PrC3/h18

No change to the Plan.

Please see Supporting Statement. Within the deposit plan, the site is allocated for
29 residential dwellings (Ref: PrC3/h18) and it should stay remain with the plan. It is the only housing allocation provided within Gorslas therefore it is essential it remains within the deposit plan. The client is keen for the site to be developed in order to meet the housing need within Gorslas. Neighbouring allocations in Cross Hands have been built out (PrC3/h11, PrC3/h12 and PrC3/h13), as well as a site in nearby Tumble (PrC3/h29). In summary, the application fully supports Policy HOM1.

Supporting statement:

1. Introduction

1.1 This representation has been prepared in relation to Carmarthenshire County Council’s consultation on the ‘Second Deposit Revised Carmarthenshire Local Development Plan’ (2018-2033). The representation is submitted on behalf of Morganstone in regard to ‘Land adjoining Brynlluan, Gorslas`.

1.2 The representation is accompanied by the requisite Representation Form and is submitted to the Authority within the statutory consultation period (by the deadline for representations of 14th April 2023).

1.3 A submission was made in regard to the land adjoining Brynlluan, Gorslas over the course of the preparation of the Revised Carmarthenshire LDP, including most recently, a deposit plan representation concerning proposed allocation of this site in the deposit Revised LDP submitted in March 2020. All representations have been made in close liaison with the Authority, with partnership working characterising the positive progression of the proposed allocation through the LDP process. In continuation of this approach, further representations are submitted to the Second Deposit Revised LDP.

1.4 It should be noted that this Second Deposit Revised LDP representation is to be followed by the submission of further site/allocation-specific documents (comprising Concept Plan; Development Viability Model and accompanying Viability Statement; and Statement of Common Ground).

2. Overview

2.1 Within the First Revised Deposit LDP, the site (referred to as ‘Land adjoining Brynlluan, Gorslas`) which was allocated for residential use under site reference PrC3/h18 which makes a provision for 29 units during the plan period.

2.2 Within the Second Revised Deposit LDP, the site continues to be identified as residential allocation under PrC3/h18 for the same quantum of development.

2.3 As per the representation submitted to the First Revised Deposit LDP, the site’s inclusion as a residential allocation in the Second Revised Deposit LDP is supported.

2.4 In summary, Morganstone continue to support the Second Deposit Revised Plan on the basis that the Council have accepted the principle of residential use development. Morganstone looks forward to working in partnership via a Statement of Common Ground with the Council and delivering this site for much needed residential development within the settlement of Gorslas which forms part of the Ammanford/Cross Hands principal centre.

2.5 The client, Morganstone is one of the region’s most prominent house builders of open market and affordable dwellings, and this site could be added to their growing number of projects. They have previously worked with the Local Planning Authority to provide high quality dwellings that meet the needs of the community in question. Contractual arrangements are in place between the landowner and Morganstone, in the form of an option agreement, to enable the site`s promotion and delivery after successfully completing a planning application.

2.6 In terms of housing allocations within the deposit plan under Policy HOM1, there are a number of allocations in Cross Hands which have been built out and completed providing almost 200 dwellings (PrC3/h11, PrC3/h12 and PrC3/h13), whilst another has been developed at the Central Garage allocation in nearby Tumble (PrC3/h29).

3. Update/Progress Following Representations to the First Revised Deposit LDP

3.1 Morganstone are now in the process of commissioning a significant amount of further supporting work to inform the proposed allocation since the previous iteration of the Deposit Plan was published in March 2020.

3.2 The following further site-specific information is to be submitted (in follow up to this Second Deposit Revised LDP representation) to further inform, and allow for a robust site allocation to be included in the Revised LDP:
• Updated Site Plan;
• Completed Ecology Report;
• Development Viability Model and Supporting Viability Statement;
• Statement of Common Ground.

3.3 In order to support future representation of the site, an ecological appraisal will need to be completed together with an updated capacity layout.
Viability

3.4 Morganstone will seek to purchase the Burrows Hutchinson viability assessment model and commission an independent viability study. The completed DVM and supporting Viability Statement will be submitted to the LPA.

