8.20

The plans spatial option should be a combination of Option 2 and 5. Although the issue of the community being more involved/ having greater influence should be embed in to the plan it should not be the leading factor for the spatial distribution of growth in the plan.

The HBF objects to the suggested strategy as it considers it will make it much harder to deliver the appropriate/recognised level of growth. It is also less likely to deliver sustainable development and will not allow the plan to take full advantage of the areas Swansea Bay City Deal status.

No Change to Plan.

Having reviewed the 2nd Deposit Revised Carmarthenshire Local Development Plan 2018-2033
(hereinafter referred to as the LDP), via:
https://www.carmarthenshire.gov.wales/home/council-services/planning/local-development-plan2018-2033/second-deposit-revised-local-development-plan/#.Y-9SSWTP1D8
I have been instructed by my client to make general representations to a number of the LDP’s Policies
and paragraphs; and specific representations to Policy HOM1, relating to housing allocation ref.
PrC3/h4, on Land at Tirychen Farm, Dyffryn Road, Ammanford. I have therefore enclosed a
Representation Form, completed as necessary, which should be read in conjunction with this letter
setting out my client’s representations to the 2nd Deposit Revised LDP.

General Representations to Section 8, Paragraphs 8.6 to 8.8 and 8.20
Section 8 of the LDP considers a number of alternative Strategic Growth and Spatial Options to support
the delivery of housing and employment growth in the County.
Regarding Strategic Growth Options, paragraphs 8.6 to 8.8 of the LDP confirm a preferred ‘Ten Year
Trend Based Projection’, forecast to deliver 8,822 new dwellings (588 new dwellings per year) and 276
new jobs per year over the LDP period 2018-2033. Regarding Spatial Options, paragraph 8.20 of the
LDP confirms a preferred ‘Balanced Community and Sustainable Growth Strategy’, whose key
components are summarised in paragraph 9.57 of the LDP to include these targets for new dwellings
and new jobs, distributed to the County’s most sustainable locations in accordance with a Settlement
Hierarchy, whilst recognising the need to support the County’s rural areas and rural economy.
My client supports the LDP’s preferred Strategic Growth and Spatial Options – they will deliver new
housing in line with requirements and new jobs to match the same; and represent an optimistic, though
not unrealistic set of assumptions and aspirations, geared towards encouraging housing and economic
growth in the County over the LDP period.

General Representations to Section 11, Strategic Policy SP1
Strategic Policy SP1 reflects the LDP’s preferred Strategic Growth and Spatial Options, confirming inter
alia provision of 9,704 new dwellings to meet a requirement of 8,822 new dwellings over the LDP
period, distributed in a sustainable manner consistent with the LDP’s Spatial Strategy and Settlement
Hierarchy. My client supports Strategic Policy SP1 – it sets the context for delivering new housing in
line with requirements; and represents a sustainable and optimistic, though not unrealistic strategy
geared towards encouraging and delivering new housing in the County over the LDP period.

General Representations to Section 11, Strategic Policy SP3
Strategic Policy SP3 builds on Strategic Policy SP1 by confirming that the provision of growth and
development will be directed to sustainable locations in accordance with a Spatial Framework based
upon a four Tier Settlement Hierarchy, with the County divided into six Settlement Clusters. My client
supports Strategic Policy SP3, in particular the designation of Ammanford/Crosshands as a ‘Tier 1
Principal Centre’ at the top of the Settlement Hierarchy in the County’s Settlement Cluster 3. In this
respect, Ammanford/Crosshands is a highly sustainable location to which new housing and employment
development should be directed; and it is entirely appropriate for the settlement to be positioned at
the top of the County’s Settlement Hierarchy.

