7.6

Amend the formatting of the document and ensure SO3, SO4 and SO5 appear in the correct order.

Dear Sir/Madam

2nd DEPOSIT REVISED CARMARTHENSHIRE LOCAL DEVELOPMENT PLAN 2018 - 2033

The Mineral Products Association (MPA) is the trade association for the aggregates, asphalt, cement, concrete, dimension stone, lime, mortar and silica sand industries. With the affiliation of British Precast, the British Association of Reinforcement (BAR), Eurobitume, MPA Northern Ireland, MPA Scotland and the British Calcium Carbonate Federation, it has a growing membership of over 530 companies and is the sectoral voice for mineral products. MPA membership is made up of the vast majority of independent SME quarrying companies throughout the UK, as well as the 9 major international and global companies. It covers 100% of UK cement production, 90% of GB aggregates production, 95% of asphalt and over 70% of ready-mixed concrete and precast concrete production. In 2016, the industry supplied £18 billion worth of materials and services to the Economy. It is the largest supplier to the construction industry, which had annual output valued at £169 billion in 2018. Industry production represents the largest materials flow in the UK economy and is also one of the largest manufacturing sectors. For more information visit: www.mineralproducts.org.

Thank you for consulting us on the above document. Our comments are appended to this letter. For ease of reference where we have proposed amendments to the text, we have struck through text (xxxxxx) to be deleted and used bold underlined text (xxxxxx) for proposed insertions.

If you require clarification on any of the points made, please do not hesitate to contact us. We welcome future engagement on this matter. We should be grateful if you could forward future correspondence to the email below.

Yours faithfully

Nick Horsley

Director of Planning, MPA Wales

Section 7.6
SO5
The formatting of the document is confusing in that SO5 appears before SO3 and SO4
Amend the formatting of the document and ensure SO3, SO4 and SO5 appear in the correct order.

Section 7.6
Strategic Objectives
It remains unclear why the provision of a sustainable and adequate supply of minerals is not identified as a Strategic Objective. This is a fundamental requirement of PPW and the need for minerals is the thread which stiches together many of the strategic objective identified, providing raw materials to deliver and address issues such as employment, housing, climate change, infrastructure, transport and environmental aspirations.
Include a further Strategic Objective to reflect the need for a sustainable and adequate supply of minerals.

Policy BHE1: Listed Buildings and Conservation Areas
Subsections 2. & 3. State:
“2. Developments within or adjacent to a conservation area will be permitted, where it would preserve or enhance the character or appearance of the conservation area, or its setting.
3. New developments in conservation areas should be of a high standard of design which responds to the area’s special characteristics and features.”
It remains unclear how the requirements of these subsections will be achieved. Maintaining the characteristic fabric of these buildings and conservation areas routinely requires an indigenous supply of local stone and materials, sympathetic to the character of the area and its buildings. There are no policies within the plan supporting the development of indigenous sources of building stone/materials.
Clarify within the plan how the characteristics of conservation areas and listed buildings will be maintained using materials sympathetic to the area. Sources of indigenous building materials will be needed and reflected within the policies in the plan.

Strategic Policy SP 18: Mineral Resources
Subsection a) states “Ensuring an adequate supply of minerals, including maintaining an adequate landbank of permitted aggregate reserves (a minimum 10 years for hard crushed rock, and a minimum 7 years for sand and gravel) throughout the Plan period;”
We welcome the amendments now incorporated.

Strategic Policy SP 18: Mineral Resources
Subsection c) states “Safeguarding minerals infrastructure, and areas underlain by minerals of economic importance where they could be worked in the future, to ensure that such resources and infrastructure are not unnecessarily sterilised by other forms of development;”
We welcome the amendments now incorporated

Paragraph 11.564
“For crushed rock, Carmarthenshire forms part of the Swansea City Sub-region, along with the local authorities of Swansea and Neath Port Talbot. Although at present, Swansea is unable to demonstrate an inability to meet RTS2 apportionments, there are more than sufficient reserves within NPT and Carmarthenshire to take up the joint apportionment within this period without resulting in under provision. A statement of subregional collaboration (SSRC) has been produced which demonstrates how the constituent Authorities satisfy the requirements of RTS2 in respect of future crushed rock provision.”
We have concerns that the approach proposed does not accord with the RTS, not least that the concerns raised in our response to the draft Swansea SSRC, dated 19th November 2020 have not been addressed. Where authorities are seeking to “absorb” apportionments from neighbouring authorities, it is necessary that there is a corresponding increase in provision within those authorities, as required by MTAN 1. The receiving authorities will need to increase their apportionments (and, where necessary, allocations), to ensure that as a minimum, the overall requirements for ongoing supply within that sub-region, as set out in the RTS, are met (both numerically and in terms of aggregate type). It will not normally be appropriate to merely transfer apportionments to an LPA with sufficient existing reserves to arithmetically absorb the apportionment, without reference to the additional consideration of productive capacity. Whilst the shortfall in allocation relates primarily to Swansea, it is inappropriate for this flaw to be reflected in the Carmarthenshire RLDP.
Amend the text accordingly to reflect the RTS second review requirements (Annex A).

Paragraph 11.565
“…..Therefore, a joint approach is being pursued by Pembrokeshire, Ceredigion and Carmarthenshire for the provision of the allocation requirement for 3.626 million tonnes over the period up to 2038.”
The allocation specified in the RTS is a minimum. The wording should be amended accordingly.
“…..Therefore, a joint approach is being pursued by Pembrokeshire, Ceredigion and Carmarthenshire for the provision of the allocation requirement for a minimum 3.626 million tonnes over the period up to 2038.”

Paragraph 11.566
“In the event that the allocations for sand and gravel in the three constituent authorities are not sufficient to meet the 3.626 million tonnes over the period up to 2038, an ‘area of search’ for sand and gravel has been identified on the proposals map (with further areas being identified by Pembrokeshire and Ceredigion in their respective Revised LDPs). Furthermore, a statement of sub-regional collaboration (SSRC) is being produced which will demonstrate how the constituent Authorities will satisfy the requirements of RTS2 in respect of future sand and gravel provision.”
Firstly, the 3.626mt is a minimum allocation and this should be reflected in the text.
Secondly, the comments above apply equally to this paragraph. In addition, the wording in paragraph 11.566 conflicts with paragraph 11.564. Paragraph 11.564 states “A statement of subregional collaboration (SSRC) has been produced which demonstrates how the constituent Authorities satisfy the requirements of RTS2”. However, this paragraph (11.566) states “a statement of sub-regional collaboration (SSRC) is being produced. (our underlining).
The wording is confusing and needs to be rectified. It is imperative that the adoption of the SSRC must follow the process outlined in the RTS 2nd Review.
Amend the text accordingly, firstly to reference the “minimum” allocation and secondly to clarify the status of the RTS.
“In the event that the allocations for sand and gravel in the three constituent authorities are not sufficient to meet the minimum 3.626 million tonnes”…..

