PrC2/h15

Yn dangos sylwadau a ffurflenni 1 i 2 o 2

Cefnogi

Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin

ID sylw: 5313

Derbyniwyd: 14/04/2023

Ymatebydd: Tata Steel Europe Limited

Asiant : Gareth Barton

Crynodeb o'r Gynrychiolaeth:

Strongly support the proposed residential allocation PrC2/H15 (Land at Maeryrddafen Road, Llanelli). The proposed allocation provides for approximately 94 new homes on the site.
The proposed allocation reflects that the site benefits from an extant outline planning permission for a residential development of up to 94 dwellings. This permission is dated 7 March 2022. The Council’s approval of this application clearly demonstrates the suitability and acceptability of the proposed development for residential development

Newid wedi’i awgrymu gan ymatebydd:

No change to the Plan

Testun llawn:

The Plan is currently unsound as it fails to allocate land at Maesarddafen Road/ Erw Las, Cefncaeau provide for residential development. The Plan is therefore not considered to be appropriate or effective.

Please refer to the accompanying cover letter and related enclosures for further details.

Cover letter:

I write on behalf of our client, Tata Steel Europe Limited (Tata Steel), in response to the current Carmarthenshire Second Deposit Revised Local Development Plan (RLDP) Consultation.

INTRODUCTION
Tata Steel owns and operates the Trostre Steel Works and owns Land at Maesarddafen Road/ Erw Las, Cefncaeau, which is allocated in the adopted Carmarthenshire Local Development Plan (2014) for residential development of 300 dwellings (site reference GA2/h35).
Part of this site (Land at Maesarddafen Road) was granted outline planning permission (reference: S/34991), for a residential development of up to 94 units on 7 March 2022. This permission remains extant. The Second Deposit RLDP includes this site as a proposed residential allocation (PrC2/H15).
An outline planning application for residential development is currently being considered by your Authority for the remaining land at Erw Las, which forms part of the current LDP allocation (GA2/h35). The application (reference: PL/05187) was registered on 29 December 2022 and the description of development is:
“The erection of new residential dwellings, vehicular access, open space and other associated infrastructure.”
Dialogue with the Council regarding this application is ongoing and we hope that it will be positively determined shortly.

The land in Tata Steel’s control at Erw Las, which forms part of the current LDP allocation (GA2/h35), is not retained as a residential allocation in the emerging RLDP.
Accordingly, the representations set out below:
• Provide support for the proposed residential allocation at Maesarddafen Road (PrC2/H15).
• Object to the failure to allocate land at Erw Las, Cefncaeau for residential development. A Sustainability Appraisal relating to this site, along with a site location plan accompanies this submission.
• Provide commentary on Policy EME1: Employment- Safeguarding of Employment Sites and request clarification of the policy wording.
Our detailed representations in relation to the RLDP are set out below. A copy of the requisite response form is also attached.

SUPPORT FOR POLICY HOM1 ALLOCATION PRC2/H15 – LAND AT MAESYRDDAFEN ROAD
Our client strongly supports the proposed residential allocation PrC2/H15 (Land at Maeryrddafen Road, Llanelli). The proposed allocation provides for approximately 94 new homes on the site.
The proposed allocation reflects that the site benefits from an extant outline planning permission for a residential development of up to 94 dwellings. This permission is dated 7 March 2022. The Council’s approval of this application clearly demonstrates the suitability and acceptability of the proposed development for residential development.
Carmarthenshire County Council’s Committee Report for the application (S/34991, dated 19 March 2019) confirms that the principle of development of the site is acceptable and the proposal complies with key planning policies and sustainability objectives.

The Committee report confirms that:
‘The site is well integrated with the existing pattern of development in Llwynhendy and is capable of accommodating a development of the scale and density proposed without compromising the quality of the scheme or detracting from the character and appearance of the surrounding area. The development will provide a wide range and choice of housing types and sizes which will be well related to the existing services and facilities in the wider Llanelli area as well as being within easy access of a variety of sustainable modes of transport. It will also contribute to the improvement of educational, open space and pedestrian and cycling facilities in the surrounding area. The level of contributions secured are considered to be commensurate with the scale and nature of the development.

