PrC1/MU2

Remove allocation PrC1/MU2 from the Plan.

We are instructed by Mr J.T.J. & Mrs C.W. Davies to a make a formal representation to the
“soundness” of the Deposit Draft of the Carmarthenshire Local Development Plan.
Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/058/003, seeking inclusion of their land for future residential development within the
defined settlement limits of Ferryside within the Replacement Local Development Plan.
The Candidate Site comprises a rectangular-shaped former grazing field set to the
immediate rear of the Parc-y-Ffynnon residential estate, which was completed in 2019.
Provision for future access into the rear field has been left over in two points.
We have noted that approximately half of the Candidate Site is included within the Second
draft settlement limits as Residential Allocation Sec2/h2 capable of accommodating 12
residential units according to the housing schedule listed under Policy HOM1 of the Plan.
However, the eastern half of the field has not been included.
This formal Representation relates solely to the unsuccessful part of the Candidate
Site.

The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our clients’ submission, reasons why all the site was not selected for inclusion within the
Second draft settlement limits of Ferryside, as contained within the Second Deposit Draft.

We note that the submission successfully passed through all three Assessment Stages,
being Stage 1 (site compatible against the location of future growth presented in the
Preferred Strategy), Stage 2A (Initial Detailed Site Assessment), Stage 2b (Further Detailed Site Assessment) and Stage 3 (Sustainability Appraisal and Habitat Regulation Assessment) of the Council’s site assessment. It therefore crucially was adjudged acceptable in all technical aspects of formal assessment but was only partially rejected at the final selection stage, with reasons for non-inclusion reported as follows: “Part of the site is to be allocated with reference SeC2/h2.”

Our clients consider the LDP is “unsound” and should be changed, as it fails to meet the tests for “soundness,” in that the Plan “is not appropriate,” and “will not deliver,” as defined by the Planning Inspectorate’s LDP Examinations Procedural Guidance.
Specifically, our clients consider that the Second Deposit draft settlement limits for Ferryside, as defined under Policy SD1 “Settlement Limits”, should be amended to include the land as edged in red upon the extract of the Proposals Map for Ferryside, as reproduced below in Figure 1. The land should be appropriately allocated for housing under Policy HOM1 “Housing Allocations.”

Figure 1 – Extract from Second Draft Proposals Map with site edged in red

This formal representation letter supplements the following documents which comprise a complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits

1.0 Allocation of only Half of Candidate Site
1.1 The Council have not provided any reasoning whatsoever for the draft allocation of only half the Candidate Site. The new settlement limit, as shown by Google Earth in Figure 2 below, does not follow any defensible boundary, such as a hedgerow, treeline or even dividing fence across the enclosure. Its positioning is therefore physically illogical in the context of adding new housing to this part of Ferryside.

Figure 2 – Google Earth (April 2021) – illustrating the cultivated form of the Candidate Site

