PrC2/h22

Remove site from Plan

Further to the publication of the above document, we have been asked by our Clients to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so we consider it necessary to
make a formal representation to the “soundness” of the Carmarthenshire Deposit Local
Development Plan in relation to the allocation for residential development at land at Cwm y
Nant, Dafen (LDP Ref. No. PrC2/h22) under the provisions of Policy HOM1. The proposed
allocation has been fully assessed and in considering its context and background
(summarised below) it is considered that its continued inclusion will lead to the Plan failing
the 3 Tests of Soundness for the reasons set out below.

Site Background and Context
The allocation relates to the land shaded brown on the Proposals Map extract below and is
proposed for allocation in the 2nd Deposit LDP for the purposes of 202 residential units.

Plan A
(Extract of Proposals Map for Cwm y Nant Allocation)

As part of the current consultation process into the 2nd Deposit LDP, the Council have again published a “Site Assessment Table” (2023), which provides details of the Council’s analysis of each received Candidate Site submission and existing allocations within the current adopted LDP. Proposed allocation PrC2/h22 was considered as part of this process and as a result the Council concluded as follows:
“Part of the allocation was not included in candidate site submission SR/086/025. Part of the remainder to be retained as a residential allocation as part of a wider area at Cwm Y Nant. Reference is made to site SR/086/025 et al below. Site to be allocated (part) with reference PrC2/h22.”
“Site(s) to be retained as a residential allocation. Reference is made to site GA2/h30 above. Site to be allocated with reference PrC2/h22 (only part of GA2/h30).”

It is clear from the above that the Council considers that the site is deliverable for the purposes of 202 houses, although it is not clear on what basis this conclusion has been made.
The allocation is greenfield in nature with its topography sloping gently from the south to the north. The southern perimeter of the site is bordered by residential properties while the
western and northern boundaries are bordered by industrial uses. The eastern boundary is then bordered by further greenfield land as can be seen from the aerial photograph below (outlined in red below).

Photograph 1
(Extract from Google Earth – June 2021)

Access to the allocation is currently unknown, however the north western perimeter of the site borders Nant y Gro (see below).

Photograph 2
(Streetscene of Nant y Gro)

Outline Planning Permission was first granted for the Proposed Residential Development for 26 Bungalows (S/25729) in the southernmost part of the allocation. Outline Planning Permission was also granted for the whole site in 2021 for the Proposed Construction of up
to 202 Units with Associated Landscaping and Infrastructure Works (S/40692). However there have been no applications made to further this development to date.
The site makes up part of an allocation in the Carmarthenshire Local Development Plan (2014) under Allocation GA2/h3 as well as the Carmarthenshire Unitary Development Plan (2006) under allocation GR2/18 as can be seen below.

Plan B
(Extract of current LDP Proposal Map for Cwm y Nant (Adopted 2014))

Plan C
(Extract of Carmarthenshire UDP Proposal Map for Cwm y Nant (Adopted 2006))

Despite having almost 20 years of support for the principle of residential development at the historic allocation from the Council, not a single housing unit has been delivered to date. We are led to believe that there is also no active marketing strategy for the development and the Council being the landowners are merely seeking to secure an outline permission on their own land asset.

Tests of Soundness
Based on the above information and the guidance documents provided by the Welsh Government and Council itself, it is considered that the inclusion of the adoption of the LDP in its current form with the inclusion of the allocation in question, would result in it failing to meet the requirements of the Tests of Soundness, for the reasons summarised below.

Test 1 – Does the Plan Fit?
The allocation fails the test of soundness as its inability to be delivered is in conflict with Paragraph 4.2.2 of Planning Policy Wales (Edition 11) requirements of national planning policy.

Test 2 – Is the Plan appropriate?
The allocation fails the test of soundness as its inability to be delivered would fail to address key issues set out by the Plan (housing supply). The Council’s decision to allocate the land appears to not have been done so on credible or robust evidence.

Test 3 – Will the Plan deliver?
The allocation fails to test the soundness as the site is clearly unable to deliver any new housing. The Welsh Governments Development Plans Manual (Edition 3) is quite clear with regard to rolling forward allocations and states that 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 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”. No evidence has been presented to demonstrate a change in circumstances to indicate the allocation will now be deliverable and so its continued allocation would lead to the plan being deemed unsound on this basis.

In summary, we object to the inclusion of the allocation in question on the basis of the above and that its inclusion within the Plan would result in the document being ‘unsound’.

We therefore respectfully request that this Representation be given careful examination, and that the allocation be removed to ensure that the document passes all the relevant tests of soundness.

Remove site PrC2/h22 from the Plan.

INTRODUCTION
1.1 Evans Banks Planning has been instructed by Mr C. Hurley (the Landowner) to prepare and submit a Representation for an Alternative Site to the Second Deposit Draft for the allocation of land at “Oaklands,” Furnace Road, Burry Port for the purposes of residential development in the Replacement Carmarthenshire Local Development Plan.
1.2 This Statement has been prepared in line with the Authority’s published documents entitled Revised Carmarthenshire Local Development Plan: Guidance Note and Revised Carmarthenshire Local Development Plan: Candidate Site Assessment Methodology. The contents of this Statement therefore address the set criteria, determining issues and each qualifying point raised within these documents
Consideration has also been given to ensuring that this formal submission complies with the guidance and requirements of Planning Policy Wales (Edition 11), in relation to the preparation of development plans and the allocation of land for residential purposes as part of that preparation process.
1.3 The contents of this Statement therefore provide a comprehensive case for the allocation of the land for residential development purposes and it should also be read in conjunction with the accompanying supporting information and indicative site layout plan.