In addition, the development satisfies the sustainability requirements of the LDP from an environmental quality and utility provision perspective by implementing a drainage strategy that will dispose of foul and surface water in a sustainable and controlled manner as well as providing betterment to the capacity of the public sewerage system. Furthermore, and as outlined in the appraisal above, there are no highway, amenity, or ecological objections to the development.’ (Page 13)
The conclusions drawn in granting outline planning permission remain unchanged when considered against national planning policy/guidance and the emerging RLDP. The site remains well integrated to the existing pattern of development, accessible to a range of sustainable modes of transport and capable of accommodating the scale and density of new homes proposed.

The site has been marketed by Harris Lamb Property Consultancy and offers have been received. We understand that discussions are progressing and Tata Steel has entered into an exclusivity period with a preferred developer. This demonstrates that the site is viable and deliverable in the short term.
POLICY HOM1: HOUSING ALLOCATIONS
Whilst supportive of the proposed allocation at Maeryrddafen Road, Llanelli (PrC2/H15) through Policy HOM1 (as set out above), our client strongly objects to the failure to allocate land at Erw Las, Cefncaeau for residential development.
The proposed site (see attached plan) forms part of a wider allocation within the adopted LDP (alongside land at Maesyrddafen Road) for a development of 300 residential homes (GA2/h35). As outlined above, the Council has already granted outline planning permission for up 94 units on part of this allocated site (application reference: S/34991 – land at Maesyrddafen Road). Whilst land at Maesyrddafen Road is proposed as an allocation in the RLDP, the remaining land within Tata Steel’s control at Erw Las is not carried forward as a proposed allocation.

Our client strongly supports the continued allocation of land at Erw Las for residential development. This would provide for additional new homes to come forward on a sustainable site, which is currently allocated in the adopted LDP.
The site is subject to an outline planning application for residential development (application ref: PL/05187) which was registered on 29 December 2022 and is currently being considered by Carmarthenshire County Council. We hope that the application will be determined positively shortly.
The plans and suite of supporting technical documents submitted alongside the application demonstrate that there are no significant constraints that would prevent the development of the site for the proposed use and confirm that the development complies with relevant planning policy.

Interest from the market has been received in relation to the site at Erw Las. This demonstrates that the site is both viable and deliverable in the short term.
In summary, Tata Steel wish to see its land at Erw Las retained as an allocation for residential development of circa 100 dwellings. The land holding (and existing allocation) also includes residual land which provides the opportunity to bring forward a considerable area of new public open space and green infrastructure.
Sustainability Appraisal
Accompanying this submission is a Integrated Sustainability Appraisal for the proposed site at Erw Las, Cefncaeau. The Sustainability Appraisal follows the template provided within the Council’s ‘Integrated Sustainability Appraisal (ISA) Guide for Promoters of Sites for Development’ (February 2023).
The appraisal confirms that the site represents a sustainable development option. The Integrated Sustainability Appraisal does not raise any significant constraints beyond those that could be mitigated through the detailed design of the development.
The technical documents prepared to support the outline planning application (application reference: S/34991) further establish the suitability of the site to provide residential development.
The site is also well served by good quality pedestrian routes and public footpaths providing links to the centre of Llanelli. A play area and area of open space is located directly to the north of the site to the rear of Tir Einon. The site is within walking distance of existing bus stops on Heol Hen, Maes Ar Ddafen Road and Llwynhendy Road, providing access to a range of destinations within Llanelli and further afield, including Llanelli Town Centre and the Trostre and Pemberton Retail Parks.
In addition to the Trostre and Pemberton Retail Parks, a range of services and facilities are located along Llwynhendy Road. A range of key services and facilities are therefore located within a 300-1500m walk of the site, ensuring the site has good accessibility.
Furthermore, there are clear similarities between the assessment of the allocated site at Maesyrddafen Road and the proposed site at Erw Las. Both sites were considered jointly in the adopted LDP and form a single allocation, acknowledging the close physical and functional relationship between the two sites, which includes a footpath running between the sites. It is considered that the land at Erw Las land performs as well as the proposed allocation at Maesyrddafen Road.
The land controlled by Tata Steel at Erw Las would provide a viable and deliverable allocation that could be brought forward quickly. As demonstrated above, a significant amount of technical work has been completed to support the outline planning application, confirming that the site is not impeded by significant technical constraints. The site could therefore be brought forward swiftly, contributing to the continuous supply of deliverable sites and thereby helping to address the identified need for new housing.
The development of the site will also help to sustain and enhance the existing services and facilities available within Llanelli, resulting in a wide range of spin-off benefits for the local community.