Paragraph 11.567
“In respect of working the resource within the area of search, this will not be carried out within 100m of residential properties. Proposals for extraction will also need to accord with the criteria set out within Policy MR1 Mineral Proposals. On those elements of the area of search that contain grade 3a agricultural land, the need for extraction will be considered in accordance with paragraph 3.59 of PPW Ed.11.”
This paragraph does not properly reflect MTAN1 and should be amended accordingly. MTAN1 states “that the following minimum
distances should be adopted unless there are clear and justifiable reasons for reducing the distance. An example may be that, because of other means of control, there is very limited impact from the mineral extraction site.” (Our underlining)
For Sand and Gravel this should be 100m.
The wording should be amended to reflect MTAN1.
Amend the text to read ““In respect of working the resource within the area of search, this will not be carried out within 100m of residential properties unless there are clear and justifiable reasons for reducing the distance. Proposals for extraction will also need to accord with the criteria set out within Policy MR1 Mineral Proposals. On those elements of the area of search that contain grade 3a agricultural land, the need for extraction will be considered in accordance with paragraph 3.59 of PPW Ed.11.”

Policy MR2: Mineral Buffer Zones
This Policy states: “Provision has been made for Buffer Zones around all sites with extant planning permission for mineral working.”
PPW requires that Buffer Zones are provided as “areas of protection around permitted and proposed mineral workings” also “buffer zones should be identified in development plans around existing or proposed minerals sites” (Our underlining). This is also reflected in MTAN1.
Amend the text to read: “Provision has been made for Buffer Zones around all sites with extant planning permission for mineral working and proposed mineral workings.” We note the amendment to para 11.571 to reflect this.

MR3: Mineral Safeguarding Areas
The policy states “Planning permission will not be granted for development proposals where they would permanently sterilise resources of aggregate….”
We note changes from the previous wording, but feel this does not reflect the wider requirements of PPW in terms of minerals resources and infrastructure. Minerals safeguarding is not solely about safeguarding aggregate resources. This should include a wider minerals base and minerals infrastructure.
Amend the wording to read “Planning permission will not be granted for development proposals where they would permanently sterilise mineral resources and minerals infrastructure.

Paragraph 11.573
The wording states “PPW stresses the importance of safeguarding mineral resources that meet society’s needs now and in the future.”
PPW also stresses the importance of safeguarding “minerals related infrastructure” (para 5.14.7). The wording should be amended to reflect PPW.
Amend the wording to read “PPW stresses the importance of safeguarding mineral resources that meet society’s needs now and in the future, together with minerals related infrastructure.”

Include a further Strategic Objective to reflect the need for a sustainable and adequate supply of minerals.

Dear Sir/Madam

2nd DEPOSIT REVISED CARMARTHENSHIRE LOCAL DEVELOPMENT PLAN 2018 - 2033

The Mineral Products Association (MPA) is the trade association for the aggregates, asphalt, cement, concrete, dimension stone, lime, mortar and silica sand industries. With the affiliation of British Precast, the British Association of Reinforcement (BAR), Eurobitume, MPA Northern Ireland, MPA Scotland and the British Calcium Carbonate Federation, it has a growing membership of over 530 companies and is the sectoral voice for mineral products. MPA membership is made up of the vast majority of independent SME quarrying companies throughout the UK, as well as the 9 major international and global companies. It covers 100% of UK cement production, 90% of GB aggregates production, 95% of asphalt and over 70% of ready-mixed concrete and precast concrete production. In 2016, the industry supplied £18 billion worth of materials and services to the Economy. It is the largest supplier to the construction industry, which had annual output valued at £169 billion in 2018. Industry production represents the largest materials flow in the UK economy and is also one of the largest manufacturing sectors. For more information visit: www.mineralproducts.org.

Thank you for consulting us on the above document. Our comments are appended to this letter. For ease of reference where we have proposed amendments to the text, we have struck through text (xxxxxx) to be deleted and used bold underlined text (xxxxxx) for proposed insertions.

If you require clarification on any of the points made, please do not hesitate to contact us. We welcome future engagement on this matter. We should be grateful if you could forward future correspondence to the email below.

Yours faithfully

Nick Horsley

Director of Planning, MPA Wales

Section 7.6
SO5
The formatting of the document is confusing in that SO5 appears before SO3 and SO4
Amend the formatting of the document and ensure SO3, SO4 and SO5 appear in the correct order.

Section 7.6
Strategic Objectives
It remains unclear why the provision of a sustainable and adequate supply of minerals is not identified as a Strategic Objective. This is a fundamental requirement of PPW and the need for minerals is the thread which stiches together many of the strategic objective identified, providing raw materials to deliver and address issues such as employment, housing, climate change, infrastructure, transport and environmental aspirations.
Include a further Strategic Objective to reflect the need for a sustainable and adequate supply of minerals.

Policy BHE1: Listed Buildings and Conservation Areas
Subsections 2. & 3. State:
“2. Developments within or adjacent to a conservation area will be permitted, where it would preserve or enhance the character or appearance of the conservation area, or its setting.
3. New developments in conservation areas should be of a high standard of design which responds to the area’s special characteristics and features.”
It remains unclear how the requirements of these subsections will be achieved. Maintaining the characteristic fabric of these buildings and conservation areas routinely requires an indigenous supply of local stone and materials, sympathetic to the character of the area and its buildings. There are no policies within the plan supporting the development of indigenous sources of building stone/materials.
Clarify within the plan how the characteristics of conservation areas and listed buildings will be maintained using materials sympathetic to the area. Sources of indigenous building materials will be needed and reflected within the policies in the plan.

Strategic Policy SP 18: Mineral Resources
Subsection a) states “Ensuring an adequate supply of minerals, including maintaining an adequate landbank of permitted aggregate reserves (a minimum 10 years for hard crushed rock, and a minimum 7 years for sand and gravel) throughout the Plan period;”
We welcome the amendments now incorporated.

Strategic Policy SP 18: Mineral Resources
Subsection c) states “Safeguarding minerals infrastructure, and areas underlain by minerals of economic importance where they could be worked in the future, to ensure that such resources and infrastructure are not unnecessarily sterilised by other forms of development;”
We welcome the amendments now incorporated

Paragraph 11.564
“For crushed rock, Carmarthenshire forms part of the Swansea City Sub-region, along with the local authorities of Swansea and Neath Port Talbot. Although at present, Swansea is unable to demonstrate an inability to meet RTS2 apportionments, there are more than sufficient reserves within NPT and Carmarthenshire to take up the joint apportionment within this period without resulting in under provision. A statement of subregional collaboration (SSRC) has been produced which demonstrates how the constituent Authorities satisfy the requirements of RTS2 in respect of future crushed rock provision.”
We have concerns that the approach proposed does not accord with the RTS, not least that the concerns raised in our response to the draft Swansea SSRC, dated 19th November 2020 have not been addressed. Where authorities are seeking to “absorb” apportionments from neighbouring authorities, it is necessary that there is a corresponding increase in provision within those authorities, as required by MTAN 1. The receiving authorities will need to increase their apportionments (and, where necessary, allocations), to ensure that as a minimum, the overall requirements for ongoing supply within that sub-region, as set out in the RTS, are met (both numerically and in terms of aggregate type). It will not normally be appropriate to merely transfer apportionments to an LPA with sufficient existing reserves to arithmetically absorb the apportionment, without reference to the additional consideration of productive capacity. Whilst the shortfall in allocation relates primarily to Swansea, it is inappropriate for this flaw to be reflected in the Carmarthenshire RLDP.
Amend the text accordingly to reflect the RTS second review requirements (Annex A).