2
2.0.0 SITE CONTEXT
2.1 THE SITE
2.1.1 The Alternative Site relates to part of a generally level, but large domestic curtilage associated with a detached dwellinghouse known as “Oaklands.” It is set immediately off the western flank of Furnace Road to the western side of the settlement of Burry Port. The Alternative Site is an irregularly shaped enclosure with the house set within the southern half of the site, and lawned garden area stretching north to an embankment with a former railway cutting.
2.1.2 The southern boundary of the site lies parallel with the boundary of the Ashburnham Hotel grounds and a similarly level enclosure at that site and the junction of Furnace Road with Ashburnham Road. That southern boundary is tree-lined, with the frontage with Furnace Road marked by an intermittent hedgerow for its 95 metres length.
2.1.3 The western perimeters of the site fall onto scrub which is also gently level to undulating and is set to separate Burry Port from Pembrey, but that undeveloped gap is only some 175 metres from the domestic curtilage of Oaklands to the eastern fringes of established houses at Pembrey.
2.1.4 The Site relates to some 0.99 hectares (2.45 acres) of well-maintained lawns with established, two-storey dwellinghouse. It has an independent vehicular driveway off Furnace Road set directly opposite established residential properties off the eastern flank of that road, where two-storey semi-detached local authority-built houses are concentrated as part of the “Bryniltyd Estate”.
This part of Burry Port is characterised by modern housing, mostly of 1960s and 70s origin and local-authority-built. The Brynilltyd estate also includes Brynymor, which extends over several access and off one access on to Furnace Road, directly opposite the access to Oaklands.
2.1.5 The Site field parcel is identified by being edged in red on the plans below. Plan A illustrates their wider position with the settlement of Burry Port. Plan B provides a detailed Ordnance Survey map extract with the site perimeters identified.
Plan A – setting of Oaklands at Burry Port
Detailed OS Plan - Plan B
2.1.6 The Site consists of a large, domesticated curtilage which already contains a sizeable residential property. The development of the site which will form a mirrored extension to the Brynilltyd estate, appearing as a continuation of the existing row of semi-detached properties and single detached house off the opposite flank of the Furnace Road carriageway. It is therefore well defined by those existing natural and man-made perimeters.
Plan C below provides a Google Earth image of the site and its surroundings, in which the above physical features are readily apparent.
Plan C – Google Earth image of Site
2.1.7 The Site’s well-defined perimeters and immediate proximity to the adjacent established residential properties off the Furnace Road highway, are shown within the photographs below. The photos also depict the existing boundary fence separating grazing fields and access road of the Candidate Site.
Photograph 1 – view of Site with existing dwelling set centrally with large curtilage
Site
Adjacent residential estate of Brynlltyd
Photograph 2 – view from existing Furnace Road carriageway looking over Site with Oaklands dwelling in background
Photograph 3 – view of properties off opposite, eastern flank of Furnace Road
Photograph 4 – view of southern tree-lined boundary with Ashburnham Hotel enclosure
Photograph 5 – view from bridged crossing of former railway line (now cycle path) looking at vegetated northern boundary of site
2.2 SETTLEMENT SUSTAINABILITY AND SITE SETTING WITHIN DRAFT LOCAL DEVELOPMENT PLAN
2.2.1 Under the Second Deposit Draft of the Carmarthenshire Local Development Plan, Oaklands falls adjoining the Settlement Limits for the settlement of Burry Port. The large domestic curtilage lies immediately adjoining established estate properties off the eastern flank of Furnace Road. The site is edged in red on the map extract.
Plan D – Extract from Second Deposit draft LDP Proposals Map of Burry Port
2.2.2 As can be seen, the Site adjoins and is well related to the Second Draft LDP Development Limits for Burry Port, and also within walking distance of the village centre
at Gwscwm Road to the north-east via the existing surfaced pavement of Furnace Road and east along Ashburnham Road.
2.2.3 Access to the Site could be achieved with a new junction onto Furnace Road, with the existing house driveway and access retained. The proposed access road would lead into a proposed cul-de-sac development, with conventional hammerhead turning area.
2.2.4 The Site’s position and proposed use therefore represents a natural and logical location for the settlement’s expansion in the context of adjoining established and proposed residential development.
As detailed above, the Site adjoins and in effect lies within the existing settlement and form of Burry Port. The existing built form and pattern of the settlement follows key access routes, such as the A484 Gwscwm Road and Lando Road, to the north and Ashburnham Road. The established town centre at Station Road extends off Ashburnham Road, with multiple cul-de-sac modern developments concentrated to the mid-hillslopes to the north of the A484 road, or south to the main railway line extending west to east from Burry Port to Kidwelly.
Burry Port is particularly popular to new homeowners due to its coastal position, and short drive to Llanelli, and in particular the A484 link to Carmarthen.
2.2.5 In terms of the Site is located within easy walking and driving distance of all community facilities and local services present and provided within the settlement of Burry Port. Access to further facilities in the towns of Llanelli and Carmarthen can then be gained by regular bus services, stops for which are located some 90 metres from the Alternative site at the junction of Ashburnham Road with Furnace Road.
The sustainable position of Burry Port should therefore be given full consideration when considering potential future growth options.
2.2.6 Housing Land Availability within Second LDP Draft
We have examined and researched sites which have been brought forward as Residential Allocations with the Deposit Draft. Burry Port falls under the Llanelli Cluster which extends along the Burry Estuary coast from Kidwelly in the west to Bynea in the east, and north to Llangennech and Hendy about the M4 corridor.
Great emphasis within the Draft Plan has been placed upon the continued allocation of proposed housing sites still left allocated from the 2014-21 Local Development Plan. Figure 1 below provides an extract from the Deposit Draft Schedule of Housing Sites from Policy HOM1, relating first to Burry Port, and accordingly across the remainder of the Llanelli Cluster.
Extract from Policy HOM1 – Burry Port
Figure 1 – Selection of Deposit Draft Housing Schedule in Llanelli Cluster
We note that within the Proposals Map for Burry Port, it included for three sites, two of which have been completed at Goodig and Glanmor Terrace leaving just one proposed site, which being the Harbourside site for 364 dwellings. The site has been marketed by the County Council for many years, and despite its coastal position, has failed to receive firm interest and any form of detailed planning application. Ground conditions require extensive remediation of former historic uses.
2.2.7 The Llanelli suburbs of Llwynhendy / Cefncaeau and Dafen, where four of the above allocations are identified, has not altered since the 2014 adopted LDP and remain undeveloped but re-allocated in the Deposit Draft.
Cwm-y-Nant (PrC2/h22) and Dafen East Gateway (h/23) were both sites allocated within the Carmarthenshire Unitary Development Plan (2006) and as mentioned above, within the Local Development Plan (2014) as sites GA2/h27 and h/30 & h/31. They
have a combined total of 352 dwellings, although neither site has been the subject of any detailed planning application, let alone market interest.
The locality is riddled with historic coal mining activity, with low lying coal seams, together with multiple mine entries across all Dafen sites. Clearly, any residential development upon either site will have to overcome ground remediation to stabilise the ground for residential foundations. The abnormal costs of which are likely to be significant, and hence present the development costs as leading to unviable and undeliverable sites.
2.2.8 Beech Grove at Pwll (PrC2/h1 has remained allocated for 10 units for the last 20 years in Development Plans. No application for planning permission has even been lodged at the site.
2.2.9 Cae Linda in Trimsaran (SeC8/h2) for 20 units has been in Development Plans stretching back to the Llanelli Borough Local Plan in 1995. It has only been developed with 5 houses, and thus its continued allocation for twenty more units in the draft LDP must surely come under question?
2.2.10 Consequently, at least twenty years of Development Plan allocations have elapsed without any signs of wholesale delivery of these sites. Clearly, there is no historic demand for sites of these scales in parts of the Llanelli, Trimsaran and Burry Port / Pembrey areas. All are certainly physically challenging sites, many of which have historic industrial or coal mining legacy issues, which may require significant abnormal costs to achieve developable areas for residential use.
We submit that the above draft allocations be omitted from the Plan, and that housing allocation be redistributed to Alternative Sites, of circa 20-25 units such as that proposed at “Oaklands” at Burry Port. There is clear evidence that such moderately sized sites are far more likely to be brought forward and developed in full by regional 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.
2.3 Settlement Facilities
2.3.1 The Site at Furnace Road lies some 10 minutes’ walk from the centre of the town at Station Road.
Public bus stops lie immediately off the junction of Furnace Road with the Ashburnham Road carriageway.
Main public bus services call at these bus stops, and further stops are available at Stockwell Lane in particular:
- Service 111 – Kidwelly to Swansea, calling at Pembrey, Burry Port, Llanelli, Trostre, Gorseinon, and Fforestfach
- Service X11 – Carmarthen to Swansea, calling at Ferryside, Burry Port, Llanelli, Trostre and Fforestfach retail parks
2.3.2 The site is within 10 minutes’ walk, to the London Paddington to Fishguard / Pembroke Dock rail service at Burry Port station.
2.3.3 The Site lies within a 5-minute walking distance of Pembrey Primary school at Ashburham Road.
Ysgol Y Strade and Burry Port Secondary Schools are located at Llanelli and Burry Port respectively, with pupil bus transport available to Ysgol-y-Strade.
The CCTA campuses at Llanelli and Carmarthen are also available via student bus services.
2.3.4 Nearby Pembrey contains a post office, two public houses and community hall along Ashburnham Road.
Burry Port town centre provides a range of small comparison shops, supermarket, petrol filling station, public houses / cafes, offices, rail station and industrial estates.
Plan E below provides an indication of the proximity of the site to Burry Port town centre, with its rail station and strategic road network to Llanelli and Carmarthen.
The red star denotes the position of the Site.
Plan E – proximity of Site to Burry Port town centre
Primary School
Suoermarket and town centre
Rail Station
A484 Road to Llanelli and Carmarthen

