PrC3/h36

Remove the site from the Plan

Objection to Policy HOM1 on behalf of Evans Banks Planning Ltd
Site PrC3/h36 – Betws Colliery, Betws, Ammanford
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 of Betws Colliery,
Betws (LDP Ref. No. PrC3/h36) 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 Proposal Map extract below and is
proposed for the allocation in the 2nd Deposit LDP for the purposes of 66 residential units.

(Extract of Proposal Map for Betws and Betws Colliery 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/h36 was considered as part of this process and as
a result the Council concluded as follows:
“Part of the site to be retained as a residential allocation, with site reference PrC3/h36. The
site has partly been developed.”
It is clear from the above therefore that the Council considers that the site is deliverable for
the purposes of 60 houses, although it is not clear on what basis this conclusion has been
made. This is particularly as whilst the southern part of the former allocation site (south of
Ffordd y Glowyr) has been developed, the remaining element (Allocation PrC3/h36)
continues to remain undeveloped.
The allocation itself is brownfield in nature and is currently in an overgrown state. The
topography of the site slopes gradually from east to south. The site is surrounded by mature
woodland to the north and to the west with Ffordd y Glowyr making up the southern
boundary, as can be seen from the aerial photograph below (allocation circled red).
see attachments

Remove the site from the plan

This representation comprises an objection to the inclusion of PrC3/h36 and
PrC3/h6 as formal allocations for residential development within the
development limits for Betws/Ammanford.
The objection is primarily based on -
1. The viability of these two sites - there is little evidence to suggest that they
will come forward during the plan period.
2. The inadequacy of the highway network in the vicinity of these sites - it is a
common occurrence for significant levels of vehicle congestion to occur at
these locations.
3. There are amenity issues associated with their proposed development.
The continued inclusion of PrC3/h36 and PrC3/h6 is blocking and preventing
the development of other more appropriate residential schemes in this part of Betws/Ammanford.