General Representations to Section 11, Strategic Policy SP4 and Paragraphs 11.71 to 11.74
Strategic Policy SP4 confirms that in order to meet the requirement for 8,822 dwellings over the LDP
period, 9,704 new dwellings will be provided between 2018-2033, in accordance with the LDP’s
Settlement Framework. My client supports Strategic Policy SP4 - it sets the context for delivering new
housing in line with requirements, with a reasonable and realistic ‘buffer’ to ensure those requirements
are satisfied; and therefore represents a sustainable and achievable strategy for meeting the County’s
housing needs over the LDP period.
Moreover, my client supports paragraphs 11.71 to 11.74 of the LDP, which confirm that the majority
of new residential development, including housing allocations (defined in paragraph 11.79 of the LDP
as sites capable of yielding 5 dwellings or more), will be directed to the County’s Tier 1 Principal Centres.

Specific Representations to Policy HOM1 and Housing Allocation Ref. PrC3/h4, on Land at
Tirychen Farm, Dyffryn Road, Ammanford
I made representations for my client on 13 August 2018, in response to your Authority’s ‘Call for
Candidate Sites’, requesting that land at Tirychen Farm, Dyffryn Road, Ammanford, be considered as a
‘Candidate Site’ for allocation for housing in the Revised LDP. My client is the Freehold owner of the
land, as edged in red and blue on the enclosed Location Plan ref. 09-012/01 REV B.
In response to these representations, land owned by my client at Tirychen Farm, Dyffryn Road,
Ammanford, was included within your Authority’s Candidate Sites Register of December 2018 under
refs. CA0326 and SR/004/012, as in principle suitable and appropriate for allocation for housing. The
extent of land concerned is shown shaded in red on the enclosed extract from your Authority’s
interactive Candidate Sites map, which is available via:
http://carmarthenshire.opus4.co.uk/planning/localplan/maps/candidatesites#/x:261756/y:212431/z:10/b:14/o:2305

I made further representations for my client on 14 January 2019, in response to your Authority’s
Candidate Sites Register consultation, putting forward the case for allocating Candidate Site ref. CA0326
(Site Ref. SR/004/012) in the LDP for circa 330 dwellings. Having reviewed the 2nd Deposit Revised LDP
and in particular Policy HOM1, I note that land owned by my client at Tirychen Farm, Dyffryn Road,
Ammanford, is proposed as an allocation for 150 dwellings, under ref. PrC3/h4 and as shaded in brown
on the enclosed extract from the LDP’s interactive Proposals Map, which is available via:
https://carmarthenshire.opus4.co.uk/planning/localplan/maps/2nd-deposit-revised-carmarthenshirelocal-development-plan-2018-2033-proposals-map#/center/51.7938,-
4.0059/zoom/16/baselayer/b:31/layers/o:9423,o:9424,o:9435,o:9436,o:9437,o:9446,o:9447,o:9448,
o:9449,o:9524,o:9525,o:9526,o:9527,o:9528,o:9529,o:9530,o:9531,o:9532,o:9533,o:9560,o:9561,o:
9562,o:9563,o:9564,o:9579,o:9580