POLICY EME1: EMPLOYMENT- SAFEGUARDING OF EMPLOYMENT SITES
The Tata Steel owned Trostre Steelworks is designated within the RLDP as an existing employment area through Strategic Policy 7 (SP7): Employment and the Economy. Policy SP7 recognises the contribution of existing employment sites as part of the employment portfolio in meeting ongoing need.
Policy EME1 safeguards sites identified for employment purposes for such uses (specifically Class B1, B2 and B8 uses). Our client welcomes the designation of the Trostre Steelworks as an existing employment site. Tata also welcome the support for employment related proposals within this area as provided by both Policy EME1 and EME2, which allows for the extension and / or intensification of existing employment enterprises.
Policy EME1 sets out criteria where, exceptionally, proposals which result in the loss of employment sites is acceptable. The wording to that policy does not make it clear whether all or some of the criteria need to be met. This should be clarified. It is considered that only some of the criteria would need to be met as not all the criteria would be relevant to every proposal.
Support is, however, given to criterion (f) of Policy EME1 which allows uses which are complementary to the primary employment use of the surrounding area. This recognises that non B-class uses and ancillary uses can be appropriate for locations within an employment site. Examples (not exhaustive) of such uses could include those relating to education or visitor centres.

Summary
I trust that the above representations assist and changes are made to reflect the position of Tata Steel in the preparation of the Plan as it progresses.
I would be grateful if Turley/Tata can be kept informed of future stages of the emerging Revised Carmarthenshire Local Development Plan.
If you require any further information please do not hesitate to contact me.

Atodiadau:


Ein hymateb:

Support Welcomed. The allocation of the site within the LDP for residential purposes has been subject to full consideration through the site assessment methodology. As part of this assessment process a detailed site pro forma has been prepared.

Gwrthwynebu

Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin

ID sylw: 5828

Derbyniwyd: 14/04/2023

Ymatebydd: Ffos Las Ltd

Asiant : Carney Sweeney

Cydymffurfio â’r gyfraith? Heb nodi

Cadarn? Nac Ydi

Crynodeb o'r Gynrychiolaeth:

Notwithstanding sites affected by the SAC phosphates constraint, there are other sites throughout the County exhibiting deliverability issues. Similarly, we note the existing allocation PrC2/15 has been reduced in size due to concerns over deliverability:

Newid wedi’i awgrymu gan ymatebydd:

Remove site from Plan

Testun llawn:

Representations to Carmarthenshire County Council 2nd Deposit Revised Local Development Plan
Consultation
Land Adjacent to Culla Road Roundabout (B4317), Carway (Candidate Site ref: SR/023/003)

CarneySweeney is instructed on behalf of our client, Ffos Las Ltd, to submit representations to the
current consultation on Carmarthenshire’s 2nd Deposit LDP. This letter accompanies the following:

 Completed Representation Form;
 Site Location Plan;
 Site Ref: SR/023/003 Reasonable Alternatives Site Assessment Proforma (Carmarthenshire
County Council, February 2023); and
 Candidate Site Submission Supporting Statement (prepared by WYG, first submitted at First
Deposit LDP candidate site consultation).

