out and clarified. If the expectation is that the Landscape Character SPG is the baseline then it would be beneficial for this to be published in advance of the Revised LDPs adoption, preferably at the time of Examination. Reference to the Landscape Character Assessment should also be made in the Policy text.
It is also unclear where the key landscape views and vistas mentioned in point e. are set out, in order for them to be protected in the policy. If these are due to be identified in the Landscape Character SPG then, again, this would benefit publication prior to plan Examination.
We also request that reference to SLAs are added into this policy, as set out in section 1 of this letter.

Object. Policy CCH1: Renewable Energy within Pre-Assessed Areas and Local Search Areas. This policy would benefit reference to cumulative impacts on landscape character, undergrounding of infrastructure, requirements for battery energy storage plants associated with the Renewable developments, and presumption of consent for renewable development proposals by communities, as well as those already set out for large scale wind farms. We suggest that the following are added to the policy:
d. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
e. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
f. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
g. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Object. Policy CCH2: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas. This policy would benefit reference to cumulative impacts on landscape character, undergrounding of infrastructure, requirements for battery energy storage plants associated with the Renewable developments, and explicit presumption of consent for renewable development proposals from communities. We suggest that the following are added to the policy:
b. [add]… , including SLAs;
g. Proposals must include an assessment of impact on landscape character, value and qualities, with regard to the cumulative effects of the development with other built, consented and likely (based on Pre-Assessed Area, Future Wales 2040) developments;
h. Proposals for associated infrastructure, such as pylons, cabling and other grid infrastructure, will require undergrounding wherever possible, unless such undergrounding conflicts with ecological, natural or archaeological constraints;
j. Proposals for battery storage plants at Renewable Energy sites must be accompanied by a fire safety strategy and a pollution control strategy, having regard to potential environmental pollution, ground water courses and potential river pollution effects;
k. Renewable and low carbon energy projects which are developed by local communities (located within 5km of the development site) at all scales of MW development will be permitted, subject to the proposed development meeting the criteria above.

Object. Table 9 Resource Summary for Renewable Electricity. The Onshore Wind Target to deliver 588.5 MW of additional installed capacity by 2033 is in our view unrealistic given there has not been a call for sites for wind power. By our calculations, extrapolating from the evidence base document, AECOM Renewable and Low Carbon Energy Assessment Section 4.3, delivery of this target may require 75% of the area unconstrained by features such as buildings, roads and rivers in the Pre-Assessed Area in north Carmarthenshire to be developed for onshore wind.9 Given the mix of landowners and small scale farms across this area, delivery of the target may be challenging without large scale land purchases, which would not be feasible or desirable for smaller scale community wind developers. This policy is likely to result in more large scale multi-national corporation wind farm developments across Carmarthenshire. This is notwithstanding the scale of significant adverse impacts, including cumulative impacts, on the landscape a target like this will create.

Object. Policy CCH6: Renewable and Low Carbon Energy in New Developments. This policy could be more ambitious helping to deliver Net Zero targets by requiring all new housing or commercial development to fit solar panels to roofs, unless it is demonstrated by the applicant that to do so would not be viable, or if by doing so would conflict with other policies in the Revised LDP (such as built heritage, townscape or landscape policies).
Object. Policy CCH7: Climate Change – Forest, Woodland and Tree Planting. Specific reference should be made in the policy text to native trees and that planting schemes much be appropriate to the cultural and ecological character of the locality. This is referenced in paragraph 11.534, however due to the large ecological and landscape impacts that can arise from non-native tree planting, in our view the wording should be directly within the policy text.
The AECOM assessment estimates that the Pre-Assessed Area in Carmarthenshire, identified in Future Wales 2040, covers an area of 687 km2. The report assumes a maximum of 5 2MW turbines per 1km2 of land. Applications for new onshore wind at scale is more likely to be focused within the Pre-Assessed Areas due to the favourable planning framework for these locations. The Revised LDP target for installed capacity is an additional 588.5 MW, which using AECOM’s calculations would need to cover a land area of 58.85 Km2, or, 14,542 acres, equivalent to 8.5% of the Pre-Assessed Area. Taking into account the expected delivery of the remaining capacity in the former TAN 8 SSA, there is the expectation that 54.83 km2 will be delivered on a total possible unconstrained area of 73.1km2, or 75% of the unconstrained land in the Pre-Assessed Area. For the purposes of the AECOM study the constrains are National Parks, Natura 2000 sites, Buildings, Roads, Rivers, the TAN8 SSA and Topple Distance buffers applied to buildings, roads and rivers. Calculations taken from data within page 29 and 30 of the AECOM Renewable and Low Carbon Energy Assessment published in the LDP Evidence Base.