Whilst the principle of housing allocation ref. PrC3/h4 is supported by my client, it is considered that
the current terms of the allocation must be improved upon. In this respect, my client’s objections to
housing allocation ref. PrC3/h4 are set out in the following paragraphs.
You will be aware that land owned by my client at Tirychen Farm, Dyffryn Road, Ammanford is currently
allocated for 250 dwellings in the Carmarthenshire Local Development Plan (LDP) 2006-2021, under
ref. GA3/h17 in Policy H1. Moreover, the site benefits from an extant outline consent ref. E/38686
granted on 8 October 2019 (as a renewal of outline consent ref. E/21663 granted on 10 October 2014)
for 289 dwellings, with access and layout granted in detail at the outline stage, as per the enclosed
copy of consented Planning Layout ref. 09-012/05 REV F.
The site’s existing allocation ref. GA3/h17 for 250 dwellings in Policy H1 of the Carmarthenshire Local
Development Plan 2006-2021; and the terms of the site’s extant outline consent ref. E/38686 for 289
dwellings clearly and unequivocally demonstrate that the site is suitable and sustainable, and available
and achievable. At the very least, therefore, allocation ref. PrC3/h4 in the 2nd Deposit Revised LDP
should be increased from 150 dwellings to 289 dwellings, to reflect the fact that the site is a consented
‘commitment’ for 289 dwellings in Ammanford - a highly sustainable Tier 1 Principal Centre at the top
of the County’s Settlement Hierarchy.
However, the site’s allocation ref. PrC3/h4 in the 2nd Deposit Revised LDP can easily be enlarged to
match the boundaries of Candidate Site ref. CA0326 (Site Ref. SR/004/012) included within your
Authority’s Candidate Sites Register of December 2018, making best use of available land that is mostly
already allocated and indeed, already consented for housing. Planning Layout ref. 09-012/05 REV E
enclosed, showing a detailed layout for a total of 336 dwellings, was first submitted with outline
application ref. E/21663 on 20 August 2009; and demonstrates that enlarging the site’s allocation ref.
PrC3/h4 to match the boundaries of Candidate Site ref. CA0326 (Site Ref. SR/004/012) could be
achieved without any harmful impacts upon the locality – the enlarged allocation would be contained
in the landscape and by retained woodland in my client’s ownership; and would be integrated with the
289 dwellings already consented under the terms of outline consent ref. E/38686. In this regard, please
refer to the enclosed Landscape Masterplan ref. SP17000 10A, which was also first submitted with
outline application ref. E/21663 on 20 August 2009.
Furthermore, enlarging allocation ref. PrC3/h4 to yield circa 80 additional dwellings over and above the
‘committed’ 289 dwellings that are already consented on the site would avoid the need to make an
equivalent housing allocation elsewhere in the County. As such, my client requests that housing
allocation ref. PrC3/h4 in Policy HOM1 of the 2nd Deposit Revised LDP is confirmed for circa 330
dwellings, using the boundaries of Candidate Site ref. CA0326 (Site Ref. SR/004/012) contained within
your Authority’s Candidate Sites Register of December 2018.

I hope you will find this letter and the enclosed helpful and that you will take account of and act upon
my client’s representations when progressing the 2nd Deposit Revised LDP. I would be grateful if you
would keep me updated with the LDP’s progress and in the meantime, please contact me if you have
any queries with this letter, or if you need to discuss any matter in more detail.
I look forward to hearing from you in due course.

