PrC3/h4

Remove housing allocation PrC3/h4 from the Revised LDP.

Please refer to our ‘Candidate Site – Supporting Statement’

Increase size of allocation and number of units to reflect extant outline consent.

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

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

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

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

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

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

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

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

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

Remove site from the Plan

1. Introduction

This document is provided in support of our submission that seeks the allocation of land in
our ownership for residential development in the new, Revised Local Development Plan
(Revised LDP).
The detailed appraisal that has been prepared in accordance with our understanding of the
relevant national and local planning policies and guidance seeks to demonstrate that the
subject land meets all of the relevant criteria for inclusion as an allocated site within the new
Revised LDP.

2. Planning Policy and Guidance
The national land use policies for Wales are set out in the Welsh Government publication
Planning Policy Wales, Edition 11 (PPW) that principally requires that planning policies,
proposals and decisions must promote sustainable development and support the well-being
of people within their communities. New development has to be sustainable and improve the
social, economic, environmental and cultural well-being of Wales.
PPW, that is supported by a series of focussed, topic based Technical Advice Notes (TANs)
and other key legislation such as the Planning (Wales) Act 2015, and the Well-being of
Future Generations (Wales) Act 2015, conveys that ‘Local Development Plans should set
out a vision for how places are expected to change in land-use terms to accommodate
development needs over the plan period’; that ‘Everyone engaged with or operating within
the planning system in Wales must embrace the concept of placemaking in both plan making
and development management decisions in order to achieve the creation of sustainable
places and improve the well-being of communities’ and that ‘The planning system should
create sustainable places which are attractive, sociable, accessible, active, secure,
welcoming, healthy and friendly. Development proposals should create the conditions to
bring people together, making them want to live, work and play in areas with a sense of
place and well-being, creating prosperity for all.’

Detailed guidance with regard to the preparation of development plans is provided in the
Development Plans Manual, Edition 3, (DPM) March 2020. The DPM identifies the key
requirements in the consideration of a candidate site. These are set out as the candidate site
must:
 be at a sustainable location;
 be readily available;
 be free from physical constraints such as access, ground condition; biodiversity or
flooding issues
 whether the site has any relevant planning history; and,
 if there are any barriers to the delivery of the site the candidature must include a
detailed summary as to how the barriers shall be overcome.
Locally, the current Carmarthenshire Local Development Plan (LDP), adopted in December
2014, advocates a hierarchical approach to new residential development, namely, Growth
Areas, Service Centres, Local Service Centres and Sustainable Communities.
The principal status of the Growth Area settlements reflects their high population levels and
that these settlements are well served by the necessary facilities, services and public
transport provision extending beyond their localised catchments that are vital to supporting
the principles of sustainability and are capable of accommodating a proportionally high level
of growth.
The LDP identifies three Growth Areas centred on the principal towns of Carmarthen, Llanelli
and Ammanford respectively. The Ammanford/Cross Hands Growth Area, referenced GA3
within the LDP, is described as performing a key role within the area due to its strategic
location on the M4 corridor and at its role at the hub of the Amman and Gwendraeth Valleys.
The Ammanford/Cross Hands Growth Area is the second largest settlement in population
terms within the LDP.
The LDP conveys that the topographical characteristic of GA3, comprising of two centres,
Ammanford and Cross Hands, along with a number of interrelated, smaller settlements of
varying scale and function, has a direct bearing on the suitability for growth with a balanced
decision having to be taken on the ability of any particular settlement to accommodate new
growth, without resulting in harm to the character of the area or community.