These representations are made in relation to land adjacent to Culla Road Roundabout (B4317),
Carway; a site which was submitted as a Candidate Site during the 2018 Call for Sites (Candidate Site
ref: SR/023/003). The site successfully passed all three stages of the LPA’s previous assessment
process, scoring highly. The site is in single ownership and is immediately deliverable. Notwithstanding
this, the site is not currently being progressed by the Council as a draft allocation. The LPA’s stated
reason for not currently allocating the site, as stated within its Site Assessment Table (2023), is:
“Whilst there are no adverse impacts to the development of this site, there is more suitable and
appropriate land available within the village to accommodate new development”.
Whilst not currently allocated, the site is included as a ‘Reasonable Alternative’ site by the LPA within
their Site Allocation Assessment - Reasonable Alternatives Report, February 2023. The report
reiterates that the site performed suitably in terms of the RLDP Site Assessment Methodology, including
Integrated Sustainability Appraisal objectives. A copy of the site’s proforma is also enclosed with this
submission and clearly demonstrates how favourably the site scores against the RLDP’s key objectives.

It is our firm view the Council should re-consider its decision not to allocate this site for housing
development, and to this end we wish to make the following representations.
Candidate Site Description and Context
Full details of the site’s characteristics and development potential are provided within the enclosed
Candidate Site Supporting Statement (2018) prepared by WYG. This Statement was previously
submitted to the LPA as part of the Call for Sites process.
In summary, the candidate site (ref: SR/023/003) comprises c. 5.3ha of land which is bound by existing
residential development to the north, comprising the built settlement of Carway, and to the south by the
Persimmon housing development at Ffos Las racecourse. The site’s location is considered highly
sustainable, given its immediate proximity to Carway, Ffos Las racecourse and Trimsaran, and
associated facilities. The allocation and subsequent ongoing delivery for housing of the adjacent
Persimmon sites1 also establishes the sustainability of this location to accommodate new housing.
The site is free from physical constraints, being relatively flat with no existing buildings. The site is not
located within any heritage, ecological or nature conservation designations and lies within Flood Zone
A.
The site can be readily accessed from the existing B4327 Culla Road Roundabout, with a secondary
access point available at Heol Dyffryn Aur to the south.
As outlined above the site is immediately deliverable and as previously concluded by officers there are
no adverse impacts to the development of this site.
Pre-Application Advice (ref: PRE/01319)
Since the previous Candidate Site submission Ffos Las Ltd has sought pre-application advice from
Carmarthenshire County Council in respect of the proposed development of the site for housing. A
written response was received from the LPA in March 2023 (application ref: PRE/01319).
Whilst the current NRW Development Advice Map identifies the site within flood zone A, the preapplication
response notes that based on the emerging draft NRW Flood Map for Planning, part of the
site lies within flood zone 3 (see Fig. 2 below). The pre-application response advises that in accordance
with TAN 15 (which is due to be adopted for decision making in June 2023) vulnerable development
such as housing is generally not permitted in Flood Zone 3.
1 Pursuant to outline planning permission for mixed use development at Ffos Las racecourse and surrounding land (pp ref:
S/11568).
www.carneysweeney.co.uk
Figure 1: NRW Flood Map for Planning extract for Carway
Whist we acknowledge the above, it is important to note only a small proportion of the site is affected
by this Flood Zone 3 designation and, most importantly, it lies partly within Flood Zone 3 for surface
water and small watercourses only and is not deemed at risk of river and sea flooding. The latest
available version of the TAN 15 (January 2023, Consultation Version), is clear that vulnerable
development such as housing is generally not considered acceptable in areas that are flood zone 3 for
Rivers and Sea flooding specifically:
“Where development is proposed in any area facing flood risk from rivers and the sea, the
planning authority will need to be satisfied that its location is justified. It is important that areas
in Zone 3 are used only as a last resort, and not at all for new highly vulnerable development.”
(TAN 15 Consultation Version 2023, pp 10.10) (our emphasis).
Whereas, in terms of surface water flood risk, TAN 15 (Jan 2023) notes:
“Locally appropriate approaches can be incorporated into the Development Plan using local
policies, and in the decision-making process for planning applications.” (pp 4.8).
“The [Flood Map for Planning] shows areas at risk of flooding from surface water and small
watercourses, split into ‘Flood Zone 2’ and ‘Flood Zone 3’. These are considerations for
planning authorities and must be integrated into plan-making processes and decision-making.
For some developments it will be possible and appropriate to include management and