Paragraph 11.565
“…..Therefore, a joint approach is being pursued by Pembrokeshire, Ceredigion and Carmarthenshire for the provision of the allocation requirement for 3.626 million tonnes over the period up to 2038.”
The allocation specified in the RTS is a minimum. The wording should be amended accordingly.
“…..Therefore, a joint approach is being pursued by Pembrokeshire, Ceredigion and Carmarthenshire for the provision of the allocation requirement for a minimum 3.626 million tonnes over the period up to 2038.”

Paragraph 11.566
“In the event that the allocations for sand and gravel in the three constituent authorities are not sufficient to meet the 3.626 million tonnes over the period up to 2038, an ‘area of search’ for sand and gravel has been identified on the proposals map (with further areas being identified by Pembrokeshire and Ceredigion in their respective Revised LDPs). Furthermore, a statement of sub-regional collaboration (SSRC) is being produced which will demonstrate how the constituent Authorities will satisfy the requirements of RTS2 in respect of future sand and gravel provision.”
Firstly, the 3.626mt is a minimum allocation and this should be reflected in the text.
Secondly, the comments above apply equally to this paragraph. In addition, the wording in paragraph 11.566 conflicts with paragraph 11.564. Paragraph 11.564 states “A statement of subregional collaboration (SSRC) has been produced which demonstrates how the constituent Authorities satisfy the requirements of RTS2”. However, this paragraph (11.566) states “a statement of sub-regional collaboration (SSRC) is being produced. (our underlining).
The wording is confusing and needs to be rectified. It is imperative that the adoption of the SSRC must follow the process outlined in the RTS 2nd Review.
Amend the text accordingly, firstly to reference the “minimum” allocation and secondly to clarify the status of the RTS.
“In the event that the allocations for sand and gravel in the three constituent authorities are not sufficient to meet the minimum 3.626 million tonnes”…..

Paragraph 11.567
“In respect of working the resource within the area of search, this will not be carried out within 100m of residential properties. Proposals for extraction will also need to accord with the criteria set out within Policy MR1 Mineral Proposals. On those elements of the area of search that contain grade 3a agricultural land, the need for extraction will be considered in accordance with paragraph 3.59 of PPW Ed.11.”
This paragraph does not properly reflect MTAN1 and should be amended accordingly. MTAN1 states “that the following minimum
distances should be adopted unless there are clear and justifiable reasons for reducing the distance. An example may be that, because of other means of control, there is very limited impact from the mineral extraction site.” (Our underlining)
For Sand and Gravel this should be 100m.
The wording should be amended to reflect MTAN1.
Amend the text to read ““In respect of working the resource within the area of search, this will not be carried out within 100m of residential properties unless there are clear and justifiable reasons for reducing the distance. Proposals for extraction will also need to accord with the criteria set out within Policy MR1 Mineral Proposals. On those elements of the area of search that contain grade 3a agricultural land, the need for extraction will be considered in accordance with paragraph 3.59 of PPW Ed.11.”

Policy MR2: Mineral Buffer Zones
This Policy states: “Provision has been made for Buffer Zones around all sites with extant planning permission for mineral working.”
PPW requires that Buffer Zones are provided as “areas of protection around permitted and proposed mineral workings” also “buffer zones should be identified in development plans around existing or proposed minerals sites” (Our underlining). This is also reflected in MTAN1.
Amend the text to read: “Provision has been made for Buffer Zones around all sites with extant planning permission for mineral working and proposed mineral workings.” We note the amendment to para 11.571 to reflect this.

MR3: Mineral Safeguarding Areas
The policy states “Planning permission will not be granted for development proposals where they would permanently sterilise resources of aggregate….”
We note changes from the previous wording, but feel this does not reflect the wider requirements of PPW in terms of minerals resources and infrastructure. Minerals safeguarding is not solely about safeguarding aggregate resources. This should include a wider minerals base and minerals infrastructure.
Amend the wording to read “Planning permission will not be granted for development proposals where they would permanently sterilise mineral resources and minerals infrastructure.

Paragraph 11.573
The wording states “PPW stresses the importance of safeguarding mineral resources that meet society’s needs now and in the future.”
PPW also stresses the importance of safeguarding “minerals related infrastructure” (para 5.14.7). The wording should be amended to reflect PPW.
Amend the wording to read “PPW stresses the importance of safeguarding mineral resources that meet society’s needs now and in the future, together with minerals related infrastructure.”

No change

Barratt David Wilson Homes South Wales Ltd (“BDW Homes”) does not consider that the Deposit Revised Carmarthenshire LDP is sound as the Plan will not deliver the required number and mix of housing over the Plan period, for the reasons we have stated on the online consultation form, in relation to the deliverability of the proposed site allocations.
BDW has prepared a site-specific representation in support of the proposed allocation of Land off Heol-y-Mynydd, Bryn for residential use within the Second Deposit Revised Carmarthenshire Local Development Plan. This was previously submitted at the Candidate Sites stage of the LDP's preparation together with a Candidate Site Assessment Questionnaire. It is supported by the following documentation, which confirm the site’s suitability for residential development:
- Site Boundary Plan by Roberts Limbrick Ltd (ref: 9047 PL01);
- Concept Masterplan by Roberts Limbrick Ltd (ref: 9047 SK01A);
- Issues & Opportunities Plan by Roberts Limbrick Ltd (ref: 9047 SK02);
- Drainage Technical Note by BDW Homes (August 2018);
- Extended Phase I Habitat Survey by TerrAqua Ecological Services Ltd (July 2018);
- Initial Landscape and Visual Appraisal by Anthony Jellard Associates (28th July 2018); and
- Technical Note by Lime Transport (ref: 18130, 11th June 2018).
The above documentation is enclosed with this representation.
It is respectfully requested that Land off Heol-y-Mynydd, Bryn is included within the Deposit Revised LDP as a residential allocation for up to 160 homes.