1.2 We therefore consider that the Council has adopted this rather inconsistent approach on the basis that it only considers that Ferryside should grow by very minor proportions over the Plan Period to 2033.
However, the village is significant in scale, containing several hundred dwellinghouses, primary school, convenience shops, public houses, education centre and railway station. It also possesses good public bus service connections to Carmarthen and Llanelli, with the X11 service calling en-route to Swansea City Centre. In other words, it is highly sustainable as a place to live, work and also continue to accommodate holidaymakers. The village contains several guest houses, caravan and chalet parks serving the tourist sector.
Candidate Site
Draft Housing Allocation Sec2/h2
1.3 The Representation Site indicative site layout plan is reproduced below as Figure 3.
It illustrates for cul-de-sac form of development with a total of 23 detached and semi-detached dwellinghouses set fronting an internal estate road, which can access the site via two independent access points from the Parc-y-Ffynnon estate. Thus the proposed form of layout and development is complementary in form to adjacent established form of residential layout at Parc-y-Ffynnon, with frontage parking, and traditional rear garden space.
1.4 The draft Allocation for only 12 units indicates that one access would be used, being the western access, and thus it would require amendments to the site layout to ensure all vehicles access and egress through that single access.
1.5 We submit that the Candidate Site encompasses the entire rear, south-eastern boundary of Parc-y-Ffynnon properties and thus complemented that entire development in width and form. The proposed draft allocation in only proposing half that area fails to respect that character, and in commiting to allocate land beyond the previous LDP settlement limits, our clients cannot understand the physical logic in not extending the draft allocation over the entire field. The Candidate Site field exhibits a consistent gradient and form across its entire length, and therefore the excluded eastern half bears no difference in profile and physical form to the western draft allocated half.
1.6 Google Earth provides such graphic evidence that the allocation of the whole field will not pose any detriment to the visual amenities of the locality. The eastern perimeter stands as a tall and proud hedgerow, with mature, tall trees to the rear extent. Coupled with the lower ground being dominated by adjoining modern houses, any viewer from public viewpoints on ground east, west and north of Parc-y-Ffynnon will have no ready appreciation that the Candidate Site is wholly developed as opposed to only half developed as suggested by the Council. There is no public access to land to the south given it is significantly higher in contour level, steep and impassable with dense woodland vegetation. It nevertheless presents a “green blanklet” or backdrop to the modest expansion southwards of Parc-y-Ffynnon.

Figure 3 – Indicative site layout plan of proposed Representation Site

2.0 Overall Housing Supply at Ferryside & Carmarthen Cluster
2.1 The proposals under this Representation merely seek the addition of a further 11
residential units to the overall housing supply of Ferryside, to add to the 12 units
already allocated within the draft Plan. Ferryside is defined as a Tier 2 Service
Centre, and lends to the principal service centre centring upon the Carmarthen
Cluster as defined within the draft LDP.
The Carmarthen Cluster aims to provide an additional 1646 residential units over the
Plan period to 2033, and thus the addition of a larger allocated site at Ferryside of 23,
rather than the current draft of 12 units will not lead to an over-supply of
dwellinghouses within the Cluster. The LDP village classification as a Tier 2 Service
Centre implies that it possesses far more community facilities and public
transport links than a typical Carmarthenshire village. Accordingly, it should be
afforded a reasonable level of future housing growth for the next 10 years.
2.2 Ferryside is quite unique in terms of its positioning and setting being part of the
Carmarthen Cluster. It is placed at the south-eastern extremity of the defined area,
bordering the Llanelli Cluster, and its extremity settlements such as Kidwelly.
Ferryside serves a rural hinderland and is the principal settlement off the eastern
banks of the Towy Estuary, and consequently, there are few other defined settlements in this part of the County which contain specific residential allocations.
2.3 Policy HOM1 provides details of the two allocations in Ferryside as shown below.