LDP polices AH1 – AH3 detail the need for new residential development to contribute
towards affordable housing in the locality. New developments comprising 5 or more
dwellings are required to provide an on-site accommodation, while smaller developments
require a relevant financial contribution towards the provision of affordable housing in the
area.
The Council’s intention to locate new development primarily within the identified growth
areas reflects the national land use planning aim for sustainable development in well
serviced areas to improve the well-being of the local population.
The Second Deposit Revised LDP, while continuing to identify a settlement hierarchy offers
a new spatial strategy, with a strategic approach aimed at locating new development at
locations that are both deliverable and sustainable. The Revised LDP again identifies key
strategic growth areas focused on six key areas or ‘defined clusters’, three of which are
again centred at Carmarthen, Llanelli and Ammanford/Cross Hands.
The continued approach in the Revised LDP again clearly reflects the national theme of
‘place making’ embedded within PPW that new residential development should seek to
sustain and enhance existing communities. This guiding principal shall ensure that the future
growth of communities shall result in built and natural environments where people can
sustainably live, work and spend their leisure time.
Proposed Strategic Policy SP3 aims to secure that key place-making responsibility through
the provision of new homes at sustainable locations through the allocation of sites at
established settlements in a hierarchical framework of Principal Centres, Service Centres,
Sustainable Villages and Rural Villages.
Strategic Policy SP4 further conveys the Plan’s strategic aim of providing new homes in a
sustainable manner through the allocation of sites in established settlements; supporting
windfall residential development on appropriate sites within settlements; and the provision of
appropriate affordable housing opportunities to meet an identified local need.
Proposed policy AHOM1 maintains the Council’s commitment to the provision of affordable
housing as part of any new residential development.

3. Candidate Site

3.1 Location and Description
Our candidate site is located along the western flank of Parklands Road, Penybanc,
Ammanford as shown on the location plan below.
The site is located a short walk (250 metres) from the social, retail, commercial and
recreational facilities of the community located in close proximity to the junction of Parklands
Road with Penybanc Road (A483). The site is also within walking distance of Parcyrhun
Primary School, Amman Valley Comprehensive School, higher education at Coleg Sir Gar,
Ammanford Campus and the local train (Swansea – Shrewsbury) station (1240 metres).
Bus-stops at the A483 junction provide a regular, every 30 minutes, service to Ammanford,
Llandeilo and Swansea. Similarly, bus stops at the junction of Parklands Road with Dyffryn
Road (at the telephone kiosk symbol on the plan), again within convenient walking distance
(410 metres) provide regular services to Ammanford, Carmarthen, Cross Hands and the
communities of the Gwendreath Valley.
Directly opposite the south-eastern corner of the site is a public footpath (51/21) that
provides for a pleasant, woodland walk to Ammanford.
The convenient public transport, walking and cycling connectivity to Ammanford and the
wider area significantly increases the range of services, amenities and facilities readily
available for Penybanc residents.

The candidate site is situated alongside the bungalow, number 26, to the south with the
remainder of the enclosure up to our agricultural field access immediately adjacent to the
house number 54 to the north, with a mix of houses (35 – 39) and bungalows (33) opposite.
The land that is laid to grass slopes gently downward from north to south with the road
frontage and southern boundaries clearly delineated by stock proof fencing.

3.2 Context
Penybanc principally extends in a linear form along both the A483 Penybanc Road and
Parklands Road with an established group of housing directly opposite the candidate site at
Newtown, Newtown Close, Waunfawr and Park Mill Road.
As indicated in red on the Revised LDP extract plan below, our candidate site is bounded to
the south and opposite by the residential development limits as delineated in both the
current LDP and the proposed Revised LDP
The site lies outside of the area within which a financial contribution would be required
towards funding the implementation of specific marsh fritillary butterfly habitat management
initiatives, the boundary of which is indicated by the dashed purple line in the plan above.
With established residential development to the north, south and east, the candidate site
represents a logical location for partly infill, residential development.

3.3 Planning History
During the 1960s and 1970s a substantial acoustic bund associated with the historic
opencast mining of the area existed along the entirety of the candidate site and the
remainder of the adjoining road frontage. That bund resulted in a significant sense of
enclosure along the street scene.
Full planning permission (P6/13142/87) was granted in July 1987 for a bungalow and garage
at a nearby plot along the road frontage land in our ownership. An extract of the approved
block and location plan is provided below.