Covering letter:

Dear Sir /Madam,
Carmarthenshire Second Deposit Revised Local Development Plan
Representation on behalf of Barratt David Wilson Homes South Wales Ltd regarding Land off
Heol-y-Mynydd, Bryn (SR/086/053)
We are pleased to submit this representation on behalf of Barratt David Wilson Homes South Wales
Ltd (‘BDW Homes’) in response to the current consultation on the Carmarthenshire Second Deposit
Revised Local Development Plan Consultation for the site Land off Heol-y-Mynydd, Bryn. The site is
recorded in the 2023 Site Assessment Table under reference SR/086/053 (Land off Heol-y-Mynydd,
Bryn).
Barratt Homes has an option agreement for the site, which has been promoted in part for residential
development through the previous LDP process. This submission is also made alongside the recent
representations in response to the Carmarthenshire Revised Local Development Plan 2018-2033.
Candidate Site and Preferred Strategy consultations.
Executive Summary
• We do not support the Council’s Strategic Policy SP4 housing requirement of 8,822 homes for
the plan period (2018-2033). We consider the Plan Period should be rolled forward by a further
two years, to 2021-2036, to take into account the time lost owing to the NRW intervention and
COVID-19 pandemic.
• We do not support Policy HOM1 which includes a number of housing allocations located within
Phosphate Sensitive Catchment Areas. The Council should reconsider their spatial distribution
of housing allocations to include additional allocations outside of phosphate areas.
• Accordingly, Bryn can accommodate future growth requirements, and the land off Heol-y-
Mynydd, Bryn should be included as an allocation.
Page 2 of 7
We have set out our full response to the 2nd Deposit Revised Plan below as well as our response
which was submitted as part of the previous Deposit Plan.
Paragraph 5.6 – A Carmarthenshire of Cohesive Communities
BDW Homes welcomes the recognition of the impact of the lack of delivery of new housing upon the
creation of Cohesive Communities. The delivery of new homes and the maintenance of a five year
supply of housing is essential to ensure that Cohesive Communities are created in line with the Well
Being of Future Generations Act. It is therefore crucial that proposed site allocations within the Plan
are deliverable. This is essential to ensure that the Plan accords with Test of Soundness 3. As
identified in later sections BDW Homes raise a number of concerns regarding proposed Allocations
and their impact upon the Council’s proposed Trajectory and lack of deliverability which has effects
Cohesive Communities.
Paragraph 6.4
BDW Homes is supportive of the proposed Vision for ‘One Carmarthenshire’ as it seeks to achieve an
appropriate balance between environmental, economic, social and cultural objectives. The proposed
Vision therefore complies with the holistic ‘Placemaking’ approach advocated by Planning Policy
Wales (Edition 10, p.16). The Vision also accurately reflects the Well-being Goals set out within the
WBFGA. BDW Homes particularly welcomes direct references within the Vision to securing
prosperous, cohesive and sustainable communities and the economic aspirations associated with the
Swansea Bay City Region.
Paragraph 7.6: Strong Connections - Strongly connected people, places and organisations that
are able to adapt to change.
BDW Homes is supportive of the wording of Strategic Objective SO6, which seeks to ensure that ‘The
principles of spatial sustainability are upheld by directing development to sustainable locations with
access to services and facilities..’. This Strategic Objective is therefore consistent with the ‘Key
Planning Principles’ set out within Planning Policy Wales (Edition 10, p.18) which seeks to ensure that
the planning system contributes to the long-term economic well-being of Wales, by making use of
existing infrastructure and facilities.
Paragraph 7.6: Prosperous People and Places - To maximise opportunities for people and
places in both urban and rural parts of our county.
BDW Homes supports Strategic Objective SO10, which refers to the delivery of an appropriate number
and mix of new housing meet society’s needs. The need to ensure that “there is sufficient housing
land available to meet the need for new private market and affordable housing” is one of the key issues
within the ‘Active & Social Places’ theme within Planning Policy Wales.
Paragraph 8.2
BDW Homes agrees that the use of the WG 2018-based subnational projections (4,359 homes) would
impact upon the historic growth of the County and would not deliver the quantity of homes required.
To this end, BDW broadly Homes supports the Council’s Preferred Strategic Growth Option, the tenyear
trend-based projection which would allow for 8,822 homes, on the basis that it seeks an ambitious
Page 3 of 7
but achievable level of growth to support the aspirations of the Strategic Regeneration Plan for
Carmarthenshire. However, BDW feels that a higher level of growth should be sought on the basis of
the National Development Framework’s aspirations for the South West National Growth Area, with its
focus on the Llanelli Area and secondary town of Carmarthen.
Preferred Option – Balanced Community and Sustainable Growth Strategy
BDW Homes is broadly supportive of the ‘Balanced Community and Sustainable Growth Strategy’ and
note that the strategy considers the role and function of settlements in seeking to assign growth. This
should ensure that new housing is directed to those areas that are likely to attract higher levels of
employment generation. In this regard, it is considered that more growth could be accommodated
within the Llanelli and South Gwendraeth Area.
Paragraph 9.11
BDW Homes supports the strategy of building in flexibility to ensure the delivery of sustainable growth
and to overcome any potential unforeseen deliverability issues, in line with national guidance.
However, the Council should ensure that sites are viable and deliverable before they are taken forward
as firm allocations in the LDP. There are concerns about several sites and their ability to contribute to
delivering the housing growth projected over the Plan period. Paragraph 4.2.10 of PPW (Edition 10)
states that, “The supply of land to meet the housing requirement proposed in a development plan must
be deliverable.”
Paragraph 11.79
It is acknowledged that windfalls can make an important contribution to the overall housing
requirement for the County. However, in order to ensure the deliverability of the housing requirement
then sufficient sites should be identified and allocated to meet this requirement. Windfall sites are
unidentified by definition and therefore should form part of the flexibility allowance only.
Strategic Policy SP4: A Sustainable Approach to Providing New Homes
Draft Strategic Policy SP4 sets out the Council’s overall housing requirement of 8,822 homes for the
plan period (2018-2033) and so provision has been made for 9,704 new homes. Owing to the delays
caused by COVID-19, which has resulted in a second Deposit Plan consultation, we consider it
necessary for the plan period, currently set at 2018-2033 to be rolled forward to 2021-2036.
Consequently, the Authority should consider the need for a higher provision of housing to
accommodate the additional two years for the plan period. Carmarthenshire County Council (CCC)
have noted that they consider that the Deposit Plan meets the ‘Tests of Soundness’ and so is in
general conformity with Future Wales 2040. According to the Planning and Compulsory Purchase Act
2004 and set out within National Planning Policy, there is a fundamental requirement for any Local
Development Plan to be found sound. To ensure that this policy meets the tests of soundness and is
justified, and effective, those allocations located within phosphate sensitive areas should be removed
and replaced with sites located outside of these areas.
To this end, BDW consider the inclusion of housing allocations within phosphate sensitive areas in the
2nd Deposit Revised Plan to be unsound as it fails the Council’s own Test of Soundness in respect of:
Page 4 of 7
• Test 2 the housing allocations located within phosphate areas are not sufficiently robust or
flexible to ensure compliance with national policy as set out in Planning Policy Wales (PPW),
and;
• Test 3 in allowing the inclusion of phosphate sensitive housing allocations the plan will not be
implemented owing to the lack of an agreed mitigation measure for phosphorous sites. To this
end, the projected housing figure will not be met.
To ensure the consistent delivery of dwellings, it is considered that additional sites should be allocated
within the Draft LDP to provide a contingency, should some allocated sites fail to be delivered at the
rate set out within the housing trajectory. This would ensure the consistent delivery of homes
throughout the Plan period.
Policy HOM1: Housing Allocations
BDW objects to a number of proposed allocations owing to concerns in relation to their suitability and
deliverability. The previous Deposit Plan response in relation to HOM1 has been set out below:
PrC2/h4
No progress of effort has been made to bring the site forward for a prolonged period. The site is not
considered to be deliverable within the Plan period.
PrC2/h10
BDW objects to the proposed allocation of this site. We have serious concerns regarding its
deliverability. The site is a former quarry and is covered by dense vegetation with complicated access
arrangements which are affected by Flood Risk Zone C2 constraints. It has not been demonstrated
that this site can be accessed without unacceptable flood risk consequences. The site is also