Figure 4 – Policy HOM1 Residential Allocations at Ferryside

Only one other site is allocated in Ferryside that relates to 12 residential units at “Caradog Court”. It benefits from an extant planning permission dating from 2011, and has been mostly completed, albeit a range of modest, two-bedroomed linked units form the bulk of the remaining allocation of 12 units as defined in the draft Allocation. That site is “carried over” in allocation from the previous 2008-21 LDP.
2.4 We have therefore examined and researched sites which have been brought forward as Residential Allocations with the Second Deposit Draft in the Carmarthen Cluster. The Cluster extends in geographic area to Bronwydd, Cynwyl Elfed, Peniel, Rhydargaeau, Alltwalis and Llanpumsaint to the north of the town. It stretches south-west to Llansteffan and Llangain, and east along the River Towy to include Nantgaredig, Pontargothi, Llanarthney and Capel Dewi. It extends along the A48 road as far as Llanddarog and Porthyrhyd. Finally, it stretches south-east along the Towy Estuary to include Cwmffrwd and Ferryside and partly along the Gwendraeth Valley to Pontyates. The following allocations are noted for their inactivity and undeliverability over the last 8-9 years.
2.5 West Carmarthen (PrC1/MU1) – 700 UNITS
In Carmarthen, great emphasis within the Draft Plan has been placed upon the continued allocation of a large, proposed housing site at West Carmarthen. The site is allocated for 700 residential units as Site PrC1/MU1.
This allocation forms the bulk of a Residential Allocation carried over from the current LDP (2014-21) where the allocation was for 1100 units.
We have calculated that of that 1100 units only a total of 141 were constructed between the Plan Adoption date of December 2014 and start of this Replacement LDP Plan Period of 2018. Since 2018, a further 90 units have been constructed, and we note from Land Registry records that the last completed unit was sold at Maes Macsen in September 2021 (18 months ago).
Therefore, since adoption of the 2014 LDP, only a total of 231 units have been completed, equating to a build rate over that 7-year period of only 33 units per annum. This build rate is considerably lower than the anticipated and much promised
delivery of 1100 units in the Plan Period of 2014 to 2021, which would have expected an annual build rate of 157 units. An actual return of 33 units per annum equates to only a 21% build rate return on that anticipated for delivery in the 2014-21 Plan.
Only 39 of those units were built in 2017-18 accordingly to the Joint Housing Land Availability Study 2018. The 2019 Study reveals that only a further 5 units were constructed in 2018-19. The August 2019 Study reports that none were under-construction at that time. During 2020 and 2021 when Covid-19 restrictions were at their peak, more units were constructed than at any other time in that LDP plan period, and therefore we would submit at this point in our formal objection that low build rates cannot be held to be reduced as a consequence of Covid-19 restrictions.
It is equally noteworthy that at a time when the housing market was at its most buoyant in 2022, that the only housebuilder with a track record on the site had ceased construction and sold their last completion (September 2021). We submit that this is testament to the weak marketability of the West Carmarthen Site.
Only 231 units out of 1100 units of the Strategic Site have therefore been completed in the 2014-21 LDP period, which equates to only 21% of that allocated total.
The Replacement LDP seeks to delivery 700 units over a Plan Period from 2018 to 2033. The extract from the Proposals Map for Carmarthen reveals that the figure includes for 90 units constructed between 2018 and 2021, leaving a balance of 610 units envisaged in the remainder of the Plan Period to 2033. That would equate to a build rate of 61 units per annum over a 10-year period. Based upon previous build rates at this site, such a predicted build rate can be described as overly optimistic, being nearly double that actually achieved on the site to date.
The West Carmarthen draft allocation includes parcels of residential allocations off the flanks of the A40 that were previously allocated within the Carmarthen District Local Plan (1997), and subsequent Carmarthenshire Unitary Development Plan (2003). No progress was made in bringing the sites at Llysonnen Road and Old St. Clears Road forward, and yet it was allocated within the Local Development Plan in 2014. Consequently, twenty-seven years of Development Plan allocations have elapsed without any signs of delivery of the majority of this site.