3.4 Residential Development Proposal
We anticipate that the site would be developed in a linear arrangement of two bungalows or
dormer bungalows, served by a paired private drive, that would positively respond to both
the site and the surroundings. To ensure that the new development is sympathetic to the
character of the existing housing, the alignment and design shall reflect the form of the
existing nearby properties.

The proposed development shall provide for south/south west facing gardens that shall seek
to maximise the potential for solar energy and contribute positively to the well-being of the
future occupants in that the dwellings shall have private outdoor amenity areas that shall be
available for the maximum periods of time throughout the year.
Although unclassified, Parklands Road where it fronts the site has a carriageway width of
7m, with a grassed verge and 1.7 m wide footway along the site frontage. At the opposite
side of the carriageway the footway fronting the existing bungalows is 1.9 m in width.
The alignment of the highway, together with the wide footway along the site frontage, shall
duly facilitate the required visibility splay for each new vehicular access.
We understand that given the very limited scale of the proposal along with the proximity to
existing facilities there shall be no requirement for an area of on-site, formal open
recreational space. To meet the Council’s requirements in terms of affordable housing we
also understand that the Revised LDP requires the relevant financial contribution towards
affordable housing shall have to be provided, that would be secured by planning obligation.
While the schematic layout proposes what is considered to be a sympathetic form and
density of development, we acknowledge that the final number, design and layout shall be
established through the submission of a full planning application.

3.5 Infrastructure
The candidate site is at a location well served by mains water, gas, electricity, public
sewerage and fast fibre broadband to the home.
Having due regard to disposal of surface water, with the adjoining land being in our
ownership there are a number of options available to facilitate the provision of a sustainable
urban drainage system.

3.6 Ecology
As evident in the photographs provided at 3.1 Location and Description above, the candidate
site is actively used and managed for the purposes of agriculture. The site is part of a larger
enclosure of improved grassland, subject to the usual nutrient practices with the road
frontage defined by a timber post and rail fence.
Other than a very small part in the south-eastern corner being designated grade 3b,
‘moderate quality agricultural land’, the majority of the land is grade 5, ‘very poor quality
agricultural land’.
The candidate site does not form part of any local or national nature conservation
designation, with the nearest Sites of Special Scientific Interest (SSSI), being the group of
fields known as Caeau Blaenau Mawr and Caeau Capel Hendre located 2km to the west.
Having due regard to the above, it is considered that the site has a very low biodiversity
value and that the residential development of the site shall have no detrimental impact upon
any SSSI.

3.7 Environmental Considerations
The candidate site is not located within an area where residential development would cause
concern with regard to river phosphate levels or within any of the categorised flood risk
areas detailed in the Development Advice Maps published by National Resources Wales.
The residential development of the land shall therefore not be at any risk of flooding.
Being in agricultural use the greenfield land has no ground contamination issues.

3.8 Historical Assets
There are no listed buildings or scheduled ancient monuments within or adjoining the
candidate site. Similarly, there are no listed buildings within the community of Penybanc or a
designated conservation area within either Penybanc or Ammanford. The residential
development of the candidate site shall therefore not have any detrimental impact on any
historical asset or the setting of any such asset.

4. Viability and Deliverability

4.1 Financial Viability
National planning policy requires that all land use allocations are both financially viable and
deliverable to ensure that plan making and decision making viability strikes a balance
between the aspirations of developers and landowners, in terms of returns against risk, and
the aims of the planning system to secure maximum benefits in the public interest through
the granting of planning permission.
Though a detailed analysis of the financial viability is difficult at this initial stage due to the
absence of such things as a comprehensive site survey and full engineering details, the
following high level appraisals with due regard to both the current LDP and Revised LDP
have been undertaken. The submitted data has been informed by discussion with
established agents and professionals to ensure that the figures accurately reflect the local
market benchmark land and property values at the present time.
The costs are based upon:
 Three bedroom dwelling – 130m2
 New three bedroom dwelling - £280,000
 Construction cost of £1,500 per square metre
 Utility Connections to include water, electric, gas and foul water
 Professional Fees (including Design, Planning, Building Regulations, Estate
Agents, SAB & LABC warranty) at 8% of the construction fee
 Developer’s profit based upon the RICS guideline of 15%