3.0 THE PROPOSAL
3.0.1 As part of the requirements for the promotion of sites for residential development, this Statement is accompanied by an indicative layout for a potential residential scheme that could be developed on the site. It should be emphasised that the accompanying layout is for illustrative purposes and that other design solutions for the site could also be reached. Notwithstanding this, the accompanying layout drawing has taken account of all the potential assets and constraints of the site and demonstrates that it is capable of delivering 18 houses in a deliverable and sustainable manner. The following information therefore expands on this principle.
3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Site be allocated in the replacement LDP for the purposes of a total of 18 residential units. As detailed above, the accompanying illustrative layout (reproduced below at Plan F) demonstrates that the site is capable of accommodating this number in a deliverable and sustainable manner.
Site layout plan - Plan F
3.1.2 As illustrated above, the site is capable of accommodating detached and semi-detached, two-storey houses to replicate and being reflective of the existing form and density of residential development in the immediate locality.
3.1.3 With regards to access, it is proposed that the Candidate Site would be served by a 6.0 metres wide radii junction onto Furnace Road. This stretch of Furnace Road experiences vehicle speeds which are respectful of the 20mph speed limit, given the presence of speed humps. Visibility splays of 2.4m x 43m can be achieved within this built-up locality.
3.1.4 The Site proposals can fully retain all existing boundary treatments, being the established mature hedgerows across the southern and northern sides of the field, which would be retained and managed wherever possible.
3.1.5 Although due to the proximity of existing facilities in Burry Port, the proposal does not include any formal areas of play or open space. It is recognised and supported that an element of the proposed units could be Affordable in nature, or contributions made to support affordable housing elsewhere in the Llanelli locality, which under the provisions of the current LDP would be in the region of 20% of the total number of dwellinghouses.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Development of the Site for residential units would be served by mains water, gas, public sewer and electricity connections, which either lie within the respective stretch of Furnace Road carriageway.
3.2.2 The estate road highway itself is equipped with roadside gullies and drainage which aid to discharge run-off from the carriageway. The proposed access to the site could connect to the existing highways drainage.
3.2.3 The Site comprises of domesticated lawns. There are no areas of significant marshy grassland or water-logging evident, and therefore at first inspection, it appears that the site benefits from good ground percolation of rainwater.
3.2.4 Soakaways would be the most sustainable means of disposing of surface water from individual properties. If required, attenuation measures can be deployed on site to control surface water run-off during extreme storm events, which could also allow for additional capacity, making allowances for climate change. Such features can be hard engineered in the form of small to modestly-sized subterranean storage crates or tanks. The field enclosures are served by a series of drainage ditches along the fields boundaries, which eventually combine and inter-connect discharging surface water which eventually discharge to the Estuary. It is considered that as a result of on-site features, there would be a number of options available to a future development of the site in terms of surface water disposal.