Amendment to Plan

1. Introduction
1.1. Pegasus Group is instructed by the Co-operative Group (the ‘Co-op’) to submit
representations to the Carmarthenshire Second Deposit Revised LDP consultation.
1.2. The Co-op own a Site referred to as ‘Land south of Penygroes Road, Gorslas’ (the ‘Site') and
are promoting the Site for residential development. A copy of the Site Location Plan is
enclosed with a copy of these representations (Appendix 1) and the extent of the land is
shown below:
1.3. The Site comprises an area of c. 6.5ha and is considered to be capable of accommodating
approximately 120 dwellings.1
1.4. A call for sites form was submitted to the Council in August 2019 by Pegasus Group on behalf
of the Co-op. A copy of this submission is also appended to these representations
(Appendix 2).
1.5. Representations were submitted to the Deposit LDP in March 2020 and these are
resubmitted here and amended as necessary. The Site has not been included as a candidate
site in the Second Deposit Revised LDP and we consider that it should be included as a
residential allocation for the reasons given in these representations.
1 Assuming 30dph on 60% of the site.
R002 | CE | April 2023 2
Executive Summary
1.6. These representations respond directly to the following policies and paragraph references,
as set out in the Second Deposit Revised LDP:
 Preferred Spatial Option (Chapter 8);
 Paragraph 8.20;
 A New Strategy (Chapter 9);
 Policy SP1: Strategic Growth;
 Policy SP3: Sustainable Distribution – Settlement Framework;
 Policy SP4 – A sustainable Approach to Providing New Homes; and
 Policy SD1: Sustainable Distribution - Development Limits.
1.7. Our comments on the above policies would support a higher quantum of growth to the Tier
1 settlements in the interests of making the plan more effective in delivering its key aims and
more appropriate in terms of delivering sustainable development and mitigating its impact
on climate change.
1.8. This will, in turn, require the identification of additional sites for housing at these settlements
and we consider that the Site should be allocated for residential development as part of this
process, based on the updated sustainability appraisal we have undertaken using the
Integrated Sustainability Appraisal (ISA) template provided for developers. This
demonstrates that the Site is a sustainable, deliverable and logical location for housing.
R002 | CE | April 2023 3
2. Preferred Spatial Option (Chapter 8)
2.1. Paragraph 8.20 sets out the preferred Spatial Option and is unchanged from the Deposit
Draft LDP. The Option is stated as being a hybrid of a Balanced Community and Sustainable
Growth Strategy. The Spatial Option acknowledges the need to recognise and reflect
investment/economic benefits and opportunities, seeks to be community led, and will aim to
allocate development in a sustainable way.
2.2. Whilst we are broadly supportive of the preferred Spatial Option, we feel that it needs to be
more explicit in stating that the strategy needs to align with the ambitious economic
aspirations of the plan.
2.3. At present, we do not feel that this is reflected in the proposed Spatial Option and, therefore,
it has not been fully justified in the context of the Council's economic growth ambitions.
2.4. We would stress that this does not require wholesale changes to the proposed Spatial Option
as this could still be community led and the delivery of sustainable development should be
at the heart of all Plan strategies. However, we would wish to see it reflect the Council's
ambitious economic growth aspirations and acknowledge that this will influence the spatial
distribution of development.
R002 | CE | April 2023 4
3. A New Strategy (Chapter 9)
3.1. We are broadly supportive of the Plan's ambitions to deliver economic growth and an uplifted
housing requirement to support this. However, the perceived reduced importance of
delivering the Council's ambitious economic growth targets within the Preferred Spatial
Option has manifested in what we consider to be an ineffective Plan Strategy.
3.2. This is because the Second Deposit Revised LDP seeks to take a balanced approach to the
distribution of housing supply (paragraph 9.4), despite the fact that it will be reliant on only
a few key centres to deliver the vast majority of the economic growth it aspires to (namely,
Llanelli, Ammanford/Cross Hands and Carmarthen).
3.3. We accept that growth will need to come forward at all levels of the settlement hierarchy
(including rural areas) to support the vitality and viability of the diverse communities across
the county. However, the Plan's focus on delivering economic growth and a balanced
approach to the distribution of development are unlikely to be an effective combination in
meeting the plan's aspirations.
3.4. The plan acknowledges that the Tier 1 settlements are the strongest economic drivers from
a market demand and delivery perspective and states that they will receive an "appropriate
proportion" of the anticipated growth. However, this should be quantified within the plan
(which it is not at present) alongside the level of housing and other types of development
needed to be delivered in conjunction with it.
3.5. The Plan Strategy needs to be more realistic in acknowledging that it cannot rely on lower
order settlements and rural areas to deliver the economic growth it aspires to and that the
Tier 1 settlements will likely need to play a greater role than is currently identified.
3.6. It also needs to acknowledge that employment sites will only come forward where they have
access to good services, facilities and infrastructure. Furthermore, they will also need to be
accessible for the local/regional labour market.
3.7. It is, therefore, essential that the Plan identifies the supporting development and