Two Dwellings with the relevant Affordable Housing financial contribution
Costs No of dwellings Cost per dwelling/m2 Total
3 bed dwellings 2 1500 390,000
Affordable Housing - 41.98 10,915
Utility Connections 5000 10,000
Professional Fees - 31,200
Total 442,115
Sales No of dwellings Value Total
3 bed dwellings 2 280,000 560,000
Total 560,000
Developer’s profit 84,000
Residual Land Value 33,885
The in-principle appraisal above demonstrates that the residential development of our
candidate site would be financially viable, while also capable of providing the relevant
contribution towards affordable housing in the community.

4.2 Deliverability
With the proposed residential development being financially viable, there are no ownership
or physical constraints to prevent the delivery of the candidate site.
The site would, on adoption of the Revised LDP, be immediately available for development
with its delivery, including the community affordable housing benefit, anticipated to be
completed in the short term, within the first 5 years following adoption of the Plan.

5. Comment on the Previous Concerns of the Council
Although the Council previously (SR/004/009) considered the whole of the road frontage
candidate site to be acceptable in terms of the location of future growth presented in its
preferred strategy, both the initial and detailed site assessment, sustainability appraisal and
habitat regulation assessment, the site was not recommended to be taken forward at that
time due to two concerns, namely that it was considered that there is more suitable land
available for residential development and that the development of the site would be likely to
result in ribbon development.

5.1 ‘More suitable land available’
It is reasonably assumed that the land referred to is that at Tirychen Farm, Dyffryn Road,
Ammanford, Revised LDP reference PrC3/h4, an allocation rolled over from the previous
development plan, where Outline planning permission (P6/16576/89) in respect of the
residential development of the land was initially granted in April 1990, having expired three
years later.
Full planning permission (P6/305/95) was granted for 141 houses and bungalows in
February 2008 that expired in February 2013.
Outline planning permission (E/21663) was granted in October 2014, renewed by means of
the Variation of Condition consent (E/38686) approved October 2019. It would seem that this
most recent permission that proposed 289 dwellings expired in October 2021 and as such
there is no current planning permission for the development of that land.
Aside from the key question whether there is a valid consent in place, the deliverability of the
site allocated for 250 dwellings in the LDP and 150 dwellings in the Revised LDP is
extremely doubtful.

Each permission that has been granted at the former Tirychen Farm has been subject to
numerous conditions and a planning obligation. The number and requirement of the
conditions such as significant highway improvements including a new bus layby, along with
the financial and physical requirements of the planning obligation (affordable housing,
cemetery car park extension, six-figure highways and education contributions, detailed
woodland management scheme) render the development beyond the realm of local building
contractors while the national, volume housebuilders have not shown any interest in the site
during the 33 years since permission was first granted, instead focussing their attention on
the M4/A48 corridor, more specifically at sites in and around Cross Hands.
An online search reveals that the land at Tirychen is not presently being marketed which
would indicate that the site was merely being land-banked.
The Council has expressed its own concern with regard to the deliverability of the allocation
in the report to Full Council in January 2018 that adopted a traffic light system in respect of
the viability and deliverability of the proposed residential land allocations within the Revised
LDP. The land at Tirychen Farm was categorised as red, ‘no indication of progress towards
delivery’.
In the absence of a valid planning permission, it would seem extremely questionable
whether a new submission at what is a large scale, rural, natural landscape would be
considered acceptable in the context of the current biodiversity objectives.
The potential delivery of the land at Tirychen, that would appear to require a new planning
permission, is markedly uncertain.

5.2 ‘The development of the candidate site would be likely to result in ribbon
development’
In the absence of any specific reasoning why the allocation of our land would be ‘likely’ to
[not ‘shall’] result in ribbon development, we understand that ribbon development is usually
deemed to be unacceptable as such linear development along highways can result in urban
sprawl or an unacceptable intrusion into the countryside; the inefficient use of resources;
hinder access to and/or the development/use of the land to the rear; and/or result in the
coalescence of settlements.