4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 The Site has been assessed against data held on the “Data Map Wales” website, which details statutory and non-statutory National and Local sites of ecological importance. Plan G below provides an extract of those records as applied to the Burry ;Port & Pembrey locality. The red star denotes the position of the Alternative Site.
4.1.2 The records reveal that the Site does not include or adjoin any national or local nature conservation designation. The site is some 0.5 kilometres distant from the Special Area of Conservation at Carmarthen Bay.
4.1.3 Any biodiversity assets that may be present at or adjoining the Site have been given full consideration with regards to exploring its potential for residential development. This has included the proposed retention and management of existing boundary tree and hedgerow features. It is envisaged that the entirety of mature trees off the northern and southern boundaries could be retained and managed further for uninterrupted biodiversity gain.
Plan G – Extract from Data Map Wales detailing any known ecological interests
4.1.4 In the wider context, the site does not adjoin or form part of any local or national nature conservation designation. There are a number of areas of established woodland, which are clearly evident on the Google Earth image presented as Plan C above. These will not be affected by development within the Site, as the indicative site layout provides
for enough buffer space to those existing root systems and crown spreads, and can be fully retained in situ, providing continued ecological retention and connectivity.
4.1.5 It is considered that any statutory and non-statutory designations are significantly distant from the site, which will ensure that its development would have no detrimental impact on them.
4.2 HISTORICAL ASSETS
4.2.1 The Site has been assessed for any proximity to known and designated Historic Assets, using the “Cof Cymru – National Historic Assets of Wales” from CADW’s website. An extract from Cof Cymru Assets map for this part of Burry Port is reproduced below as Plan H The red star denotes the position of the Candidate Site.
4.2.2 The Site does not include or form part of any Listed Buildings or proximity to a Conservation Area. There are no Conservation Areas located near the Candidate Site. The proposed development of the Site would not have any detrimental impact on the setting or interest of any nearby historical asset.
Plan H – Extract from Cof Cymru Historic Assets website
4.3 ENVIRONMENTAL CONSTRAINTS
4.3.1 Potential for Risk from Flooding
The Site has been assessed against the Flood Map for Planning, prepared by Natural Resources Wales. An extract from the FMfP map is reproduced below as Plan I, with the site denoted by a red star.
Plan I – Extract from NRW’s Flood Map for Planning
4.3.2 The above plan extract reveals that the field enclosure lies just outside a designated Flood Zone 2, which is located along the former railway line, and to its north.
4.3.3 An examination has also been made of the NRW records relating to potential surface water flooding. Plan I above reveals areas of land in the locality susceptible to such surface water flooding risk. The purple tone denotes the positioning of the Alternative Site and reveals that the site is free from any such constraint.
4.3.4 Any development of the Site would involve engineering works to ensure that their sufficient on-site attenuation of surface water and that the existing boundary drainage ditches are improved and have sufficient capacity to receive surface water from existing and proposed developments.
4.3.5 Past & Present Potential for Ground Contamination and Coal Mining Activity
The Site comprises a large domestic garden. Due to its greenfield nature and domestic use, the rear field of the Candidate Site has no history of known past ground contamination related constraints. Whilst the locality has historically been the subject of coal mining, the records of The Coal Authority have been examined to ascertain any precise mine entries, addits or seams of shallow coal and mine workings. An extract from The Coal Authority interactive mapping base is reproduced as Plan L, with the site identified by a red star.
Plan L – Extract from Coal Authority’s records map for locality
4.3.5 The Coal Authority records reveal that the site is not directly affected by any coal mining legacy, which is concentrated to a seam to the north at the crest of the hillside descending south-eastwards towards Burry Port.

5.0 VVIABILITY IABILITY
5.0.1 As part of the preparation of any development plan, it is vital to ensure that allocations within it are both viable and deliverable. To not make efforts to explore both these aspects inherently poses risks that the Plan may be unsound and so in turn fails to meet its own targets or objectives.
5.0.2 Although detailed viability appraisals are difficult to prepare at this stage of the Plan’s preparation due to the absence of, for example, such things as full engineering details, it is possible to undertake such appraisals at a strategic or in-principle level. The following therefore represents such a process and is fit-for-purpose in providing confidence with regards to both the viability and deliverability of the Candidate Site at this stage. It should be noted that more detailed analysis at a planning application stage may result in some potential variance.
5.1 VIABILITY APPRAISAL
5.1.1 The following provides an indication of the viability of delivering the proposed 18 units on the Site in question. It is based very much on its greenfield status and uses values and costings previously accepted by the Local Authority through its determination of planning applications and other works. The following appraisal is therefore based on the assumptions set out below in order to provide a residual land value for the scheme.
Costs
• Dwelling construction costs are based on an absolute minimum of £1300 per metre given that bespoke four bed detached houses (140 sq.m.), with a medium grade of internal finishing, and formation of accesses to the highway are likely to be the preferred house type. Three bedroomed semi-detached housing of 85 sq.m. is also proposed
• Estate road carriageway costs of £1200 per linear metre
• Connections for all utilities include water, foul water and electric.
• Developer’s Profit based on minimum RICS guidelines (18%)
• Professional Fees include planning application fee, associated professional fees, estate agency fees (1%) and LABC Warranty fee.
Sales Values
• Sale Prices based on LPAs “Affordable Housing” Supplementary Planning Guidance, market research and Welsh Government “Acceptable Cost Guidance” figures where relevant.
5.1.2 Using the above, the following represents a strategic viability appraisal for the proposed 18 units, based on an affordable housing level of 20% which provides for 3 x three-bed dwellinghouses.
Costs
Cost Per Unit/Metre
No. Units/Metres
Total
Four Bed Houses
182,000
8
1,456,000
Three Bed Houses
110,500
10
1,105,000
Estate Road
1200
130
156,000
Utility Connections
5000
18
90,000
Professional Fees
-
-
90,000
Sprinklers
3500
18
63,000
Parks Contribution
2464
18
44,000
Education Contribution
1000
12 children
12,000
Total
3,016,000
Sales
Four Bed (Open M’kt)
295,000
8
2,360,000
Three Bed (Open M’kt)
245,000
7
1,715,000
Three Bed Affordable
91,000
3
273,000
Total
4,348,000
Developers Profit
Total
783,000
Residual Land Value
549,000
Table 2
5.1.3 Based on the above figures, it is considered that in-principle, the development of the site would be financially viable. The residual land value of £549,000 with a net area of 2.2 acres is consistent with evidence gathered over recent years by the District Valuer in examining residential site transactions within Carmarthenshire. The DV discovered land values on completed and on-going sites to be averaging £245,000 per net residential acre of land, based on 2020 values.
5.2 DELIVERABILITY
5.2.1 In terms of deliverability, it should be firstly noted, as illustrated above, that the site is financially and physically viable, with no environmental, geo-physical or technical constraints prohibiting immediate development. Furthermore, there are no ownership or third-party interests preventing the site’s delivery.
5.2.2 In terms of a delivery timescale, with a developer secured, it is envisaged that the site could be capable of being completed within 3 years from the adoption of the replacement Local Development Plan. Burry Port remains an attractive part of the Carmarthen Bay coastline, benefitting from its semi-rural location, but easy access to
Carmarthen and Llanelli by road and rail and the nearby schools, shops, services and community facilities.
5.2.3 The presence of modern, detached houses located near the site at Ashburnham Road is testament to this market need and the desire for home buyers to seek out such forms of modest residential development.

