SeC8/h2

Remove the site from the 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 Cae
Linda (LDP Ref. No. SeC8/h2) 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 45 residential units.

Plan A
(Extract of Proposals Map for Cae Linda 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 SeC8/h2 was considered as part of this process and as a result the Council concluded as follows:
“Site Allocation to be reduced in size. Parts of the site has planning permission. Site to be allocated with reference SeC8/h2.”

It is clear from the above that the Council considers that the site is deliverable for the purposes of 45 houses, although it is unclear on what basis this conclusion has been made. No justification is put forward as to how a figure of 45 units is arrived at?
The allocation is greenfield in nature with its topography sloping from south to the north. The southern and eastern perimeters of the site are bordered by residential properties. The northern and western boundaries are then bordered by open green space and mature vegetation and hedgerow 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 gained off Cae Linda, that being a residential street as cam be seen below.

Photograph 2
(Streetscene of Cae Linda)

Outline Planning Permission was granted in September 2020 for the Residential Development (S/37639). An approval of Reserved Matters was them granted for Approval of Reserved Matters on S/37639 (Phase 1 – 12 x 5 bedroom dwellings, 2 x 2 bedroom dwellings) in May 2022. However, this application only amounts for 14 dwellings on a site allocated for 45 dwellings.
The site is allocated in the Carmarthenshire Local Development Plan (2014) under allocation T3/4/h6 as well as the Carmarthenshire Unitary Development Plan (2006) under allocation T9/c (as can be seen below).

Plan B
(Extract of Current Carmarthenshire LDP Proposal Map for Allocation Site (Adopted 2014))

Plan C
(Extract of Carmarthenshire UDP Proposal Map for Allocation Site (Adopted 2006))

Despite having almost 20 years of support for the principle of residential development at the historic allocation from the Council, only 5 housing units have been delivered to date. It is submitted that the allocation to be removed given that the site is within settlement limits, but the rate of build at the site would not be in line with that of the plan period.

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 SeC8/h2 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 housing allocation SeC8/h2 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 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.

No change to the Plan

Dear Sir/Madam,

I write to confirm the statutory safeguarding position of the Ministry of Defence (MOD) in relation to the 2nd Deposit Revised Carmarthenshire Local Development Plan (LDP) 2018 – 2033. The 2nd Deposit Revised LDP sets out the land use policies and proposals including the allocation and use of land through to 2033.

The Defence Infrastructure Organisation (DIO) Safeguarding Team represents the MOD as a statutory consultee in the UK planning system to ensure designated zones around key operational defence sites such as aerodromes, explosives storage sites, air weapon ranges, and technical sites are not adversely affected by development outside the MOD estate. For clarity, this response relates to MOD Safeguarding concerns only and should be read in conjunction with any other submissions that might be provided by other parts of the MOD.

Future Wales, the National Plan 2040 makes clear that military sites and assets in Wales are important to the UK strategic defence systems and emphasises that these sites and assets should be protected from the impacts of development. MOD may be involved in the planning system both as a statutory and non-statutory consultee. Statutory consultation occurs as a result of the provisions of the Town and Country Planning (Safeguarded aerodromes, technical sites and military explosives storage areas) Direction 2002 (DfT/ODPM Circular 01/2003) and the location data and criteria set out on safeguarding
maps issued by Department for Levelling Up, Housing and Communities (DLUHC) in accordance with the provisions of that Direction.

The area covered by any 2nd Deposit Revised Carmarthenshire Local Development Plan (LDP) 2018 – 2033 will both contain and be washed over by statutory safeguarding zones that are designated to preserve the operation and capability of defence assets and sites including RAF Pembrey Sands, MOD Pendine, and the Mid Wales Tactical Training Area
Copies of these plans, in both GIS shapefile and .pdf format, can be provided on request through the email address above.
On reviewing the potential allocation sites, the following site references fall within statutory safeguarding zones designated to protect the operational capabilities of defence sites and assets:

Housing Allocations
SAFEGUARDING ZONE(S) AFFECTED
Kidwelly
RAF Pembrey Sands (Range safeguarding zone)
Pembrey
RAF Pembrey Sands (Range safeguarding zone)
Trimsaran Ffos Las
RAF Pembrey Sands (Range safeguarding zone)
Llangadog
RAF Pembrey Sands (Range safeguarding zone)

To provide an illustration of the various issues that might be fundamental to MOD assessment carried out in response to statutory consultation, a brief summary of each of the safeguarding zone types is provided below. Depending on the statutory safeguarding zone within which a site allocation or proposed development falls, different considerations will apply.