To address each in turn, our proposed site lies within a well-established area of housing with
the most recent residential development within Penybanc being the bungalows at Waunfawr
and the houses at Newtown Close opposite the candidate site. As such, the residential
development of the land shall not result in an urban sprawl or an unacceptable intrusion into
the open countryside and would be more appropriately characterised as partly infilling an
area within the established built fabric of the community.
The site is well served by the necessary services infrastructure and as such shall not
therefore result in the inefficient use of resources.
Residential development of the site shall not hinder or impede in any way the continued
access to the land to the rear that is served by an existing access to the north of the site and
also from the rear of our home to the south.
Being located within an established residential area the site shall not result in the
coalescence of any neighbouring settlements.
The reduction of the candidate site from that submitted in 2014 (SR/004/009) to comprise
only part of the road frontage shall serve to safeguard against any concern the Council may
have with regard to the loss of part of an area of a natural landscape within the local built
environment. Furthermore, the woodland adjacent to 54 Parklands Road to the north, that
fronts Parcwern Care Home and is only 100 metres from the candidate site, is the subject of
a Tree Preservation Order (CCC TPO E20). That TPO shall ensure that a formally secured,
natural interruption to the street scene is permanently maintained.
The extract from the CCC TPO plan below illustrates the proximity of the candidate site to
the woodland TPO E20.

It is also noted that no concerns with regard to any unacceptable loss of a natural landscape
feature, sporadic or ribbon development were deemed relevant in the grant of planning
permission P6/13142/87 referred to above.
Having due regard to our aforesaid reasoning, it is considered that the residential
development of the site shall not result in ribbon development.

6. Conclusion
Our candidate site, that has housing on two sides and nearby on a third, has all of the mains
services including fast fibre broadband readily available. The site therefore represents a
logical form of part infill development at a sustainable location, being only a short walking
distance to the community social, retail, commercial, and recreational facilities and also to
public transport that regularly links Penybanc with the neighbouring hub of Ammanford and
the wider area, further increasing the range of services and facilities available to future
occupants.
The land that has in part previously benefited from the grant of a residential planning
permission is free from any constraint in terms of access, biodiversity, ground condition or
flooding.
In terms of its sustainability credentials, the simple, efficient layout of the development shall
require minimal access construction; prioritise the solar orientation of houses and gardens;
provide for a sustainable urban drainage system with features such as permeable surfaces
where possible, together with a landscaping scheme that would significantly improve and
enhance the existing biodiversity through the planting of indigenous species. The location of
the site encourages sustainable transport use through convenient, close access to the local
bus and train service along with direct access opposite the site to an attractive public
footpath that affords easy walking connectivity to the town of Ammanford, and also to the
established local cycle path network.
With significant doubt around the deliverability of the only, longstanding allocation in the
locality our candidate site would be immediately available, with no uncertainty in terms of its
viability or deliverability. Although very modest in scale, the allocation of our site for
residential development would represent both a sound option to address the likely deficit in
provision and offer a positive contribution to the housing growth strategy of the area.
We respectfully contend that the robust information provided in this appraisal demonstrates
that the designation of the land for residential development would be consistent with the key
objectives of both national and local guidance and policy objectives in that the candidate site
is at a sustainable location, viable, readily available and free from any physical or
environmental constraints

Remove site from Plan

Further to the publication of the above document, we have been instructed 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 (LDP) in relation to the allocation for residential development of Tirychen
Farm, Penybanc (LDP Ref. No. PrC3/h4) 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 150 residential units.

Plan A
(Extract of Proposals Map for Penybanc and Tirychen 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 PrC3/h4 was considered as part of this process and as a result the Council concluded as follows:
Site to be retained as a residential allocation for a lower number of dwellings with the remainder of the site being delivered beyond the Revised LDP's lifetime. Site reference is PrC3/h4.
It is clear from the above therefore that the Council considers that the site is deliverable for the purposes of 150 houses, although it is not clear on what basis this conclusion has been made.
It should be noted that the site was also allocated in the Carmarthenshire Unitary Development Plan (2006), with an extract from the UDP’s Proposals Map showing the allocation in question shown below.