brownfield in nature, and it should be demonstrated that appropriate ground investigation work has
been undertaken to demonstrate that the site is viable and deliverable. The site should be removed
as a draft allocation from the Deposit Revised LDP.
PrC2/h22
BDW objects to the allocation of this site. It comprises an existing allocation within the adopted LDP
which is proposed to be ‘rolled’ forward by CCC. There is no evidenced justification for the continued
allocation of this site, given that no progress has been made since its first allocation in 2014. The
delivery of this site has been pushed back a year in every JHLAS since at least 201, which confirms
the lack of progress and deliverability of this site. This site should be removed as a draft allocation
from the Deposit Revised LDP.
PrC2/h23
The site is not deliverable during the plan period. It has a number of constraints, is not sustainable in
terms of its location and it is not supported by a robust masterplan.
Sec5/h2
The site is constrained, is not viable and is not deliverable within the plan period.
Page 5 of 7
PrC3/h4
This is an historic allocation and there has been little progress in bringing the site forward for
development despite extensive marketing. The site is not deliverable within the Plan period.
PrC1/MU2
BDW is concerned that whilst this is a major urban extension to the south of Carmarthen, there is no
confirmation that an end user is in place in the form of a residential developer to deliver the quantum
of development proposed within the Plan period. The deliverability of this site is therefore questionable.
Phosphate Sensitive Catchment Areas
In addition to the above, BDW Homes wholly object to a number of additional housing allocations
which fall within Phosphate Sensitive Catchment Areas. A detailed list of these housing allocations
have been provided in Table 1: List of Housing Allocations in Phosphates areas, as well as our detailed
response to each of the proposed housing allocation. A number of the sites have been included as
housing allocations as they have gained planning permission. We do not agree with the inclusion of
these sites as they should be listed as commitments. Similarly, those allocations included as they have
a planning application submitted and pending should not be automatically included as an allocation.
This is contrary to the tests of soundness, as those allocations being rolled forward within phosphate
sensitive areas are currently not suitable nor deliverable owing to NRW phosphorous guidance.
With regards to CCC’s efforts to solve the phosphate issue within the County, investigative work has
been undertaken which forms part of the LDP evidence base. From reviewing this work, it is evident
that CCC have no agreed mitigation measure to tackle the phosphate issue. A nutrient budget
calculator has been constructed which calculates the phosphate levels that a proposed residential
development in Carmarthenshire could produce. This is not a mitigation measure and so
Carmarthenshire are yet to find a suitable phosphate solution.
In addition, a Nutrient Mitigation Options Technical Review (2022) has been prepared by Ricardo
Energy & Environmental, outlining guidance on phosphorous mitigation options for use in
Carmarthenshire. Although the report provides a short list and review of possible mitigation options no
set option has been agreed upon. The report concludes ‘it is likely that all schemes will require
engagement with/by CCC, Natural Resources Wales, the Nutrient Management Board and
developers. Other stakeholders like landowners/land managers, Dwr Cymru Welsh Water and
environmental NGOs are likely to also have a role in delivery of specific solutions.’
To this end, BDW Homes wholly object to the allocation of sites within Phosphate Catchment areas
owing to the County having no established mitigation solution for development in phosphate areas. As
such, all housing allocations which fall within phosphate sensitive areas should be discounted from
the LDP, as these suits are not suitable nor deliverable. Additional more suitable sites should be
sought which are located outside of the phosphate sensitive areas. Land off Heol-y-Mynydd, Bryn is
a suitable location for development, being located adjacent to the settlement of Bryn/Llanelli and
located outside a phosphate sensitive area.
Page 6 of 7
Candidate Site Assessment - Land off Heol-y-Mynydd, Bryn (SR/086/053)
From reviewing the Candidate Site Assessment Table 2023 it appears Candidate Site (SR/086/053),
Land off Heol-y-Mynydd, has been filtered out during the stage 2 assessment process, owing to
concerns at the over intensification of residential development within the immediate area and that the
site will remain outside of the development limits. We wholly object to this decision and perceive the
assessment of the site as contrasting information in relation to the site’s constraints. Owing to the
allocation of two other sites within the settlement of Bryn, Maes Y Bryn (PrC2/h21) and Harddfan
(PrC2/h20), CCC have confirmed Bryn is a suitable location for development. Both housing allocations
will total 40 dwellings combined. Given Maes y Bryn benefits from planning permission for 34 dwellings
and planning conditions are currently being discharged, this site should not count towards the housing
provision of Bryn. On this basis, the proposed allocation of Land off Heol-y-Mynydd would not cause
an over intensification of the settlement of Bryn.
The candidate site presents an opportunity for a logical continuation of existing residential
development in Bryn. The Candidate Site is located within a sustainable location close to a number of
facilities and good transport links. This is evidenced in the accompanying Technical Note prepared by
Lime Transport confirms that desirable walking distances for commuting and school journeys is 500m,
while the acceptable walking distance is 1km and 2km comprises the preferred maximum. The majority
of roads in the vicinity of the Site (including Heol-y-Mynydd) accommodate pedestrian facilities,
thereby linking the Site to all local services and facilities.
In terms of local services and facilities, the Site is situated approximately 400m from Bryn Community
Primary School and 3km from Bryngwyn School. The Site is also situated 1.6km from Llwynhendy
Health Centre, 600m from Bryn Post Office and 600m from Bryn Village Hall. The Site is also situated
approximately 1.5km from Llwynhendy, which provides a wide range of services including a library,
convenience store, public house and various takeaway restaurants, beauty salons and other retail
stores. Llanelli Town Centre is situated 4km from the Site and Parc Trostre Retail Park is situated 3km
from the Site, both of which provide a variety of services and employment opportunities.
With regards to public transport, Table 2.1 of the Technical Note by Lime Transport confirms that the
Site is situated in close proximity (ranging from 450m to 1km) to a number of bus stops which provide
regular services to Llanelli, Pontarddulais and Swansea among other destinations. Llanelli train station
is also situated approximately 4km to the south-west of the Site, which is served by bus routes 110
and 111 which operate within the acceptable walking distance of the Site.
The submitted LVA states that due to recent and ongoing housing developments in the area, the
development of Land off Heol-y-Mynydd would now represent a logical rounding off of the settlement
boundary. Accordingly, we consider that Llanelli / Bryn is capable of accommodating a significant
proportion of the County’s growth over the next Plan period, and this Site is capable of making a
significant contribution to this growth.
A concept masterplan has been prepared by Roberts Limbrick Ltd illustrating the site can
accommodate up to 160 dwellings, open space, landscaping and associated infrastructure. This
proposed scale of development would accord with the Deposit Plan in terms of the scale of strategic
Page 7 of 7
site required to deliver the housing requirement. Additionally, it is considered to be an appropriate
extension to the settlement in this location.
The site falls within Cluster 2: Llanelli and Southern Gwendraeth Area which has been identified as a
‘national growth area’ within Future Wales. To this end, with the potential for up to 160 dwellings to be
delivered, this site is genuinely deliverable and can contribute to the identified housing need within the
locality.
Final Remarks
Overall, BDW Homes raise a number of concerns regarding the current Preferred Strategy, including:
• We do not support the Council’s Strategic Policy SP4 housing requirement of 8,822 homes for
the plan period (2018-2033). We consider the Plan Period should be rolled forward by a further
two years, to 2021-2036, to take into account the time lost owing to the NRW intervention and
COVID-19 pandemic, and is contrary to Tests of Soundness 2 & 3.
• Significant objections are raised in relation to Policy HOM1 which includes a number of
housing allocations located within Phosphate Sensitive Catchment Areas. The Council should
reconsider their spatial distribution of housing allocations to include additional allocations
outside of phosphate areas.
Consequently, support is provided for Land off Heol-y-Mynydd, Bryn, which is deliverable and
developer lead, it has a developer on board and ready to take the site forward. Accordingly,
Bryn/Llanelli can accommodate future growth requirements, and the land off Heol-y-Mynydd, Bryn
should be included as an allocation.
We would be grateful if we could be kept informed on the further progress of the plan and further
opportunities for engagement.
Yours sincerely,
Katherine Dowdall
Principal Planner