• Air Weapon Range Safeguarding Zones serve to regulate developments that could introduce or support populations of large and, or, flocking birds hazardous to aircraft. This can include landscaping schemes associated with large developments as well as the creation of new waterbodies, wetlands and Sustainable Drainage Systems (SUDS). The incorporation of open water, both permanent and temporary, wetlands ponds and ditches provide a range of habitats for wildlife, including potentially increasing the creation of attractant environments for large and flocking bird species hazardous to aviation. In addition, these zones serve to monitor the development of new micro-light/leisure flying sites in the vicinity of air weapon ranges.

• Technical safeguarding zones serve to ensure that air traffic management, primarily radar, navigation, and communications systems are safeguarded to limit the impact of development on their capability and operation. The height, massing and materials used to finish a development may all be factors in assessing the impact of a given scheme. Developments that incorporate renewable energy systems may be of particular concern given their potential to provide large expanses of metal at height, for example in the case of a wind turbine or a solar PV system mounted on a roof

• Statutory safeguarding zones are designated around Military explosives storage sites, to ensure that development and land uses will be compatible with MOD capability. Within these zones, where applicable, requirements relating to the siting, design, and construction of buildings, or changes to land use may apply. In principle, the MOD does not object to land in the outer explosives safeguarding zone being developed for residential, commercial, and industrial land use purposes. Any buildings within this zone must be ‘non-vulnerable’ to blast effects, that is of robust construction, so should an explosive event occur, the structure would not collapse or sustain damage that could cause critical injury to the occupants. Of particular concern within this zone are tall buildings (in excess of 3 storeys), light weight construction and large areas of glazing. The MOD will object to development proposals which support people living, working and congregating within the inner explosives safeguarding zone.

• A significant portion of the 2nd Deposit Revised Carmarthenshire LDP 2018 – 2033 area is within a part of the UK Military Low Flying System, designated as Training Area 7T (Mid-Wales). Within the Tactical Training Area (TTA), fixed wing aircraft may operate as low as 100 feet or 30.5 metres Above Ground Level (AGL) to conduct low level flight training. The introduction of development within the TTA has the potential to introduce a physical obstruction to low flying aircraft operating in the area. As such the MOD would wish to be consulted on any development within the TTA which has a height of/or exceeding 15.2M AGL.

Mineral extraction has the potential to have a significant impact on defence capability and operations, through all stages of the extraction, restoration, and aftercare process. These types of developments have the potential to provide attractive environments to certain large and/or flocking bird species hazardous to aviation safety and therefore may be subject to design requirements or for management plans to be applied. Development types that might require the application of planning condition(s) and/or the use of Planning Obligations to secure legal frameworks for the way development is carried out or managed can include mineral extraction schemes, waste development schemes or proposals associated with waste facilities including any restoration of sites. The MOD requests that the plan highlights that the MOD must be consulted on any mineral extraction, waste or landfill scheme which occupies a statutory range safeguarding zone.

The MOD welcomes the provisions of policies CCC1 and CCH2 regarding renewable energy, which makes clear that renewable and low carbon projects will not be acceptable where they would have an unacceptable impact on the operations of defence facilities and operations (including aviation and radar) or the Mid Wales Low Flying Tactical Training Area (TTA-7T).
In addition, and where development falls outside designated safeguarding zones, the MOD may also have an interest, particularly where the development is of a type likely to have an impact on operational capability by virtue of scale, height, or physical properties. The MOD should be consulted, through DIO Safeguarding, where development exceeds a height of 50m above ground level to ensure that the potential for these structures to form a physical obstacle to low flying aircraft can be addressed through appropriate lighting and charting. In addition, the MOD requests to be consulted on any proposals, regardless of height, which fall outside of an MOD safeguarding zone but are in the vicinity of military training estate or property.

The MOD Safeguarding team note that the council will prepare Supplementary Planning Guidance for the Pembrey Peninsula and would ask that we are consulted during the preparation of any SPG.
I trust this clearly explains our position on this update. Please do not hesitate to contact me should you wish to consider these points further.