Plan B
(Extract of UDP Proposals Map for Allocation Site)

The allocation itself is greenfield in nature with an undulating topography. It consists of a series of enclosures, many of which contain mature vegetation, trees and hedgerows, as can be seen from the aerial photograph below (allocation circled red).

Photograph 1
(Extract from Google Earth – June 2021)

Access to the site is currently gained from Newtown Close, a narrow road, served by a single or no footway for its extent (see below).

Photograph 2
(streetscene of Newtown Road)

Full planning permission was first granted for residential development on the allocation as far back as 1992 (Application D6/19332), which subsequently lapsed. The site continued to be allocated however for the purposes of residential development within the Dinefwr Local Plan (1996), the subsequent Carmarthenshire Unitary Development Plan (2003) and finally the Carmarthenshire Local Development Plan (2014).
A number of outline planning permissions have been granted since the 1992 permission lapsed, but following a recent refusal of planning permission under Application PL/00919 (based on insufficient information to demonstrate no detrimental impact on biodiversity interests on the site), the allocation currently does not benefit from a ‘live’ planning permission. Despite therefore over 30 years of support for the principle of residential development at the site from the Council, not a single housing unit has been delivered to date.

Tests of Soundness
Based on the above information and the guidance documents produce 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, particularly in light of recent contrasting refusals for residential development relating to the impact of such development on biodiversity interests on the site.

Test 3 – Will the Plan deliver?
The allocation fails the test of soundness as the site is clearly unable to deliver any new housing. The 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 a substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered.”. no evidence has been presented to demonstrate a change in circumstances to indicate the allocation will now be delivered.
In addition to biodiversity interest constraints, we understand from speaking with interested developers and housing associations who have expressed interest in the site that the landowners land value aspirations resulting in any development of the site being financially unsustainable. This is qualified by the lack of development on the site for over 30 years. The Council has failed to provide any evidence to the contrary.

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 housing allocation PrC3/h4.

I would like to include site (SR/004/004) for consideration within the LDP.
About the site:
- The site is located on Penybanc Road, with direct access. The access road would fit in with current highway safety.
- Should planning permission be granted for the site I wish to immediately start the process of building for affordable housing.
- The site does not support habitats for any protected species or wildlife.
- The site is close to many public transport links and amenities. (1.3 miles to Ammanford bus station, 1.3 miles Ammanford train station, Bus stops along Penybanc Road)
- Recently built adjacent sites will allow easy access to sewerage, mains water and power lines.
- The site does not overlook any adjacent property or buildings.
- I would like all buildings on the site to be sustainable eco housing.

Please see attached images below showing the site and confirmation of ownership.

I have further concerns in regards to site PrC3/h4. This site first obtained outline in 2009 (ref E/21663). However, in 12 years no progression of work or development can be seen. The site is located within a 1 mile of my proposed site. The size of site PrC3/h4 is far greater than my own. Therefore I could argue that the ongoing impact both to the local residents and environment would be much larger should this site be approved and not my own. As I have stated above I’d want the development works on my site to begin as soon as possible should the permission be granted. Site PrC3/h4 has had this opportunity for over a decade and no action has been taken. This is an opportunity wasted, however this would not be the case on my site.

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

Change to Plan if necessary

Thank you for consulting Cyfoeth Naturiol Cymru/National Resources Wales (NRW) on the above, which was received on 17 February 2023.

We welcome the opportunity to provide comments on your Second Deposit Revised
LDP.

We support the intent of the plan’s policies and proposals to enable the delivery of sustainable development and ensure social, economic, environmental and cultural
well-being goals are all suitably balanced in the decision-making process, so the right development occurs in the right place.