mitigation measures (refer to section 8).” (pp 5.2) (our emphasis added).
“A Flood Consequences Assessment will be required for any new development proposal
located fully or partly in Flood Zones 2 and 3 - Surface Water and Small Watercourses.” (pp
8.7).
The emerging TAN15 does not preclude housing development within surface water Flood Zone 3; such
development will generally be acceptable, subject to detailed design and appropriate management and
mitigation.
Accordingly, any future development proposals at the site would be supported by a Flood
Consequences Assessment and Drainage Strategy and would be subject to the separate SAB approval
process to secure sustainable surface water drainage measures. This is eminently achievable at the
detailed design stage and, therefore, should not be considered a barrier to the allocation of the site.
Additionally, it should be noted that significant drainage infrastructure has already been implemented
at this location as part of the delivery of, firstly, Ffos Las racecourse and latterly the housing allocation
being delivered by Persimmon immediately to the south (site allocation ref. SeC8/h1).
In respect to other potential site-specific requirements, namely, further ecological investigation, we
envisage this being carried out to help inform detailed development proposals and ensure Biodiversity
Net Gain (BNG) is delivered by on site delivery and/or by offsetting.
Housing Need and Supply
The Council’s pre-application advice concludes that while development of the site would be considered
contrary to the development plan (given the site’s current status outside the existing settlement
boundary), there is noted potential for small areas of local needs housing adjacent to the development
limits (in Carway) provided there is an established genuine local need.
We note the 2nd Deposit Plan Strategic Policy – SP4 ‘A Sustainable Approach to Delivering Homes’
states that:
“In order to ensure the overall housing requirement of 8,822 homes for the plan period is met,
provision is made for 9,704 new homes in accordance with the settlement framework in order
to promote the creation and enhancement of sustainable communities.”
Various population and household growth projections were assessed to reach the above requirement
figure. The ten-year based projection from Turley’s Housing and Economic Growth Report was chosen
to be taken forward for the RLDP, which projects a total population increase of 14,468 and a
requirement for 588 new homes per year.
We understand this annual housing requirement reflects build rates since 2007, which are
approximately 501 homes per year (paragraph 4 of the Housing and Economic Growth Report, Turley,
November 2022). However, this figure is less than half that of the 2014 LDP housing target, which was
1,013 dwellings per annum. Carmarthenshire Council has failed to deliver sufficient homes to meet local
demand for a longstanding period; basing future delivery on inadequate past build rates merely
compounds the longstanding issue of undersupply going forward into the new plan period.
The supporting Housing and Economic Growth report importantly notes that:
“Undersupply may though have contributed towards residents of Carmarthenshire living in
larger households than was previously anticipated, some potentially being left with no choice
but to stay in the family home or share with other adults due to a shortage of available housing.”
(pp 5).
There is clear, genuine local need. The strong market interest and swift and ongoing delivery of the
existing allocation in Carway directly adjacent to the site is a strong demonstration, itself, of local need.
We consider the housing targets proposed within the 2nd Deposit are insufficient to address previous
undersupply and meet the demands of the growing local population across the new plan period. We
consider housing targets should be lifted accordingly.
In order to achieve the RLDP’s goals to “promote the creation and enhancement of sustainable
communities” (RLDP Policy SP4), additional housing should be directed towards sustainable
settlements such as Carway. Carway is an identified Service Centre within the settlement hierarchy and
is accordingly appropriate for additional housing allocations (as per RLDP Strategic Policy SP3).
The subject site adjacent to Culla Road Roundabout (ref: SR/023/003) represents a sustainably located
site, as established in principle by the neighbouring allocated sites (refs: SeC8/h1, which has been built
out and SeC8/h3, which benefits from outline planning consent). Furthermore, the site is immediately
deliverable and by the Council’s own measure scored highly in the LPA’s candidate site assessment
process. Based on the Council’s Site Assessment Table (2023), the only reason for rejecting the site
www.carneysweeney.co.uk
as an allocation is a perceived lack of need. However, we encourage the Council to revisit its previous
conclusion on this in the context of the Council’s persistent undersupply of housing and added
uncertainty regarding the deliverability of the Council’s proposed housing allocations. Paragraph 4.2.10
of Planning Policy Wales 11 (PPW) stresses the importance that “The supply of land to meet the
housing requirement proposed in a development plan must be deliverable.”
Phosphates and SAC