Clearly, there is no historic demand for a site of this scale in this part of Carmarthen. More physically challenging sites, such as the Roman Park site in Llangunnor by Redrow Homes, and the Mount Pleasant site, also in Llangunnor, by Lovell Homes have come forward, and been fully completed, long before West Carmarthen. Yet still the Council is prepared to allocate the site once again for hundreds of residential units in a new Development Plan.
2.6 Pibwrlwyd (Site PrC1/MU2) – ALLOCATION OF 247 UNITS
We would also question the allocation of land at Pibwrlwyd in Carmarthen, being partly for a residential development of 247 units on the Parc Pibwrlwyd development. The Council published and subsequently adopted Supplementary Planning Guidance on “Pibwrlwyd” in 2014.
Paragraph 3.2 was quite specific in that “The LDP describes the acceptable uses on the site as follows: “The proposed use for the site is for a business park centred around employment uses (Use Classes B1, B2 and B8), with uses associated with, and ancillary to the existing Coleg Sir Gâr.”
A development brief in the form of SPG has been prepared and adopted. This in setting out appropriate uses under Use Classes B1, B2 and B8 for the employment element of the site also explores other compatible uses. Residential use on this site is not considered appropriate.” (self-emphasis)
The Council has seen fit to re-examine the Development Plan status of this Mixed-Use Site and concluded that residential uses should now be brought forward, with a residential capacity of 247 units. No explanation has been provided within the supporting text to LDP policies to warrant a dramatic departure from the adopted SPG.
The site is completely and physically divorced from established housing at Pensarn and Llangunnor. It is physically separated by foot from local schools, community facilities and play facilities by the A40 / A48 trunk road network, with only a dark and insecure pedestrian underpass linking it to the Pensarn Commercial Area.
New housing at this location would accordingly be quite alien in form to the long-established business and education uses at Pibwrlwyd.
2.7 Land off Parc-y-Delyn (PrC1/h4) – ALLOCATED FOR 17 UNITS
This new allocation suffers from including Tree Preservation Orders imposed upon specimens at the proposed vehicle access onto Parc-y-Delyn. The site also appears covered in rich flora and fauna and could harbour biodiversity interests.
2.8 As referenced at the outset of this Section, there are several satellite settlements about Carmarthen contributing housing allocations to the Cluster Total of 1690 dwellings. However, we have discovered that many allocations have simply and conveniently been “rolled over” from the 2014 adopted LDP, or in some cases even earlier from the 2008 Unitary Development Plan. No explanation, evidence or demonstration of viability or deliverability has been provided within the Site Assessment Table (January 2023) to demonstrate such a widespread practice.
The following sites are examples of such dormant sites:
Cae Camfas, Heol Llanelli, Pontyates (SeC1/h4) – ALLOCATED FOR 8 UNITS
This site in Pontyates was allocated in 2014 in the Local Development Plan, and yet no applications for planning permission have been submitted in the entire 8 years of the Plan Period.
2.9 Gwyn Villa, Llanpumsaint (SuV12/h1) – ALLOCATED FOR 20 UNITS
This site in Llanpumsaint was allocated in 2014 in the Local Development Plan, and yet no applications for planning permission have been submitted in the entire 8 years of the Plan Period.
2.10 Fronheulog, Cynwyl Elfed (SuV1/h1) – ALLOCATED FOR 8 UNITS
This site in Cynwyl Elfed was allocated in 2014 in the Local Development Plan, and also the 2008 UDP, and applications for planning permission have been submitted for only two individual houses in the entire 15 years of the above combined Plan Periods have been commenced.
2.11 We submit that the above draft allocations at West Carmarthen be significantly reduced in scale, and in the case of Pibwrlwyd and above-named satellite allocations be omitted from the Plan and that housing allocation be redistributed to modest Candidate Sites, of up to 20-30 units such as that proposed at Parc-y-Ffynnon. There is clear evidence in the rapid completion of the adjoining Parc-y-Ffynnon development that such modest sites are far more likely to be brought forward and developed in full by regional and small housebuilders given that construction and development costs are more likely to be viable in relation to house sales and the general housing market in this part of Carmarthenshire.
2.13 In the case of Parc-y-Ffynnon, there are little signs within the immediate locality of properties for second sale, and no evidence of undeveloped land available within this part of the settlement limits, which is a strong indicator of a healthy property market at Ferryside. Consequently, it is a location where housing proposals are deliverable, assisting to meet housing needs in this part of the Carmarthen Cluster.