We also acknowledge that you have taken on board advice from our previous correspondence which has enabled positive provisions in the second Deposit Plan
both in policy terms and regarding allocation of sites. However, there are issues with the latest draft which we feel challenge the Soundness of the Plan. These key
issues are highlighted below:
• SAC rivers / Habitats Regulations Assessment (HRA)
• Flood risk regarding the following sites allocated for housing under Strategic Policy 4: A Sustainable Approach to Providing New Homes
PrC3/h33 Llys Dolgader
PrC3/h19 Land off Llys y Nant
SeC19/h1 Land at Park View, Whitland
Sec19/h2 Land at Whitland Creamery
• Flood risk regarding allocation - PrC2/GT1 – Land at Penyfan, Trostre, Llanelli, under Strategic Policy SP 10: Gypsy and Traveller provision.
• Biodiversity and ecosystem resilience regarding six allocations (two housing and four employment).
In addition, to matters of soundness we also advise that some refining/clarity be made to the plan in respect of several policies and supporting text to ensure the
robustness of the plan.

Our detailed comments on the plan and supporting documents can be found in the annexes to this letter.

Please note that our comments are without prejudice to any comments we may wish to make when consulted on any subsequent formal planning application submissions
to develop any of the land identified within the plan. At the time of any other consultation there may be new information available which we will need to consider
in providing our formal advice.

Finally, we look forward to continuing to work closely with you to progress the plan and trust these comments are of assistance. If you have any queries, or if you require any further information, please do not hesitate to contact us at the above address.

Remove the site from the Plan

We are instructed by Mr P. Harries & Mrs J. Sainty to a make a formal representation to the
“soundness” of 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/067/012, seeking inclusion of their land for future residential development within the
defined settlement limits of Gorslas within the Replacement Local Development Plan. The
Candidate Site comprises an undeveloped field enclosure set primarily to the rear of
residential properties which front the eastern flank of Church Road in Gorslas. The site has
an undeveloped plot which lies between detached houses on Church Road which leads
directly to the field at the rear.
We have noted that the frontage plot is included within the draft settlement limits, however
the adjoining, rear field has not been included. This formal Representation relates solely to
the unsuccessful part of the Candidate Site.
The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our clients’ submission, reasons why the site was not selected for inclusion within the draft
settlement limits of Gorslas, as contained within the Second Deposit Draft. We note that the
submission successfully passed through all initial stages, being Stage 1 (site compatible
against the location of future growth presented in the Preferred Strategy) and Stage 2A
(Initial Detailed Site Assessment). However, at Stage 2B (further detailed site assessment)
of the Council’s Assessment, it was concluded that the Candidate Site was not appropriate
to proceed, citing that “There is sufficient and more suitable land available for development
within the area to accommodate its housing need. Development at this location may impact negatively upon the amenity of adjacent residential properties.

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 Gorslas, 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 Gorslas, as reproduced below in Figure 1. The land should be appropriately allocated for housing under Policy HOM1 “Housing Allocations.”

Figure 1 – Extract from Draft Proposals Map with 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 Cross Hands / Ammanford with Deposit Draft

1.1 The Council consider that the only reason for the Candidate Site at Church Road not being included within the draft Plan as a Residential Allocation is that they believe that there are sufficient residential sites allocated elsewhere in the settlement. On this basis, it must be accepted that the form of the Candidate Site set to the rear of established properties which front Church Road, together with the proposals to
utilise the existing vehicular access (subject to appropriate widening and junction
alignment) is deemed acceptable, and in accord with the spatial form and character
of the settlement.

1.2 The proposals under this Representation merely seek the addition of circa 6
residential units to the overall housing supply of Gorslas, which forms part of the
principal service centre of Cross Hands, and within the Ammanford / Cross Hands
Cluster as defined within the draft LDP. Figure 2 below provides an extract of the
indicative site layout plan for this Representation site.
Figure 2 – Indicative Site Layout Plan of Representation Site

1.3 The Ammanford / Cross Hands Cluster aims to provide an additional 1267 residential
units over the Plan period to 2033, and thus the addition of an allocated site of only 6
units will not lead to an over-supply of dwellinghouses within the Cluster.