6.0 NATIONAL PLANNING POLICY CONSIDERATIONS
6.1.1 In the preparation of any development plan, consideration must be given to national planning policy and guidance. At present, this takes the form of Planning Policy Wales (Edition 11) and a series of Technical Advice Notes (TAN) that deal with a range of topic areas.
6.1.2 With regards to residential development, or housing, the overarching requirements and principle guidance set by national policy can be found in the PPW, which reads as follows:
“Local planning authorities must ensure that sufficient land is genuinely available or will become available to provide a 5-year supply of land for housing judged against the general objectives and the scale and location of development provided for in the development plan. This means that sites must be free, or readily freed, from planning, physical and ownership constraints, and economically feasible for development, so as to create and support sustainable communities where people want to live. There must be sufficient sites suitable for the full range of housing types.”
6.1.3 At present, Carmarthenshire County Council’s housing supply figure is below the required 5-year level and so it is imperative that this is addressed as quickly as possible to avoid further deterioration of communities and the facilities and services they have to offer. The instigation of the formal Review of the LDP will form part of addressing this issue, but only if truly sustainable and deliverable allocations are identified and allocated, to replace many of the failing sites that currently form part of the Authority’s housing and growth strategy for the County, as set out by the current LDP.
6.1.4 Dealing specifically with the Site subject of this Report, it is evident that its inclusion within the Replacement LDP would adhere to the requirements of PPW in that it is free from any planning, physical or ownership constraint. In addition, as shown at Section 5 of this Statement, the site is also economically viable in deliverability terms.
6.1.5 PPW provides Authorities with more specific guidance in selecting sites for allocation for residential development and in terms of the Candidate Site, it is considered that it satisfies all relevant criteria, including the following:
• The location of the Site is sustainable in terms of its proximity to a range of community facilities, local services and public transport services.
• The physical and social infrastructure of the settlement is capable of accommodating the proposed development without detriment to any interest.
• The Site is not subject to any physical constraint such as ground instability, ecological interest, flood risk, historic assets or contamination, that would prevent its delivery.
• The development of the site for residential purposes would be compatible with existing adjoining land uses, and its form contained by firm, defensible perimeters.
6.1.6 In summary therefore, the allocation of the Site adheres and supports the objective, principles and requirements of national planning policy.

7.0 CONCLUSION
7.1.1 The Site consists of a large, domesticated garden area to a detached house, but lying immediately adjoining an estate of local-authority-built houses, and along Furnace Road which links Gwscwm Road (A484) with Ashburnham Road. The development of the site would mirror development of the eastern flank of the road without the site spilling into the surrounding undeveloped gorse set between Pembrey and Burry Port.
7.1.2 The Site forms a logical extension to the existing settlement, being well related to established residential development off its eastern perimeter; and further development at Bryniltyd. The Site can be found to be capable of being accessed off the existing public road carriageway, via a new junction which benefits from good visibility onto the Furnace Road. The development of the Candidate Site will mirror the existing modern housing arrangement off Bryniltyd.
7.1.3 The precise location is such that the strong defensible boundaries of boundary hedgerows and trees, coupled with adjoining former railway cutting, provide a natural and part physical screen from views within the wider landscape. The development of the site would take place against the backdrop of higher ground to the north and a residential estate to the immediate east. Accordingly, the development of the site would remain more akin in character to the built-up form of Burry Port, than open gorse and shrub to the north and west.
7.1.4 In addition to the above, the site lies within close proximity and walking distance of the existing community services and local facilities of Pembrey and Burry Port, particularly the post office, public houses and Primary School at Ashburnham Road, which will ensure it makes a positive contribution to both national and local sustainable development objectives.
7.1.5 From a wider sense, the Site will also benefit from well served excellent public transport links to the nearby settlements, specifically the towns of Llanelli and Carmarthen, together with other locations within and adjoining the County. In tandem to this, the development of the Site will in turn ensure a deliverable source of future housing for the Local Service Centre in which it lies, which has seen less than half allocated sites being part or fully developed leading to an under supply since the adoption of the current LDP. The development of the Site will help to redress this imbalance and it is strongly suggested that the Authority closely scrutinises those sites currently allocated in the draft LDP in terms of their suitability and deliverability if it is to continue to allocate them. National planning policy however would suggest that in view of the uncertainty in relation to their delivery, such sites should not form part of the replacement LDP. make to the housing land supply.
7.1.6 With the Site having no access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints, its delivery if allocated is assured. Combined therefore with its locational characteristics, the Site in question represents a sustainable Alternative Site for future housing development.
7.1.7 In view of the above and information provided in this Statement, it is respectfully requested that the Alternative Site in question be allocated for a modest residential development.

Remove HOM1 allocation PrC2/h22 from the Plan.

We are instructed by Mr D. Gravell to make a formal representation with regards to the
above land and the Second Deposit Draft of the Carmarthenshire Local Development Plan.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/0116/006, seeking the inclusion of their land within the development limits of
Mynyddygarreg as part of the Replacement Local Development Plan.

The Candidate Site comprises an irregular-shaped grazing paddock set off the western flank
of Llangadog Road that runs north to south from the centre of the village of Mynyddygarreg.
The proposals seek inclusion of the well-defined enclosure to provide a modest development
of detached and semi-detached houses to complement established properties which lie
directly alongside the road off the eastern flank of the road. It therefore represented a logical
opportunity for infilling within the settlement and providing a much-need and deliverable
residential opportunity which can generate 11 dwellings. Its extents are illustrated by the site
edged in red, being a site location plan, at Figure 1 below.