No change

Barratt David Wilson Homes South Wales Ltd (“BDW Homes”) does not consider that the Deposit Revised Carmarthenshire LDP is sound as the Plan will not deliver the required number and mix of housing over the Plan period, for the reasons we have stated on the online consultation form, in relation to the deliverability of the proposed site allocations.
BDW has prepared a site-specific representation in support of the proposed allocation of Land off Heol-y-Mynydd, Bryn for residential use within the Second Deposit Revised Carmarthenshire Local Development Plan. This was previously submitted at the Candidate Sites stage of the LDP's preparation together with a Candidate Site Assessment Questionnaire. It is supported by the following documentation, which confirm the site’s suitability for residential development:
- Site Boundary Plan by Roberts Limbrick Ltd (ref: 9047 PL01);
- Concept Masterplan by Roberts Limbrick Ltd (ref: 9047 SK01A);
- Issues & Opportunities Plan by Roberts Limbrick Ltd (ref: 9047 SK02);
- Drainage Technical Note by BDW Homes (August 2018);
- Extended Phase I Habitat Survey by TerrAqua Ecological Services Ltd (July 2018);
- Initial Landscape and Visual Appraisal by Anthony Jellard Associates (28th July 2018); and
- Technical Note by Lime Transport (ref: 18130, 11th June 2018).
The above documentation is enclosed with this representation.
It is respectfully requested that Land off Heol-y-Mynydd, Bryn is included within the Deposit Revised LDP as a residential allocation for up to 160 homes.

Covering letter:

Dear Sir /Madam,
Carmarthenshire Second Deposit Revised Local Development Plan
Representation on behalf of Barratt David Wilson Homes South Wales Ltd regarding Land off
Heol-y-Mynydd, Bryn (SR/086/053)
We are pleased to submit this representation on behalf of Barratt David Wilson Homes South Wales
Ltd (‘BDW Homes’) in response to the current consultation on the Carmarthenshire Second Deposit
Revised Local Development Plan Consultation for the site Land off Heol-y-Mynydd, Bryn. The site is
recorded in the 2023 Site Assessment Table under reference SR/086/053 (Land off Heol-y-Mynydd,
Bryn).
Barratt Homes has an option agreement for the site, which has been promoted in part for residential
development through the previous LDP process. This submission is also made alongside the recent
representations in response to the Carmarthenshire Revised Local Development Plan 2018-2033.
Candidate Site and Preferred Strategy consultations.
Executive Summary
• We do not support the Council’s Strategic Policy SP4 housing requirement of 8,822 homes for
the plan period (2018-2033). We consider the Plan Period should be rolled forward by a further
two years, to 2021-2036, to take into account the time lost owing to the NRW intervention and
COVID-19 pandemic.
• We do not support Policy HOM1 which includes a number of housing allocations located within
Phosphate Sensitive Catchment Areas. The Council should reconsider their spatial distribution
of housing allocations to include additional allocations outside of phosphate areas.
• Accordingly, Bryn can accommodate future growth requirements, and the land off Heol-y-
Mynydd, Bryn should be included as an allocation.
Page 2 of 7
We have set out our full response to the 2nd Deposit Revised Plan below as well as our response
which was submitted as part of the previous Deposit Plan.
Paragraph 5.6 – A Carmarthenshire of Cohesive Communities
BDW Homes welcomes the recognition of the impact of the lack of delivery of new housing upon the
creation of Cohesive Communities. The delivery of new homes and the maintenance of a five year
supply of housing is essential to ensure that Cohesive Communities are created in line with the Well
Being of Future Generations Act. It is therefore crucial that proposed site allocations within the Plan
are deliverable. This is essential to ensure that the Plan accords with Test of Soundness 3. As
identified in later sections BDW Homes raise a number of concerns regarding proposed Allocations
and their impact upon the Council’s proposed Trajectory and lack of deliverability which has effects
Cohesive Communities.
Paragraph 6.4
BDW Homes is supportive of the proposed Vision for ‘One Carmarthenshire’ as it seeks to achieve an
appropriate balance between environmental, economic, social and cultural objectives. The proposed
Vision therefore complies with the holistic ‘Placemaking’ approach advocated by Planning Policy
Wales (Edition 10, p.16). The Vision also accurately reflects the Well-being Goals set out within the
WBFGA. BDW Homes particularly welcomes direct references within the Vision to securing
prosperous, cohesive and sustainable communities and the economic aspirations associated with the
Swansea Bay City Region.
Paragraph 7.6: Strong Connections - Strongly connected people, places and organisations that
are able to adapt to change.
BDW Homes is supportive of the wording of Strategic Objective SO6, which seeks to ensure that ‘The
principles of spatial sustainability are upheld by directing development to sustainable locations with
access to services and facilities..’. This Strategic Objective is therefore consistent with the ‘Key
Planning Principles’ set out within Planning Policy Wales (Edition 10, p.18) which seeks to ensure that
the planning system contributes to the long-term economic well-being of Wales, by making use of
existing infrastructure and facilities.
Paragraph 7.6: Prosperous People and Places - To maximise opportunities for people and
places in both urban and rural parts of our county.
BDW Homes supports Strategic Objective SO10, which refers to the delivery of an appropriate number
and mix of new housing meet society’s needs. The need to ensure that “there is sufficient housing
land available to meet the need for new private market and affordable housing” is one of the key issues
within the ‘Active & Social Places’ theme within Planning Policy Wales.
Paragraph 8.2
BDW Homes agrees that the use of the WG 2018-based subnational projections (4,359 homes) would
impact upon the historic growth of the County and would not deliver the quantity of homes required.
To this end, BDW broadly Homes supports the Council’s Preferred Strategic Growth Option, the tenyear
trend-based projection which would allow for 8,822 homes, on the basis that it seeks an ambitious
Page 3 of 7
but achievable level of growth to support the aspirations of the Strategic Regeneration Plan for
Carmarthenshire. However, BDW feels that a higher level of growth should be sought on the basis of
the National Development Framework’s aspirations for the South West National Growth Area, with its
focus on the Llanelli Area and secondary town of Carmarthen.
Preferred Option – Balanced Community and Sustainable Growth Strategy
BDW Homes is broadly supportive of the ‘Balanced Community and Sustainable Growth Strategy’ and
note that the strategy considers the role and function of settlements in seeking to assign growth. This
should ensure that new housing is directed to those areas that are likely to attract higher levels of
employment generation. In this regard, it is considered that more growth could be accommodated
within the Llanelli and South Gwendraeth Area.
Paragraph 9.11
BDW Homes supports the strategy of building in flexibility to ensure the delivery of sustainable growth
and to overcome any potential unforeseen deliverability issues, in line with national guidance.
However, the Council should ensure that sites are viable and deliverable before they are taken forward
as firm allocations in the LDP. There are concerns about several sites and their ability to contribute to
delivering the housing growth projected over the Plan period. Paragraph 4.2.10 of PPW (Edition 10)
states that, “The supply of land to meet the housing requirement proposed in a development plan must
be deliverable.”
Paragraph 11.79
It is acknowledged that windfalls can make an important contribution to the overall housing
requirement for the County. However, in order to ensure the deliverability of the housing requirement
then sufficient sites should be identified and allocated to meet this requirement. Windfall sites are
unidentified by definition and therefore should form part of the flexibility allowance only.
Strategic Policy SP4: A Sustainable Approach to Providing New Homes
Draft Strategic Policy SP4 sets out the Council’s overall housing requirement of 8,822 homes for the
plan period (2018-2033) and so provision has been made for 9,704 new homes. Owing to the delays
caused by COVID-19, which has resulted in a second Deposit Plan consultation, we consider it
necessary for the plan period, currently set at 2018-2033 to be rolled forward to 2021-2036.
Consequently, the Authority should consider the need for a higher provision of housing to
accommodate the additional two years for the plan period. Carmarthenshire County Council (CCC)
have noted that they consider that the Deposit Plan meets the ‘Tests of Soundness’ and so is in
general conformity with Future Wales 2040. According to the Planning and Compulsory Purchase Act
2004 and set out within National Planning Policy, there is a fundamental requirement for any Local
Development Plan to be found sound. To ensure that this policy meets the tests of soundness and is
justified, and effective, those allocations located within phosphate sensitive areas should be removed
and replaced with sites located outside of these areas.
To this end, BDW consider the inclusion of housing allocations within phosphate sensitive areas in the
2nd Deposit Revised Plan to be unsound as it fails the Council’s own Test of Soundness in respect of:
Page 4 of 7
• Test 2 the housing allocations located within phosphate areas are not sufficiently robust or
flexible to ensure compliance with national policy as set out in Planning Policy Wales (PPW),
and;
• Test 3 in allowing the inclusion of phosphate sensitive housing allocations the plan will not be
implemented owing to the lack of an agreed mitigation measure for phosphorous sites. To this
end, the projected housing figure will not be met.
To ensure the consistent delivery of dwellings, it is considered that additional sites should be allocated
within the Draft LDP to provide a contingency, should some allocated sites fail to be delivered at the
rate set out within the housing trajectory. This would ensure the consistent delivery of homes
throughout the Plan period.
Policy HOM1: Housing Allocations
BDW objects to a number of proposed allocations owing to concerns in relation to their suitability and
deliverability. The previous Deposit Plan response in relation to HOM1 has been set out below:
PrC2/h4
No progress of effort has been made to bring the site forward for a prolonged period. The site is not
considered to be deliverable within the Plan period.
PrC2/h10
BDW objects to the proposed allocation of this site. We have serious concerns regarding its
deliverability. The site is a former quarry and is covered by dense vegetation with complicated access
arrangements which are affected by Flood Risk Zone C2 constraints. It has not been demonstrated
that this site can be accessed without unacceptable flood risk consequences. The site is also
brownfield in nature, and it should be demonstrated that appropriate ground investigation work has