CONCLUSION
In conclusion, this Representation to the Second Deposit Draft of the Revised LDP has sought to examine the Council’s reasons for non-inclusion of all the Candidate Site.
Our clients have illustrated that their indicative proposals to construct a total of 23 dwellinghouses will not appear at odds to the prevailing spatial pattern of development in Ferryside. The locality has numerous examples of modern cul-de-sac development being completed at backland / edge of settlement locations, which in turn, advocates that the form of development proposed at Parc-y-Ffynnon is no different, resulting in it being respectful to the character and setting of the locality. The Council have already acknowledged that a backland site is suitable at this location in Ferryside, our clients merely suggest that it be enlarged to encompass all the level field to a parallel position with the constructed Parc-y-Ffynnon development.

We respectfully request that this Representation be given careful examination, and consequently the defined settlement limits of this part of Ferryside realigned to include the whole Representation Site, as a Residential Allocation in the Proposals Map of the adopted Local Development Plan.

Reduce and remove the housing element of the allocation.

1.0 I NTROD UCTION
1.1 Evans Banks Planning Limited act for a number of landowners and have made formal representations in respect of those clients’ land interests in relation to the Carmarthenshire Replacement Local Development Plan (2018-21): Second Deposit Draft. Within those Representations, we have referred to previous Candidate Site submissions made in August 2018. The Council in response to those Candidate Site submissions have published a Site Assessment Table (January 2023). We have noted in rejecting Candidate Sites, the Council has on multiple occasions concluded that a Candidate Site should not progress and be allocated as “there is sufficient land allocated for housing growth elsewhere in the Plan.”
1.2 Policy HOM1 “Residential Allocations” refers to the schedule of sites put forward as draft residential allocations to meet housing growth over the Plan Period.
1.3 This Statement will focus upon a significant allocated site with the Carmarthen Cluster (Cluster 1) that being Site PrC1/MU2 at Pibwrlwyd. The Schedule of Residential Allocations at Policy HOM1 indicates that 247 residential units are proposed and anticipated to be brought forward over only one “Delivery Timescales”, namely over Years 11-15 (2029-33), therefore being very late in the Plan Period.
1.4 On behalf of our clients, we herewith lodge a formal representation in objection of the Mixed-Use Allocation. We submit that the Council’s expectations for the delivery of this site are unachievable based upon its lack of progress since allocation within the adopted Carmarthenshire Unitary Development Plan 2001-16, and Carmarthenshire Local Development Plan 2008-21. This Statement will focus upon the slow progress of the site evidenced by not only lack of applications for full planning permission, but also the “sea-change” in local planning policy from adopted Supplementary Planning Guidance dated 2014. In that SPG, the Council expressly stated that any form of residential development upon the site would be resisted.
A noticeable lack of active site marketing further compounds the argument that the level of mixed-use allocation is unrealistic.

2.0 SITE CONTEXT IN SECOND DEPOSIT DRAFT
2.1 The Pibwrlwyd Strategic Residential Site (PrC1/MU2) is part of a Mixed-Use Allocation, made under the provisions of Policy SG1 “Regeneration and Mixed-Use Sites” which in the case of Pibwrlwyd states that the site is provided for “Includes a mix of uses reflecting its strategic location and contribution to Carmarthen. Uses include employment, commercial leisure, education associated with Coleg Sir Gâr and residential (an allowance is made for 247 new homes)”.
2.2 The site extends over several hectares of open, undulated, former pasture, set off the eastern flank of the A484 Carmarthen to Kidwelly Road, extending east by several hundred metres to the eastern boundary with the A48 trunk road. Coleg Sir Gar is to be found in the southern extremity of the allocation, and Parc Pensarn Retail and Employment Park in the northern portion.
Figure 1 – Extract from Proposals Map showing extent of Site PrC1/MU2
2.3 The southern extent of the allocation shows it also includes educational uses off the southern flank of Pibwrlwyd Lane, which lies off the roundabout interchange with the
A484, and where a handful of established houses are to be found extending eastwards to where that minor road terminates near the A48 embankment.
2.4 Figure 2 below provides a Google Earth image of the retail, employment and educational uses as of April 2021, whilst Figure 3 shows the state of development progress back in June 2018, which coincides with the start of the Replacement LDP Plan Period.
Figure 2 – Google Earth – April 2021 – illustrating extent of development about Pibwrlwyd at that time
Figure 3 – Google Earth – June 2018 – illustrating extent development about the start of Replacement LDP Period
2.4 The above Google Earth images reveal that extent of new commercial office units constructed at Cabna Court off Heol Glyndwr that has taken place since June 2018. It is notable that the wide, open expanses of undulating fields stretching south for a distance of some 360 metres have remained in their agricultural state for generations, with no signs of any form of built development. It is also notable in that time, that the extent of educational buildings at the Pibwrlwyd Campus have remained unchanged, with little progress in terms of expansion and / or redevelopment. In other words, the majority of the Strategic Site has lain dormant for many years.