The Council published a First Deposit Draft of the Replacement Local Development Plan in
January 2020. At that time, the Council revealed its analysis of each submitted Candidate
Site within a “Site Assessment Table” (January 2020) We noted at that time that our Clients
land was considered as part of this process and as a result the Authority concluded that the
site had successfully passed through all four 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. Accordingly at Stage 4 the Council reported “Site to be allocated within the
revised LDP reference SuV22/h3”
Figure 1 – Location plan of Candidate Site at Mynyddygarreg
As a result of the above Council assessment, Figure 2 presents an extract of the First Deposit LDP Proposals Map for Mynyddygarreg, which clearly identified part of our clients’ land as within the defined development limits and allocated for Residential Development.
Figure 2 – Extract of Proposals Map for Mynyddygarreg with site included within settlement limits as shown by a red arrow

Our clients are therefore astonished to discover that upon publication of the Second Deposit Draft of the LDP, the Council have sought to amend the draft settlement limits, to exclude all the field frontage from within the proposed settlement limits. That new Draft Plan for this southern part of Mynyddygarreg is reproduced as Figure 3 below.
A new Site Assessment Table, dated January 2023, now indicates that the Council conclude that “The site includes High Grade Agricultural Land (Grade 2), whilst there are other opportunities to develop within the village.”
Figure 3 – Second Deposit Draft extract of Mynyddygarreg limits at Llangadog Road

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 draft settlement limits for Mynyddygarreg, 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 Mynyddygarreg, as reproduced below in Figure 4. The land should be appropriately allocated for housing under Policy HOM1 “Housing Allocations.”
Figure 4 – Extent of Representation 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 Overall Housing Supply at Mynyddygarreg and Cluster 2 within Deposit Draft

1.1 The Council consider that there are two reasons for the Candidate Site at Llangadog Road as not being included within the draft Plan as a Residential Allocation. One reason is that they believe that there are sufficient residential sites allocated elsewhere in the settlement. The second reason relates to the grading of agricultural land and that the Council now there years later from assessing and presenting matters in a First Deposit Draft, consider that constructing residential properties Grade 2 Agricultural Land in Mynyddygarreg is unacceptable? We will respond to that reason in the Section 3 of this Representation.

1.2 On this basis, it must be accepted that the form of the Candidate Site set as an infill opportunity between established properties which front the minor road running through this part of Mynyddygarreg, together with the proposals to create new vehicular accesses onto Llangadog Road is deemed acceptable, and in accord with the spatial form and character of the settlement.

1.3 The proposals under this Representation merely seek the addition of 11 residential units to the overall housing supply of Mynyddygarreg, which is regarded as a Tier 3 Sustainable Village, identified within the Llanelli within the draft LDP. Figure 5 below provides an extract of the indicative site layout plan for this Representation site. The proposals can provide a mix of 3 and 4 bed detached and semi-detached dwellinghouses all fronting the Llangadog Road frontage and allowing a safe buffer zone from the rear elevations of the proposed dwellings to an existing Welsh Water sewer apparatus that transverses the field enclosure.
Figure 5 – Proposed Indicative Site Layout Plan for Representation Site

1.4 The Llanelli Cluster (Cluster 2) aims to provide an additional 3039 residential units over the Plan period to 2033, with Mynyddygarreg (Settlement SuV22) providing two allocated sites at expected to provide a combined total of 31 units to that overall Cluster total (reproduced at Figure 6 below). We would submit in the first instance that the addition of an additional allocated site of 11 units will not lead to an over-supply of dwellinghouses within the Cluster, nor the defined Mynyddygarreg settlement supply.
Figure 6 – Extract from Policy HOM1 for Mynyddygarreg

1.5 We have examined and researched sites which have been brought forward as Residential Allocations with the Deposit Draft. In Mynyddygarreg, we consider reference should be made to the current adopted (2014) Local Development Plan to enable a comparison to be made as to the Council’s aspirations for the future growth of housing in that settlement. Great emphasis within the Draft Plan has been placed upon the continued allocation of the Gwenllian Gardens housing site, which was allocated from the 2008-21 Local Development Plan. The above table indicates that
the Council expect that site to be delivered to the market between LDP years 1-5 and 6-10, being 2018 to 2028. Indeed, construction works are at an advance stage on the site and we consider that it is reasonable to continue the allocation of this site.

1.6 However, we note that in the case of the other proposed allocation at “Land adjacent to Ty Newydd, Meinciau Road,” it is a new allocation having appeared as outside settlement limits in the 2014-adopted LDP, as reproduced at Figure 7 below.
Figure 7 - Extract of Current LDP Proposal Map for Mynyddygarreg
and Residential Allocations for Period 2008-21

1.7 The current Development Plan Map for Mynyddygarreg reveals the success of residential allocations in the village. Sites SC17/h1, h2 and h3 have all been completed, and site SC17/h4 is the Gwenllian Gardens site, which as referred to above, is under construction.

1.8 The draft allocation of “Land adjacent to Ty Newydd at Meinciau Road” for 8 dwellings is a new allocation in the Replacement LDP. We note that it was included in the First Consultation Draft in 2020, along with our client’s site at Llangadog Road as new allocations. It is immediately apparent that whilst Meinciau Road has been retained in the Second Draft Plan, our client’s draft allocation at Llangadog Road has been sacrificed. One of the grounds relates to our client’s land being classified as High-Grade Agricultural Land, but we have discovered that the Meinciau Road site is also classified under such a similar designation, and yet it remains in the Second Draft Plan.

1.9 We understand that the Meinciau Road site is under the ownership of Kidwelly Town Council, and yet no explanation has been given as to how that Candidate Site being brought forward by a non-private body is being preferred to a private individual’s Candidate Site which clearly through the absence of any regulatory controls is able to offer his allocated site to the market is a far more streamlined and practical manner.

2.0 Llanelli, Burry Port, Kidwelly and remainder of Cluster 2

2.1 We have examined and researched sites which have been brought forward as Residential Allocations with the Deposit Draft. Mynyddygarreg falls under the Llanelli Cluster which extends along the Burry Estuary coast from Kidwelly in the west to Bynea in the east, and north to Llangennech and Hendy about the M4 corridor.
Great emphasis within the Draft Plan has been placed upon the continued allocation of proposed housing sites still left allocated from the 2014-21 Local Development Plan. Figure 8 below provides an extract of such sites.
Figure 8 – Selection of Deposit Draft Housing Schedule in Llanelli Cluster

2.2 We note that within the Proposals Map for Burry Port, it included for three sites, two of which have been completed at Goodig and Glanmor Terrace leaving just one proposed site, which being the Harbourside site for 364 dwellings. The site has been marketed by the County Council for many years, and despite its coastal position, has failed to receive firm interest and any form of detailed planning application. Ground conditions require extensive remediation of former historic uses.