5. Adequacy of the Integrated Sustainability Appraisal assessment as it concerns Landscape
We are raising substantive concerns with regard to the robustness of the assessment carried out in the Integrated Sustainability Appraisal (‘ISA’).
The Sustainability Appraisal Scoping Report (published July 2018) set out the parameters of the Sustainability Appraisal, identifying Sustainability Issues and Opportunities, Sustainability Assessment Objectives and Decision Making Influences. This identified Landscape as number 9 of a total of 15 equal issues. Issue 9 is set out as follows: ‘There are several sites designated as of landscape or townscape value within the county. These features need to be protected, and where possible enhanced.’ In the Decision Making Influences, the question, ‘Will the LDP have a positive or negative impact on designated landscapes?’ is posed.
Linking these two quotes is the specific mention of ‘designated landscapes’, not statutory designated, nor ‘Designated’ noun. Special Landscape Areas are considered designated landscapes in this definition. This is the case in comparable LPAs in Wales, PPW11 para 6.3.12 refers to ‘the designation of Special Landscape Areas’ and the Current LDP Policy EQ6 states that ‘Special Landscape Areas are designated…’. Thus, references to designated landscapes in the Sustainability Appraisal, must take into account local as well as statutory designations, including SLAs. The question ‘will the LDP have a positive or negative impact on designated landscapes?’ and that the Revised LDP removes some of these designated landscapes, is an important consideration for the assessments in the Sustainability Appraisal.
Sustainable development is defined in the Well-being of Future Generations (Wales) Act 2015 as the ‘process of improving the economic, social, environmental, and cultural wellbeing of Wales by taking action.’ A change to the development plan which removes some designated landscapes should be considered carefully and assessed robustly on the terms that those designations have been removed, to demonstrate that the change is not an impairment to sustainable development.
Turning to the latest version of the ISA, published February 2023. The prediction of the effects of the plan involves identifying changes to the environmental baseline. The baseline for sustainability objective ISA9 – Landscape is set out in ISA Appendix B (pp.61-67) with the other baseline assessments. This baseline constitutes an introductory paragraph explaining that the Brecon Beacons National Park sits outside the LDP boundaries, along with a copy of the Current LDP Appendix 4 Special Landscape Areas assessment in full, then proceeds to state the ‘Predicted effect without implementation of the LDP’.
In our view, this assessment of predicted effects has been carried out incorrectly. The predicted effects mention protected habitat and species and biodiversity, which are assessed under ISA2 Biodiversity, and fails to comment adequately on changes to landscape as a characteristic in and of itself. Crucially, this assessment fails to note that the locally designated landscapes, SLAs, will continue to be in effect once the Plan period expires. This is, in our opinion, a substantive omission especially given that the baseline text is comprised of Special Landscape Area descriptions and assessing areas noted as being ‘worthy of the protection that the designation of SLAs provides.’
Section 4 of the ISA sets out a summary of the environmental baseline and predicted effects, noting that the future baseline for landscape is declining. This summary has a stronger summarisation of the likely effect on landscape than that set out in the ISA Appendix and states clearly that ‘landscape
protection measures should be strengthened’. As this assessment is provided on the basis that the Current LDP continues to remain in place, the need to have measures strengthening landscape protection must be considered to be in addition to those already in place, including the designated SLAs.
As the ISA needs to take into account the effect of the Revised LDP being adopted, against the baseline of the Current LDP remaining, some assessment of the removal of the local designated SLAs would be expected in the ISA. However, Special Landscape Areas are not mentioned in the main text of the ISA, nor the ISA Appendices, outside of the Baseline and list of Abbreviations. Failure to take account of the loss of this designation from the LDP is, in our view, a major error and questions the credibility of the appraisal of predicted effects on ISA9 – Landscape, throughout the ISA document and brings into question the soundness of the Plan.
There are also other concerning errors and omissions. One example is the review of SP16: Climate Change and associated specific policies CCH1: Renewable Energy within Pre-Assessed Areas and Local Search Areas and CCH2: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas, in Appendix F and G. The appraisal considers the effects on landscape to be ‘neutral’ and with ‘positive and negative effects’. This is not credible given the scale of change proposed to the landscape on the basis of the targets for new wind power generation by 2033, and this target set in the context of the removal of the SLAs from the LDP. A negative effect should be identified. Whether the negative effect should be acceptable on balance is a test that is separate to this specific part of the ISA. The ISA should credibly take into account the high magnitude of the changes, the Plan’s intention to remove the SLA designated landscapes, and the effect characteristics including the scale of cumulative effects, their special extent and their probability; all of which is high impact and likely.
Another example is the review of SP14: Maintaining and Enhancing of the Natural Environment, where the Appraisal comments against ISA9 state that ‘This policy directly refers to the protection and enhancement of Carmarthenshire’s landscape’ (ISA Appendix F, p.46). This policy does not do as the Appraisal states. The protection and enhancement is directed at the natural environment more generally, it is not a policy linked back to ISA9 in its monitoring objectives, and points more generally to a confusion throughout the Revised LDP between the character of landscape as a visual and integral whole vs smaller scale aspects which make up the natural environment, which are nonetheless important, but fundamentally different.