3.0 Progress since Adoption of Local Development Plan in 2014
3.1 The Carmarthenshire Local Development Plan was adopted in December 2014. The Plan is scheduled to run over a Plan Period from 2008 to end of 2021. The Site at Pibwrlwyd was allocated for Mixed Use in that Plan and referenced GA1/MU2. Figure 4 below illustrates the extent of the allocation for the current adopted Plan.
Figure 4 – 2014-adopted Local Development Plan for Allocation GA1/MU2
3.3 Since adoption of the 2014 LDP, applications for full planning permission have been granted for a “swim centre”, dental surgery and two office suite units in the northern part of the allocation at Cabna Court. Whilst off the Pibwrlwyd Lane part, a single-storey animals testing unit has been formed. All those developments have been completed and implemented. A planning application for a manufacturing unit with warehouse was granted off Heol Glasdwr, adjoining Cabna Court in September 2021, but has yet to commence any on-site works.
3.4 PIBWRLWYD SUPPLEMENTARY PLANNING GUIDANCE
3.4.1 The Pibwrlwyd Supplementary Planning Guidance was adopted alongside the LDP in December 2014. It describes the vision and policy provision for Pibwrlwyd to include for “The proposed use for the site is for a business park centred around employment uses (Use Classes B1, B2 and B8), with uses associated with, and ancillary to the existing Coleg Sir Gâr. A development brief in the form of SPG has been prepared and adopted. This in setting out appropriate uses under Use Classes B1, B2 and B8 for the employment element of the site also explores other compatible uses. Residential use on this site is not considered appropriate”.
3.4.2 The SPG outlines proposed uses for the site, as follows:
“Due to the strategic location and the prominence of the site, any development on the site must be of high quality. Acceptable uses on the site include:
B1 Business: Offices not within A2.
Research and Development, studios, laboratories, high tech, light industry.
B2 General Industrial: Appropriate uses that don’t have an adverse impact on neighbouring uses.
B8 Storage or Distribution: Wholesale warehouse, distribution centres, repositories. D1 Non-residential Institutions: non-residential education and training centres – relating to the extension of the Coleg Sir Gâr campus.
Other suitable uses may include, subject to amenity considerations:
• Car showrooms and sales (sui generis);
• Hotel (C1);
Use Classes B1, B2 and B8 will be restricted to 15.5ha of the overall site.”
3.4.3 It is therefore abundantly clear that the focus throughout the entire SPG is to encourage B1, B2 & B8 uses from Parc Pensarn to the north, and Educational uses from the Coleg Sir Campus from the south. Due to the obvious potential for environmental conflicts with those industrial and commercial uses, any form of residential development was strongly resisted.