2.3 The Llanelli suburbs of Llwynhendy / Cefncaeau and Dafen, where four of the above allocations are identified, has not altered since the 2014 adopted LDP and remain undeveloped but re-allocated in the Deposit Draft.
Cwm-y-Nant (PrC2/h22) and Dafen East Gateway (h/23) were both sites allocated within the Carmarthenshire Unitary Development Plan (2006) and as mentioned above, within the Local Development Plan (2014) as sites GA2/h27 and h/30 & h/31.
They have a combined total of 352 dwellings, although neither site has been the subject of any detailed planning application, let alone market interest.
The locality is riddled with historic coal mining activity, with low lying coal seams, together with multiple mine entries across all Dafen sites. Clearly, any residential development upon either site will have to overcome ground remediation to stabilise the ground for residential foundations. The abnormal costs of which are likely to be significant, and hence present the development costs as leading to unviable and undeliverable sites.

2.4 Beech Grove at Pwll (PrC2/h1) has remained allocated for 10 units for the last 10 years in Development Plans. No application for planning permission has even been lodged at the site.

2.5 Cae Linda in Trimsaran (SeC8/h2) for 20 units has been in Development Plans stretching back to the Llanelli Borough Local Plan in 1995. It has only been developed with 5 houses, and thus its continued allocation for twenty more units in the draft LDP must surely come under question?

2.6 Consequently, at least twenty years of Development Plan allocations have elapsed without any signs of wholesale delivery of these sites. Clearly, there is no historic demand for sites of these scales in parts of the Llanelli, Trimsaran and Burry Port / Pembrey areas. All are certainly physically challenging sites, many of which have historic industrial or coal mining legacy issues, which may require significant abnormal costs to achieve developable areas for residential use.
We submit that the above draft allocations be omitted from the Plan, and that housing allocation be redistributed to Alternative Sites, of circa 10 units such as that proposed at Llangadog Road in Mynyddygarreg. There is clear evidence that such modestly sized sites are far more likely to be brought forward and developed in full by regional and local 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.

3.0 Alleged Loss of Grade 2 Agricultural Land

3.1 The Council originally included the Candidate Site at Llangadog Road as a new Residential Allocation in the 2020 First Deposit Draft. They now have concluded that the development of the site should not proceed forward as the land is classified as Grade 2 High Grade Agricultural Land. We have researched such a land classification using Welsh Government’s “Data Map Wales” service, and the map extract for this part of Mynyddygarreg is reproduced below as Figure 9, with the Candidate Site highlighted by a red arrow.
Figure 9 – Data Map Wales Agricultural Land Classification at Llangadog Road

3.2 It is noted that Grade 2 “High Grade” agricultural land is coloured a light blue colour, however, the accuracy of the map base and therefore whole premise of identifying such classifications must be called into question as the Grade 2 tone includes a modern housing site located directly opposite the Candidate Site. That site was previously brownfield land, being the site of the Optical Factory at Mynyddygarreg, and thus never formerly agricultural land of high substance?

3.3 We also note that the classification of land as Grade 2 Agricultural Land has not prevented the Council from allocating land for future residential development in this Replacement and former LDPs. Indeed some of those sites have been developed, one locally by the Council itself, and one now has the benefit of planning permission. Figures 10 and 11 below illustrate three such examples at Pembrey and Hendy.
Figure 10 below illustrates that allocated site SeC5/h1 at Garreglwyd in Pembrey for 14 units has been developed by the Council on Grade 2 Agricultural Land. Planning permission has now been granted at Awel-y-Mynydd at Pembrey (SeC5/h2) for 100 units.
Figure 11 below illustrates that Allocated Site SeC6/h1 at Llwyngwern at Hendy is allocated for 20 units.
Figure 10 – DMW extract for Pembrey and two allocated sites in Grade 2 Land
Figure 10 – DMW extract for Hendy and an allocated and partly completed site is identified upon Grade 2 Land

3.4 We would therefore submit that not only can the Land Classification Map not be relied upon as an accurate guide as to the grade of agricultural land, even if it is broadly accurate, the Council has saw fit to develop its houses upon it, and also grant planning permission to Applicants to develop multiple residential properties thereon, without any apparent agricultural compensation for that activity and construction.
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 a Candidate Site.

Our clients have illustrated that their indicative proposals to construct 11 dwellinghouses will not appear at odds to the prevailing spatial pattern of development in Mynyddygarreg. The proposals will provide a modern frontage development, mirroring modern estate development at the former Optical Factory site, and thus being respectful to the character and setting of the locality.

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

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

Remove site from Plan

We are instructed by Mr B. O. Beynon to make a formal representation with regards to the
above land and the Second Deposit Draft of the Carmarthenshire Local Development Plan.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/074/011, seeking the inclusion of their land within the development limits of Kidwelly as
part of the Replacement Local Development Plan.
The Candidate Site comprises a potential second phase of Housing Allocation SeC3/h4
“Dinas Yard”, being a series of immediately adjoining grazing fields, which shares a common
boundary with that future housing site, also located to the rear of Holloway Farm, and
extends near the rear of established properties fronting Stockwell Lane. Its extents are
illustrated by the site edged in red, being a site location plan, at Figure 1 below.
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 the site was not selected for inclusion within the draft
settlement limits of Kidwelly, 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), and Stage 2A (Initial Detailed Site Assessment). It however did not
proceed further than Stage 2b (Further Detailed Site Assessment) of the Council’s site
assessment. The Council have published reasons for non-inclusion, which are reported as
follows: “It is considered that there would be deliverability issues with this site, particularly
with the permission on the adjacent site which would cater for the needs of the settlement in
the long term.”
Figure 1 – Location plan of Candidate Site at Kidwelly
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 draft settlement limits for Kidwelly, 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 Kidwelly, as reproduced below in Figure 2. The land should be appropriately allocated for housing under Policy HOM1 “Housing Allocations.”
Figure 4 – Extent of Representation 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
- Location and indicative site layout plans
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits

1.0 Overall Housing Supply at Kidwelly within Deposit Draft

1.1 The Council consider that there are sufficient residential sites allocated elsewhere in the settlement, and they believe there would be deliverability issues, with the first phase of the former Dinas Yard site being sufficient to cater for future housing growth at Kidwelly. The Candidate Site borders Site Allocation SeC3/h4 which has the benefit of Approval of Reserved Matters, granted in June 2022, for a total of 71 dwellinghouses. The Candidate Site is seen as a logical second phase of that allocated site, with the proposed access estate road extending east from that development, which initially junctions off Pembrey Road.

1.2 The Council’s Assessment conclusions, suggest that they accept that the form of the Candidate Site set between the Kidwelly By-Pass and former railway line to Stockwell Lane is in accord with the spatial form and character of the settlement.