We understand one of the principal reasons for the Council’s current consultation on a 2nd Deposit Plan
was to evaluate NRW’s guidance on riverine phosphate levels. Within the County, there are two riverine
Special Areas of Conservation (SAC) that are affected by this guidance: the Afon Teifi and Afon Tywi.
Planning applications for development that may increase phosphate levels in these rivers need to
demonstrate nutrient neutrality for development to proceed.
The 2nd Deposit Plan’s evidence base includes a Nutrient Mitigation Options Technical Review report
prepared by Ricardo (June 2022). The report notes that the Pencader Sewage Treatment Works and
Llandovery Waste Water Treatment works have the highest number of planning applications
constrained by phosphorus (page iv of the report). Therefore, it is apparent that future housing
development in Pencader and Llandovery is particularly constrained by the need for nutrient neutrality.
There is now, in our view, significant doubts as to the deliverability of the housing sites allocated within
the 2nd Deposit in these two settlements in particular, namely:
 Ref: SeC14/h2 Land adjoining Maescader, Pencader for 24 dwellings;
 Ref: SeC14/h1 Blossom Garage, Pencader, for 30 dwellings;
 Ref: SeC15/h1 Land to north of Dan y Crug, Llandovery, for 61 dwellings;
 Ref: SeC15/h2 Land adjacent to Bryndeilog, Tywi Avenue, Llandovery, for 8 dwellings.
In particular, we question the deliverability of site allocation ref: SeC14/h2 Blossom Garage. This site
has been subject to a recent planning application refusal (ref: W/39283). One of the principal reasons
for refusal was the site being located within the catchment of Afon Tywi SAC and not demonstrating
phosphate neutrality or betterment.
We note allocation ref: SeC15/h1 in Llandovery listed above has been allocated for many years and
remains undeveloped. The LPA’s supporting Site Assessment Table (2023) indeed notes concerns
over the deliverability of this site, and therefore reduces the size of the allocation within the 2nd Draft
Deposit RLDP. The riverine SAC phosphates constraint makes this site even less deliverable.
Other settlements in the County that have housing allocations near to riverine SACs are Newcastle
Emlyn (which is also largely constrained by SSSI and Conservation Area designations) (allocations for
51 units); Pont-Tyweli (14 units); Cwmifor (8 units); Carmarthen (1,283 units); Burry Port (501 units);
Llanelli (1,516 units); and Llangennech (94 units).
It is highly likely that proposed housing allocations in locations affected by riverine SACs phosphate
constraints will not be deliverable, either in part or in full. Indeed, site ref SeC14/h2 above has already
failed to achieve planning permission. Combined, we understand the above affected settlements are
allocated to provide an estimated 3,590 homes. On an assumption that just c.25% of these allocations
failed to be delivered due to the riverine SAC phosphate constraint, this would lead to a significant
shortfall of c.897 homes throughout the Plan period.
Notwithstanding sites affected by the SAC phosphates constraint, there are other sites throughout the
County exhibiting deliverability issues. For instance, existing allocation Ref: SeC16/h1 - Llandeilo
Northern Quarter has been reduced in size due to deliverability concerns. We understand this site has
been allocated for a longstanding period without being delivered. Similarly, we note the below existing
allocations, totalling 115 units, have been reduced in size due to concerns over deliverability:
 Opposite Village Hall in Cwmifor for 16 units (ref: SC30/h1);
 Land at Maesarddafen, Llanelli for 94 units (ref: PrC2/h15);
www.carneysweeney.co.uk
 Heol Y Graig, Llwynhendy for 5 units (ref: PrC2/h28).
The 2nd Deposit Plan’s current reliance on riverine SAC phosphate affected housing allocations, and
other failed/constrained allocations gives rise to significant uncertainty as to the Plan’s effectiveness,
and, indeed, soundness.
Meanwhile, the subject land adjacent to Culla Road Roundabout (candidate site ref: SR/023/003) has
been excluded, on the seemingly sole basis that there is no need for the allocation. In regard to the
riverine SAC phosphate constraint, land at Culla Road is entirely unconstrained. As outlined previously
and acknowledged by officers there remain “…no adverse impacts to the development of this site…”.
We stress the site should be reconsidered for allocation.
Figure 3: Aerial view of Carway, overlaid with the existing settlement limit boundaries (shown in blue) and the
indicative site boundary (outlined in red)
Figure 3 clearly demonstrates the potential for development of the site as a logical “completion” or
“rounding” of the settlement of Carway, which is currently in two parts and physically divorced by the
subject site. Infilling the land between both parts of the settlement presents an opportunity to cohesively
develop the Service Centre settlement, without extending the built limits of the settlement or incurring
any further into the surrounding countryside. There has been significant market interest in the site from
housing developers, which indicates strong demand for the delivery of the site to meet local housing
need in Carway. The accompanying Supporting Statement sets out the merits to delivering the site for
much needed housing.