4.0 CARMARTHENSHIRE UNITARY DEVELOPMENT PLAN 2001-16
4.1 The Carmarthenshire Unitary Development Plan was adopted in June 2006. The land at Pibwrlwyd was allocated as a Strategic Site under Policy E15, referenced as Site PDB19. Figure 5 below provides an illustration of the Proposals Map from the UDP.
Figure 5 – Unitary Development Plan Extract of Pibwrlwyd
4.2 The site was also allocated in the Carmarthenshire Unitary Development Plan as a Planning and Development Brief Site, which sets out the vision of the site “as a Business Park centred on B1, B2 and B8 uses and will allow for the consolidation and redevelopment of the existing Carmarthen elements of Coleg Sir Gâr within the site. The Brief will evaluate the feasibility of other compatible uses, including car showrooms and some limited retail use...Residential uses are not considered appropriate for this site”.

5.0 OBJECTION TO RESIDENTIAL ALLOCATION IN SECOND DEPOSIT DRAFT LOCAL DEVELOPMENT PLAN
5.1 The Replacement LDP seeks to delivery “an allowance of 247 units” over a Plan Period from 2018 to 2033 at Pibwrlwyd, in complete disregard for the 2014 Supplementary Planning Guidance.
5.2 The bulk of the land at Pibwrlwyd lies under the freehold ownership of Coleg Sir Gar. The College have owned the site throughout the above UDP and LDP Plan Periods. During that Period, they not undertaken any marketing of the site to seek out commercial, leisure or industrial uses in line with the Local Planning Policy framework, particularly the Supplementary Planning Guidance. In contrast, the owners of Cabna Court to the north, namely Welsh Government, have embarked upon a marketing campaign (principally through appointed Land Agents Cushman & Wakefield) and successfully attracted several office and commercial interests to the commercial estate off Heol Glasdwr.
5.3 The Council have indicated that they expect the delivery of the Pibwrlwyd site to taken place in LDP Years 11-15, that being 2029-2033, and thus remains a further 5-10 years before the development potential is realised. That timescale equates to a period of over 25 years of allocations in the UDP and two LDPs without any prospect of even part of the allocation being fulfilled, and not even the subject of a planning application.
5.4 National Planning Policy in terms of the allocation of residential land in Local Development Plans is to be found in Planning Policy Wales (Edition 11) (February 2022). PPW has a long-standing policy provision that industrial and residential development should be segregated in order to avoid any potential for future conflicts between the ability of those existing businesses to properly function and trade, versus the rights and needs of occupiers of residential properties to be afforded a reasonable level of amenity. By siting new residential development near to commercial development, difficulties can arise in terms of complaints of excessive, vibration, dust and disturbance from the use of loud and heavy machinery and the movement of
heavy goods vehicles. Hours of operation of those commercial operations can be questioned, particularly of between the hours of 19:00 to 07:00 hours on week nights and at weekends when adjoining occupiers of residential properties tend to be more home based. Many modern businesses now require operating over longer shift patterns and accordingly the traditional hours of working strictly during the weekday have long been cast aside. HGV deliveries, for example, may be necessary during early morning and / or evening hours. Siting new residential development in close proximity to existing and proposed industrial development will undoubtedly create potential for conflict and disturbance to those new Pibwrlwyd residents upon the Pibwrlwyd Strategic Site.
5.5 We have noted at Pibwrlwyd that Heol Glasdwr has two access spurs leading off its west-east axis. The eastern-most access leads onto Cabna Court as shown at Photo 1 below, taken in March 2023. The extent of new build offices at Cabna Court is shown off both flanks of the estate road which terminates at the Coleg Sir Gar land.
Photo 1 – Cabna Court north of Pibwrlwyd
5.6 Photo 2 illustrates the other access spur off the western side of Heol Glasdwr, where industrial units are positioned off that carriageway. It graphically illustrates how new residents would have to negotiate past commercial vehicles to access their new homes and give rise to potential conflicts.
Photo 2 – access off Heol Glasdwr amongst commercial units
5.7 We note that the open fields at Pibwrlwyd comprise some 22 hectares below / south of the Cabna Court and Heol Glasdwr commercial uses. Assuming the LDP capacity expectation of 35 units per hectare is achievable, a total “allowance of 247 units” would require 7 hectares of land take, and thus equating to one-third of the site.
5.8 Given that no firm proposals have yet to materialise on this majority part of the Strategic Site, and also over the last 20 years, and yet it remains allocated in the Second Draft. It is likely that any residential development would appear “stand-alone” and remote from any integrated mixed-use development at Pibwrlwyd. The obvious and longstanding uncertainty and lack of progress in bringing this part of the allocated site to fruition will undoubtedly also reflect upon a residential element within that scheme. By the Council’s own admission, it only likely to come forward in the latter years of the new LDP, and thus such a prediction is hardly an endorsement of its potential creditability and deliverability.
5.9 Locational Remoteness
5.9.1 The site is completely and physically divorced from established housing at Pensarn and Llangunnor. It is physically separated by foot from local schools, community facilities and play facilities by the A40 / A48 trunk road network, with only a dark and insecure pedestrian underpass linking it to the Pensarn Commercial Area. Parents and their children would have to walk some two kilometres and up Rhiw Babell hill to access the nearest Primary School at Llangunnor. This is unlikely to occur and
instead, parents will resort to travelling to school by private car, which defeats sustainability principles and objectives inherent in development plan policy making.
New housing at this location would accordingly be quite alien in form to the long-established business and education uses at Pibwrlwyd. Figure 6 below illustrates the distances to the nearest local primary school and green space in the locality.
Figure 6 – Remote distance of Pibwrlwyd Site from nearest Primary School
Pibwrlwyd
Llangunnor Primary School and Public park