1.3 The proposals under this Representation seek the addition of circa 80 residential units to the overall housing supply of Kidwelly, which forms a Tier 2 Service Centre, being part of the Llanelli Cluster as defined within the draft LDP. Figure 3 below provides an extract of the indicative site layout plan for this Representation site.
Figure 3 – Indicative Site Layout plan of Representation Site

1.4 The Llanelli Cluster (Cluster 2) aims to provide an additional 3039 residential units
over the Plan period to 2033, with Kidwelly (Settlement SeC3) providing three
allocated sites at expected to provide a combined total of 115 units to that overall
Cluster total (reproduced at Figure 4 below). We would submit in the first instance
that the addition of an additional allocated site of 80 units will not lead to an oversupply
of dwellinghouses within the wider Llanelli Cluster settlement supply.
Figure 4 – Extract from Policy HOM1 for Kidwelly

1.5 We have examined and researched sites which have been brought forward as
Residential Allocations with the Deposit Draft. In Kidwelly, we consider reference
should be made to the current adopted (2014) Local Development Plan to enable a
comparison to be made as to the Council’s aspirations for the future growth of
housing in that settlement. Within the Draft Plan, we note the continued allocation of
Dinas Yard and land part of Holloway Farm, which was allocated from the 2008-21 Local Development Plan. The above table indicates that the Council expect that site to be delivered to the market between LDP Years 6-10, being 2024 to 2028. Indeed, construction works will be commencing in Summer 2023 following the granting of Approval of Reserved Matters for 71 dwellinghouses.

1.6 However, we note that in the case of the other proposed allocation at “Llys Felin,” work is complete upon a first phase of 9 bungalows, with a further 15 units currently subject of a planning application. Site Allocation SeC3/h2 at “Land off Priory Street” is a new allocation for 20 units, having appeared as outside settlement limits in the 2014-adopted LDP, as reproduced at Figure 5 below.
Figure 5 - Extract of 2014-adopted LDP Proposal Map for Kidwelly

1.7 The current Development Plan Map for Kidwelly reveals the success of residential allocations in the town. Sites T3/3/h2, h6, h7 and h8 have all been completed or nearing completion, and site T3/3/h9 and h10 has Approval of Reserved Matters with a commencement imminent. Sites T3/3/h3, h4 and h5 do not have the benefit of planning permission, and it is noted have been omitted from the new Second Deposit Draft accordingly.

2.0 Llanelli, Burry Port, Hendy and remainder of Cluster 2

2.1 We have examined and researched sites which have been brought forward as Residential Allocations with the Deposit Draft. Kidwelly falls under the Llanelli Cluster which extends along the Burry Estuary coast from Kidwelly in the west to Bynea in the east, and north to Llangennech and Hendy about the M4 corridor.
Great emphasis within the Draft Plan has been placed upon the continued allocation of proposed housing sites still left allocated from the 2014-21 Local Development Plan. Figure 6 below provides an extract of such sites.
Figure 6 – Selection of Deposit Draft Housing Schedule in Llanelli Cluster

2.2 We note that within the Proposals Map for Burry Port, it included for three sites, two of which have been completed at Goodig and Glanmor Terrace leaving just one proposed site, which being the Harbourside site for 364 dwellings. The site has been marketed by the County Council for many years, and despite its coastal position, has failed to receive firm interest and any form of detailed planning application. Ground conditions require extensive remediation of former historic uses.

2.3 The Llanelli suburbs of Llwynhendy / Cefncaeau and Dafen, where four of the above allocations are identified, has not altered since the 2014 adopted LDP and remain undeveloped but re-allocated in the Deposit Draft.
Cwm-y-Nant (PrC2/h22) and Dafen East Gateway (h/23) were both sites allocated within the Carmarthenshire Unitary Development Plan (2006) and as mentioned
above, within the Local Development Plan (2014) as sites GA2/h27 and h/30 & h/31. They have a combined total of 352 dwellings, although neither site has been the subject of any detailed planning application, let alone market interest.
The locality is riddled with historic coal mining activity, with low lying coal seams, together with multiple mine entries across all Dafen sites. Any residential development upon either site will have to overcome ground remediation to stabilise the ground for residential foundations. The abnormal costs of which are likely to be significant, and hence present the development costs as leading to unviable and undeliverable sites.

2.4 Beech Grove at Pwll (PrC2/h1) has remained allocated for 10 units for the last 10 years in Development Plans. No application for planning permission has even been lodged at the site.

2.5 Cae Linda in Trimsaran (SeC8/h2) for 45 units has been in Development Plans stretching back to the Llanelli Borough Local Plan in 1995. It has only been developed with 5 houses, and thus its continued allocation for forty more units in the draft LDP must surely come under question?

2.6 Consequently, at least twenty years of Development Plan allocations have elapsed without any signs of wholesale delivery of these sites. There is no historic demand for sites of these scales in parts of the Llanelli, Trimsaran and Burry Port / Pembrey areas. All are certainly physically challenging sites, many of which have historic industrial or coal mining legacy issues, which may require significant abnormal costs to achieve developable areas for residential use.
We submit that the above draft allocations be omitted from the Plan, and that housing allocation be redistributed to Alternative Sites, of circa 80 units such as that proposed at Holloway Farm in Kidwelly. There is clear evidence that such moderately sized sites are far more likely to be brought forward and developed in full by regional and local 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.

3.0 CONCLUSION

3.1 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 a Candidate Site.
Our clients have illustrated that their indicative proposals to construct circa 80 dwellinghouses will not appear at odds to the prevailing spatial pattern of development in Kidwelly. The locality has numerous examples of modern cul-de-sac development being completed at backland locations, which in turn, advocates that the form of development proposed at Holloway Farm is no different, resulting in it being respectful to the character and setting of the locality.

3.2 The Council must acknowledge that the costs in preparing, submitting and negotiating through to a positive decision for Approval Of Reserved Matters
demonstrates our client’s commitment to deliver housing allocations. The site will shortly be under construction with a regional housebuilder with a view to completion within two years, and thus the proposed Phase 2 will enable house building to continue into the latter years of the Replacement LDP Plan Period.
We respectfully request that this Representation be given careful examination, and consequently the defined settlement limits of this part of Kidwelly realigned to include the Representation Site, as a Residential Allocation in the Proposals Map of the adopted Local Development Plan.