Summary
To summarise the above:
 Candidate site ref: SR/023/003 ‘Land adj. Culla Road Roundabout (B4317), Carway’ was
submitted as part of the 2018 Call for Sites. It scores highly across all stages of the LPA’s
assessment process;
www.carneysweeney.co.uk
 Pre-application advice (ref: PRE/01319) notes the site lies within Flood Zone 3 in the emerging
TAN15. The site lies within Zone 3 for surface water and small watercourses flooding only (i.e.
not river or sea flooding), whereby development for housing is generally acceptable; in
accordance with TAN 15 (Jan 2023);
 Site specific assessments such as ecological surveys etc. can be provided as part of any future
proposals at the site, to ensure Biodiversity Net Gain is achieved. There are no insurmountable
site constraints identified at this stage. The site is readily deliverable;
 The proposed provision for 9,704 homes within the RLDP to meet an identified requirement for
8,822 homes at c.500 homes per year is considered insufficient and will compound
longstanding undersupply. The County should be targeting an increase in annual build rates,
in order to provide for the future population growth and meet local need;
 Based on current draft allocations the riverine SAC phosphate constraint will likely significantly
constrain the delivery of housing across the County over the emerging plan period, particularly
in Pencader and Llandovery. The Council’s previous conclusions on need should be thoroughly
reassessed. The proposed site at land adjacent to Culla Road Roundabout (ref: SR/023/003)
is unconstrained and immediately deliverable.
 The sustainability of this site location is established and confirmed by the Council’s own site
assessment process. Delivery of the site for housing will logically complete the Carway
settlement and meet clear and genuine local need. There has already been significant market
interest in the site by developers. The site should be allocated for housing within the RLDP.
We trust that the above/ enclosed representations will be taken into consideration as part of the future
progression of Carmarthenshire’s RLDP.
We look forward to being kept informed of the RDP’s progress and hearing from you in due course.
Should you require any further information or wish to discuss further please do not hesitate to contact
us.

Atodiadau:


Ein hymateb:

Disagree, the allocation of the site within the LDP for residential purposes has been subject to full consideration through the site assessment methodology. As part of this assessment process a detailed site pro forma has been prepared