6.0 CONCLUSION
6.1 The Allocated Site at Pibwrlwyd is substantial in overall size. The Carmarthen Cluster is expected to deliver 1690 units over the Plan Period, and thus the residential element of the Mixed-Use site (247 units) contributes 14.6% towards that overall total. That equates to one new house in every seven in the Carmarthen Cluster is being promoted at an “out-of-town” location, divorced from community facilities.
6.2 After over 20 years of UDP and LDP Plan Periods, only Welsh Government have enacted upon the Mixed-Use allocation, as evidenced at Cabna Court. Coleg Sir Gar in contrast over this time have not even undertaken any known marketing campaign to realise the asset bestowed upon by the above two Development Plans.
6.3 We submit that the Allocated Site be dramatically reduced in scale to only include the area about Cabna Court and Heol Glasdwr for employment purposes (B1, B2 & B8). The area about Coleg Sir Gar at Pibwrlwyd Lane could benefit from perhaps one sole modest field enclosure to allow for educational expansion. The remaining field enclosures, being the bulk of central 20 hectares, should be omitted from the allocation. The proposed housing allowance should be re-allocated elsewhere in Carmarthen to more sustainable Candidate Sites.
6.4 Clearly, there is no historic demand for a Mixed-Use site of this scale in this part of Carmarthen. New commercial development is attracted to Cross Hands East and Parc Dafen in Llanelli, being located further east along the A48 / M4 corridor, and thus locationally superior. The Cillefwr Industrial Estate and area about the Carmarthen Livestock Mart are able to satisfy future employment growth for the town of Carmarthen.
6.5 The overwhelming majority of the allocation has underdelivered. We would refer and advocate to the Inspector to heed Welsh Government’s Guidance provided in Development Plans Manual (Edition 3) (March 2020). Page 120 states: “Rolling forward allocations - Allocations rolled forward from a previous plan will require
careful justification for inclusion in a revised plan, aligning with PPW. There will need to be a substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered. The sites should be subject to the same candidate site process requirements as new sites i.e., they must be demonstrated to be sustainable and deliverable. If an LPA wishes to retain such sites but cannot evidence, they will be delivered, i.e., for aspirational or regeneration purposes, they can still be allocated in the plan but not relied upon as contributing to the provision. It will not be appropriate to include such sites in the windfall allowance. They should be treated as ‘bonus sites’.”

Remove the site from the Plan

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.