infrastructure that needs to be delivered alongside employment sites in order to stimulate
investment and economic growth. The plan currently fails to do this, and this has resulted in
deficient policies which are discussed further below.
R002 | CE | April 2023 5
4. Policy SP1: Strategic Growth and Policy SP4: A
Sustainable Approach to Providing New Homes
4.1. As stated above, we support the Council's decision to deliver a higher quantum of dwellings
over the plan period to align with the Council's economic growth ambitions. We support the
proposed 10% flexibility applied to the housing requirement as this will provide a reasonable
(albeit not optimal) level of flexibility to improve the prospects of meeting the minimum
housing requirement.
4.2. However, we question why this has been reduced from the 15% flexibility applied in the First
Deposit Revised LDP. This is particularly important in the context where one of the reserve
sites under Policy SG2 has been removed.
4.3. In addition, we are not convinced the distribution of housing has been properly justified in
the context of the ambition to deliver higher levels of economic growth. Our principal concern
is that the ambitions to deliver economic growth will be jeopardised by the balanced
approach to distributing growth across the county.
4.4. This has, in turn, resulted in a distribution pattern that does not appear to appreciate the
importance of the spatial relationship between employment growth and housing delivery as
they support the delivery of one another.
4.5. In simple terms, the distribution strategy does not take a realistic view of the capacity of
lower order settlements to deliver economic growth, relative to the Tier 1 settlements and
has, accordingly, failed to allocate a sufficient level of housing in close proximity to key
employment areas.
4.6. It is important for housing to be delivered in close proximity to key employment areas for a
number of reasons. Two particularly pertinent reasons are as follows:
1. It encourages commuting via alternative modes of transport to the private motor
vehicle in the interests of sustainability and mitigating impacts on climate change;
2. Housing delivery creates a critical mass and local workforce which stimulates
investment and job creation.
4.7. Policies SP1 and SP4 (including their supporting text) need to clearly justify the overall
quantum of development to be delivered at each settlement tier and then explain how it will
be distributed to support the economic aspirations of the plan, alongside its sustainability
and community aspirations. Its failure to do so at present is a significant deficiency with the
plan that needs to be addressed.
R002 | CE | April 2023 6
5. Strategic Policy SP3: Sustainable Distribution –
Settlement Framework
5.1. Policy SP3 sets out the settlement hierarchy and settlement clusters. We largely agree with
the structure and support the Ammanford/Cross Hands area being included within the first
tier – Principal Settlements.
5.2. We also agree with the assertion that growth and development will be directed to sustainable
locations in accordance with the spatial framework; however, as mentioned above, we have
some reservations with how this has been implemented.
5.3. Whilst we note that the highest proportion of development is due to be delivered at the Tier
1 settlements (a principle we support), we consider that too great a proportion of growth has
been allocated to lower order settlements. As stated above, the Plan is unrealistic in the way
it proposes to distribute growth to deliver its economic aspirations and the allocation of
housing sites to support this is also unsuitable as a result.
5.4. If the Plan is serious about delivering economic growth, sustainable development and
mitigating its impacts on the environment to combat climate change, then it needs to rethink
its distribution framework and allocate higher levels of development to the Tier 1
settlements.
R002 | CE | April 2023 7
6. Policy SD1: Development Limits
6.1. This policy states that development within the identified development of Tier 1-3 settlements
will be acceptable, provided that they accord with other relevant policies of the LDP.
6.2. Whilst there are exceptions to this rule (for example, Policy HOM6), the policy does not set
out a scenario whereby development for traditional housing can come forward beyond the
development limits. This will be problematic in circumstances where the Council's housing
delivery fails to keep pace with their proposed annual requirement.
6.3. Whilst we support the principle of identifying specific sites to meet the development needs
of the district within the LDP to guard against excessive unplanned development, Local Plans
still need to be sufficiently flexible to ensure that housing and other types of development
can come forward to meet the needs of the population. This is especially important in
situations when delivery does not match up with the plan's target levels of growth. This could
be due to any number of reasons, from deficiencies with the plan, unforeseen technical issues
affecting the delivery of certain sites or broader macro-economic factors.
6.4. We note the identification of Reserve Sites (Policy SG2) and acknowledge that this will go
some way to securing supply in the event allocated sites cannot come forward albeit one of
the reserve sites has been removed from the Second Deposit Revised LDP over the Revised
Deposit version. However, we would question whether this is a sufficiently flexible approach
that will help to guarantee the delivery of the plan's housing requirement. We note that the
delivery of a reserve site will need to be subject to a masterplanning exercise. This
requirement is something that would potentially delay its delivery and prevent it from