6. Conclusion
The removal of the SLA designations from the LDP cannot but be an adverse change. The failure to take account of this substantive change and substantiate why this is not a significant weakening of the LDP from its current form is of great concern.
We encourage Carmarthenshire’s Forward Planning Department to set this right before the LDP is examined and re-introduce the SLA designations into the Plan to address the issues raised in this letter, re-providing a substantive part of the means to protect and enhance our outstanding and high valued landscapes for future generations.
We re-iterate our request to make representations on the LDP examination on the subject of landscape, with regard to relevant policies.
We appreciate your, and the appointed Planning Inspector’s, consideration of this letter.

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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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.
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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
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.
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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
• 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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PPW: Welsh Government Planning Policy Wales – Edition 11 2021
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

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

As set out in the summary

SECOND REVISED LOCAL DEVELOPMENT PLAN 2018 – 2033: CYNGOR SIR GÂR
Response to Public Consultation April 2023

1. We wish to support the points raised in the response submitted by Plaid Cymru Councillors and fully support the content of the document
2. We wish to add these points for consideration, in addition to responses made online:
• Rural Enterprise Dwellings: The interpretation of this policy needs to be expanded beyond traditional rural enterprise to include supporting individuals who make a positive social and or ecological impact in our rural landscape.
• When interpreting development proposals against policy, all proposals should be required to meet a higher level of minimum standards regarding environmental design and sustainable developments, essentially setting SP12 and PSD5 as substantive pre-requisites before other policy is then considered.
• Consideration should be given against the local context, where evidenced, when considering affordable and intermediate housing.
• Planning policy should aim to limit the impact of second homes/holiday homes on rural settlements.
• The development limits in Llansteffan do not yet include a long established group of houses along Mill Pond Lane, SA33 5LG. This lane is part of the settlement, and should reside within the limits. See below image of proposed change to boundary.