been undertaken to demonstrate that the site is viable and deliverable. The site should be removed
as a draft allocation from the Deposit Revised LDP.
PrC2/h22
BDW objects to the allocation of this site. It comprises an existing allocation within the adopted LDP
which is proposed to be ‘rolled’ forward by CCC. There is no evidenced justification for the continued
allocation of this site, given that no progress has been made since its first allocation in 2014. The
delivery of this site has been pushed back a year in every JHLAS since at least 201, which confirms
the lack of progress and deliverability of this site. This site should be removed as a draft allocation
from the Deposit Revised LDP.
PrC2/h23
The site is not deliverable during the plan period. It has a number of constraints, is not sustainable in
terms of its location and it is not supported by a robust masterplan.
Sec5/h2
The site is constrained, is not viable and is not deliverable within the plan period.
Page 5 of 7
PrC3/h4
This is an historic allocation and there has been little progress in bringing the site forward for
development despite extensive marketing. The site is not deliverable within the Plan period.
PrC1/MU2
BDW is concerned that whilst this is a major urban extension to the south of Carmarthen, there is no
confirmation that an end user is in place in the form of a residential developer to deliver the quantum
of development proposed within the Plan period. The deliverability of this site is therefore questionable.
Phosphate Sensitive Catchment Areas
In addition to the above, BDW Homes wholly object to a number of additional housing allocations
which fall within Phosphate Sensitive Catchment Areas. A detailed list of these housing allocations
have been provided in Table 1: List of Housing Allocations in Phosphates areas, as well as our detailed
response to each of the proposed housing allocation. A number of the sites have been included as
housing allocations as they have gained planning permission. We do not agree with the inclusion of
these sites as they should be listed as commitments. Similarly, those allocations included as they have
a planning application submitted and pending should not be automatically included as an allocation.
This is contrary to the tests of soundness, as those allocations being rolled forward within phosphate
sensitive areas are currently not suitable nor deliverable owing to NRW phosphorous guidance.
With regards to CCC’s efforts to solve the phosphate issue within the County, investigative work has
been undertaken which forms part of the LDP evidence base. From reviewing this work, it is evident
that CCC have no agreed mitigation measure to tackle the phosphate issue. A nutrient budget
calculator has been constructed which calculates the phosphate levels that a proposed residential
development in Carmarthenshire could produce. This is not a mitigation measure and so
Carmarthenshire are yet to find a suitable phosphate solution.
In addition, a Nutrient Mitigation Options Technical Review (2022) has been prepared by Ricardo
Energy & Environmental, outlining guidance on phosphorous mitigation options for use in
Carmarthenshire. Although the report provides a short list and review of possible mitigation options no
set option has been agreed upon. The report concludes ‘it is likely that all schemes will require
engagement with/by CCC, Natural Resources Wales, the Nutrient Management Board and
developers. Other stakeholders like landowners/land managers, Dwr Cymru Welsh Water and
environmental NGOs are likely to also have a role in delivery of specific solutions.’
To this end, BDW Homes wholly object to the allocation of sites within Phosphate Catchment areas
owing to the County having no established mitigation solution for development in phosphate areas. As
such, all housing allocations which fall within phosphate sensitive areas should be discounted from
the LDP, as these suits are not suitable nor deliverable. Additional more suitable sites should be
sought which are located outside of the phosphate sensitive areas. Land off Heol-y-Mynydd, Bryn is
a suitable location for development, being located adjacent to the settlement of Bryn/Llanelli and
located outside a phosphate sensitive area.
Page 6 of 7
Candidate Site Assessment - Land off Heol-y-Mynydd, Bryn (SR/086/053)
From reviewing the Candidate Site Assessment Table 2023 it appears Candidate Site (SR/086/053),
Land off Heol-y-Mynydd, has been filtered out during the stage 2 assessment process, owing to
concerns at the over intensification of residential development within the immediate area and that the
site will remain outside of the development limits. We wholly object to this decision and perceive the
assessment of the site as contrasting information in relation to the site’s constraints. Owing to the
allocation of two other sites within the settlement of Bryn, Maes Y Bryn (PrC2/h21) and Harddfan
(PrC2/h20), CCC have confirmed Bryn is a suitable location for development. Both housing allocations
will total 40 dwellings combined. Given Maes y Bryn benefits from planning permission for 34 dwellings
and planning conditions are currently being discharged, this site should not count towards the housing
provision of Bryn. On this basis, the proposed allocation of Land off Heol-y-Mynydd would not cause
an over intensification of the settlement of Bryn.
The candidate site presents an opportunity for a logical continuation of existing residential
development in Bryn. The Candidate Site is located within a sustainable location close to a number of
facilities and good transport links. This is evidenced in the accompanying Technical Note prepared by
Lime Transport confirms that desirable walking distances for commuting and school journeys is 500m,
while the acceptable walking distance is 1km and 2km comprises the preferred maximum. The majority
of roads in the vicinity of the Site (including Heol-y-Mynydd) accommodate pedestrian facilities,
thereby linking the Site to all local services and facilities.
In terms of local services and facilities, the Site is situated approximately 400m from Bryn Community
Primary School and 3km from Bryngwyn School. The Site is also situated 1.6km from Llwynhendy
Health Centre, 600m from Bryn Post Office and 600m from Bryn Village Hall. The Site is also situated
approximately 1.5km from Llwynhendy, which provides a wide range of services including a library,
convenience store, public house and various takeaway restaurants, beauty salons and other retail
stores. Llanelli Town Centre is situated 4km from the Site and Parc Trostre Retail Park is situated 3km
from the Site, both of which provide a variety of services and employment opportunities.
With regards to public transport, Table 2.1 of the Technical Note by Lime Transport confirms that the
Site is situated in close proximity (ranging from 450m to 1km) to a number of bus stops which provide
regular services to Llanelli, Pontarddulais and Swansea among other destinations. Llanelli train station
is also situated approximately 4km to the south-west of the Site, which is served by bus routes 110
and 111 which operate within the acceptable walking distance of the Site.
The submitted LVA states that due to recent and ongoing housing developments in the area, the
development of Land off Heol-y-Mynydd would now represent a logical rounding off of the settlement
boundary. Accordingly, we consider that Llanelli / Bryn is capable of accommodating a significant
proportion of the County’s growth over the next Plan period, and this Site is capable of making a
significant contribution to this growth.
A concept masterplan has been prepared by Roberts Limbrick Ltd illustrating the site can
accommodate up to 160 dwellings, open space, landscaping and associated infrastructure. This
proposed scale of development would accord with the Deposit Plan in terms of the scale of strategic
Page 7 of 7
site required to deliver the housing requirement. Additionally, it is considered to be an appropriate
extension to the settlement in this location.
The site falls within Cluster 2: Llanelli and Southern Gwendraeth Area which has been identified as a
‘national growth area’ within Future Wales. To this end, with the potential for up to 160 dwellings to be
delivered, this site is genuinely deliverable and can contribute to the identified housing need within the
locality.
Final Remarks
Overall, BDW Homes raise a number of concerns regarding the current Preferred Strategy, including:
• We do not support the Council’s Strategic Policy SP4 housing requirement of 8,822 homes for
the plan period (2018-2033). We consider the Plan Period should be rolled forward by a further
two years, to 2021-2036, to take into account the time lost owing to the NRW intervention and
COVID-19 pandemic, and is contrary to Tests of Soundness 2 & 3.
• Significant objections are raised in relation to Policy HOM1 which includes a number of
housing allocations located within Phosphate Sensitive Catchment Areas. The Council should
reconsider their spatial distribution of housing allocations to include additional allocations
outside of phosphate areas.
Consequently, support is provided for Land off Heol-y-Mynydd, Bryn, which is deliverable and
developer lead, it has a developer on board and ready to take the site forward. Accordingly,
Bryn/Llanelli can accommodate future growth requirements, and the land off Heol-y-Mynydd, Bryn
should be included as an allocation.
We would be grateful if we could be kept informed on the further progress of the plan and further
opportunities for engagement.
Yours sincerely,
Katherine Dowdall
Principal Planner

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.