1.4 Only one site is allocated within the draft settlement limits of Gorslas, that being Site
PrC3/h18 “Land adjacent to Brynlluan”. That site is expected to provide for 29 units. It
is considered that the settlement of the scale of Gorslas is highly sustainable given its
close proximity to Cross Hands and its wealth of retail, employment and community
facilities. The addition of only one modest site in the village will not bring enough
housing for the remainder of the new Plan Period. The addition of one further, very
modestly sized site of only 6 units will not place a burden on facilities, not the semi-rural backdrop to the settlement.

1.5 We have examined and researched sites which have been brought forward as Residential Allocations with the Second Deposit Draft. On behalf of clients in this LDP Cluster, we have made formal Representations seeking the omission of the following draft Allocations:
Site PrC3/h4 - Tirychen Farm, Dyffryn Road, Penybanc - for 150 units.

Planning permission was last granted in 2014 for 289 dwellings, under Application E/21633. However, that permission was only granted in outline form. It subsequently lapsed, and the landowners sought to vary conditions upon that permission to extend the validity of the outline permission. That Variation of Condition application was finally approved in October 2019, under Application E/38686.

The recently approved Variation of Condition permission does little to display any real progress in the deliverability of the site. It merely amounts to the landowners seeking to continue to benefit from an outline planning permission at the site. Full planning permission was granted as far back as 1992 (D6/19332), which subsequently lapsed. The Land continued to be allocated within the Dinefwr Local Plan (1996), and subsequent Carmarthenshire Unitary Development Plan (2003). No progress was made in bringing the site forward, and yet it was allocated within the Local Development Plan in 2014. Consequently, thirty years of Development Plan allocations have elapsed without any signs of delivery of this site. Clearly, there is no historic demand for a site of this scale in this part of the Ammanford area. More physically challenging sites, such as the re-development of the Betws Colliery site at Betws and Cae Pound at Cross Hands West Tip have come forward long before Tirychen, and yet still the Council is prepared to allocate the site once again in a new Development Plan.
The decision to retain Tirychen Farm after a period of 30 years within the LDP is shown to be inconsistent, as does not sit with LDP Procedural Guidance which encourages Local Planning Authorities to only re-allocate sites based upon firm evidence of deliverability.

1.6 Site PrC3/h22 Land at Pant-y-Blodau in Penygroes for 79 units.
The site was allocated as GA3/h35 in the Adopted 2014 LDP for 90 units. Planning Permission was granted in April 2015, and yet some 8 years later, no work has been undertaken on the site, and the land remains undeveloped. No indication is provided within the Site Assessment Report (January 2023) as to why the Council consider this long-standing allocation to remain in the Plan?

1.7 We submit that the draft allocations at Tirychen and Pantyblodau be omitted from the Plan, and that housing allocations be redistributed to modest Candidate Sites, of up to 10 units such as that proposed at Church Road. There is clear evidence in Gorslas, Cefneithin and Drefach that such modest sites are far more likely to be brought forward and developed in full by regional and small housebuilders given that
construction and development costs are more likely to be viable in relation to house sales and the general housing market in this part of Carmarthenshire.

1.8 In the case of Church Road, there are little signs within the immediate locality of properties for second sale, and no evidence of undeveloped land available within this part of the settlement limits, which is a strong indicator of a healthy property market at Gorslas. Consequently, it is a location where housing proposals are deliverable, assisting to meet housing needs in this part of Cross Hands.

2.0 Proximity to Neighbouring Properties

2.1 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 6 dwellinghouses as a sensitive small development will not appear at odds to the prevailing spatial pattern of development in Gorslas. The Council’s assessment conclusion that “Development at this location may impact negatively upon the amenity of adjacent residential properties” is without foundation, and completely contradictory. The locality has numerous examples of modern cul-de-sac development being completed at backland locations, especially opposite, off the western flank of Church Road, which in turn, advocates that the form of development proposed off the eastern flank of Church Road is no different, resulting in it being respectful to the character and setting of the locality. The indicative site layout plan illustrates that new dwellings can be positioned to remain at a healthy and commensurate habitable distance from existing neighbouring properties backing on to the site from Church Road.

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