addressing a specific need (e.g. housing shortfall) in a timely manner.
6.5. As such, we consider that this policy should incorporate wording to allow for development in
sustainable locations that would otherwise comply with the relevant policies of the LDP in
the event that the supply and delivery of housing failed to keep pace with the Local Plan
Housing Requirement (i.e. the absence of a five-year supply of housing land).
6.6. We would suggest additional wording to the policy to make it clear to prospective applicants
when it would be acceptable to propose development on unallocated sites. This would
provide certainty and allow for windfall sites to come forward in accordance with the LDP to
meet shortfalls when they arise.
6.7. We acknowledge that the plan has attempted to plan positively for housing growth in
particular and sought to incorporate measures to secure this (10% buffer to the housing
requirement (albeit reduced from 15%) and the identification of reserve sites) over the plan
period. However, we consider that policy SD1 should incorporate additional flexibility to allow
development to come forward under certain circumstances (as specified above) in order the
ensure the plan can remain as effective as possible for its duration.
R002 | CE | April 2023 8
7. Land to the south of Penygroes Road, Gorslas,
Llanelli
7.1. As stated in the Introduction, the Co-op controls an area of land to the south of Penygroes
Road, Gorslas comprising a number of fields which cover an area of around 6.5ha and would
be capable of delivering c. 120 dwellings.
7.2. Vehicular access could be taken from the B4556 to the east with an emergency/pedestrian
access being taken from the north via an existing driveway/access.
7.3. The Site is well related to development around the 6-way junction along the A476 which is
home to a number of services and facilities that would meet the day to day needs of future
residents.
7.4. The Site is also well related to existing and future large-scale employment and commercial
development areas at Cross Hands.
7.5. The Site's proximity to these services, facilities and employment opportunities would reduce
the reliance on the private motor vehicle to meet the day to day needs of future residents
and would encourage the use of active modes of travel such as walking and cycling.
7.6. The Site is free from any land use allocation or other designations that would otherwise
constrain development; it could be made available for development in the short-term and
be built out comfortably within a five-year time frame once detailed planning permission is
granted.
R002 | CE | April 2023 9
8. Integrated Sustainability Appraisal
8.1. Our representations to the Deposit LDP in March 2020 included an assessment of the
sustainability of the Site with regard to the guidance available at that time. Since then, the
Council has published an Integrated Sustainability Appraisal (ISA) document for consultation
alongside the Second Deposit LDP.
8.2. Paragraph 1.7 of the ISA states that:
“The Council strongly advises that in responding to the Deposit rLDP, any relevant new,
site(s) proposed should be accompanied by an integrated Sustainability Appraisal
(incorporating Strategic Environmental Assessment). A site not subject to ISA is unlikely
to be considered suitable for allocation in the plan.”
8.3. As a result, we have provided an assessment of the sustainability of the Site against this
updated criteria in the below table.
8.4. As shown by our responses, the Site performs extremely well against the various elements of
the SA with only the fact that the Site is a greenfield site and may contain high carbon soils
being the only constraints affecting the Site's development.
9. Summary Representations
9.1. These representations have been submitted on behalf of the Co-op in respect of its land to
the south of Penygroes Road, Gorslas. The Co-op is promoting the Site for residential
development and consider it to be a sustainably located, deliverable and logical site for the
proposed use. The Co-op has a good track record of promoting sites for development and
working with developers and house builders to ensure that sites are sold on and deliverable.
It does not sit on sites or ‘land bank.’
9.2. Whilst we are broadly supportive of the economic aspirations of the LDP and agree with the
uplift to the housing requirement accordingly, we have reservations with the proposed
strategy to deliver this ambitions targets.
9.3. This is namely down to the following reasons:
 The Preferred Spatial Option and Plan Strategy appear to have diminished the
importance of delivering these said economic aspirations;
 They are unrealistic in their view that lower order settlements will be able to deliver the
currently proposed economic growth and role Tier 1 settlements will need to play has
been underestimated;
 There is a disconnect with the spatial distribution of employment development and
residential development and it is not clear how they will support the delivery of one
another; and
 The proposed flexibility measures notwithstanding, we consider that the plan should
include a policy to facilitate development beyond the defined settlement limits in the
case of severe plan failure.
9.4. We suspect that when the plan is reviewed in light of these issues, a higher proportion of
growth will be identified at the Tier 1 settlements and this will require additional housing
allocations to be included.
9.5. Our client's Site is available, deliverable and sustainably located. We have assessed it against
the Council's ISA template and it has performed very well with few minor issues. We would,
therefore, support a new policy allocating the Site for residential development in the final
version of the LDP.