4. Second Revised Deposit LDP – Integrated Sustainability Appraisal (February 2023)

4.1 The Integrated Sustainability Appraisal (February 2023) undertaken by the Authority in relation to the Second Revised Deposit LDP indicates that the residential allocation at land adjoining Brynlluan, Gorslas performs well against the defined sustainability criteria, with a number of ‘positive’ and ‘very positive’ outcomes identified (as shown in the extract from the ISA Report below). Figure 1: ISA Summary – land adjoining Brynlluan, Gorslas (PrC3/h18)

4.2 It is the case that a ‘negative’ outcome is identified in relation to ISA 2 (Biodiversity), and ISA 7 (Soil). It is noted that all greenfield allocations perform negatively against the ISA 2 and ISA 7 criteria.

4.3 It is understood that there are Welsh Water assets traversing the site. Having said this, it is not considered that this would sterilise the site for future development.

4.4 Part of the land is under threat from potential Surface Water Flooding as a result of a small watercourse running through the site. It is considered likely that a suitable site layout and design can be identified which locates highly vulnerable development outside of the area at risk of flooding.

4.5 At present, the site does not benefit from vehicular access that could be used for residential development, though it is proposed that access could be achieved onto Cefneithin Road along the southern border of the site.

5. Consideration of Tests of Soundness

5.1 It is considered that the Second Revised Deposit Plan meets the three Tests of Soundness, which must be satisfied in order for a development plan to be considered ‘sound’ and able to be recommended for adoption.

5.2 The proposals for the land adjoining Brynlluan, Gorslas are in conformity with the three Tests of Soundness as discussed below in the context of the site and the proposals involved.
Does the Plan Fit? (i.e. is it consistent with other plans?)

5.3 The proposals are compatible with the National Development Framework, and particularly ‘Policy 24 – Regional Centres’ as Gorslas, that forms part of the Ammanford/Cross Hands principal centre, along with the other identified towns in Mid and South-West Wales, will be the focus for managed growth, reflecting their important sub-regional functions. Regional and local development plans should recognise the roles of these settlements.
Is the Plan appropriate? (i.e. is it appropriate for the area in the light of evidence?)

5.4 The proposals have been derived from evidence submitted with the earlier Candidate Site together with previous engagement with the Council and earlier evidence which formed part of the adopted LDP evidence base which is still relevant.
Will the Plan deliver? (i.e. is it likely to be effective?)

5.5 Morganstone are very keen to deliver the site as promised. This is the only housing allocation for Gorslas, therefore encouraging it`s delivery will provide a valuable contribution towards housing in the area.
5.6 In summary:

• The Second Revised Deposit LDP policy and allocation relating to site PrC3/h18 is founded on robust evidence and provides an appropriate planning framework to deliver modest new homes within the context of the village of Gorslas where new development has been limited over recent times, in accordance with the overarching vision and objectives of the Plan, as part of a development to come forward over the Plan period. It is imperative that this housing allocation is delivered as it is the sole one within Gorslas for the deposit plan.

• The policy and allocation allows for the controlled and sustainable development of the site and is supported by a detailed technical review of relevant settlement boundaries and landscape characteristics, as well as of the individual opportunities and constraints relating to the site.

• Morganstone consider that the Second Revised Deposit LDP is sound and entirely appropriate in so far as it relates to the site. The proposals for the site are consistent with LDP policy, and capable of delivering a financially viable, sustainable form of development.

• Such a development is considered to accord with the requirements of the Well-being of Future Generations (Wales) Act 2015, and provides an opportunity to contribute towards delivering economic, social, and environmental improvement.

6. Conclusion

6.1 This Second Revised Deposit Plan submission document has been prepared in order to accompany the Representation Form completed in respect of land adjoining Brynlluan in Gorslas. It is submitted on behalf of Morganstone.

6.2 The proposed residential land allocation under site reference PrC3/h18 which provides for a modest scale of new residential development, is supported, as is the overall soundness of the Plan.

6.3 This Second Revised Deposit Plan submission fully supports the proposed allocation. Furthermore, the development of other allocations within the deposit plan in nearby areas puts added emphasis on the delivery of this housing allocation. 3 allocations within Cross Hands have been built out recently, whilst another was completed recently in Tumble. This further emphasis that developing this allocation is essential in order to meet the housing need within the area.

6.4 The submission of further site/allocation-specific documents, comprising an updated site plan and completed ecological appraisal, Development Viability Model and accompanying Viability Statement; and Statement of Common Ground, is to follow this overarching representation of support on the Second Revised Deposit Plan, which will further detail and reinforce the viability of the proposed allocation.

6.5 Morganstone looks forward to working in partnership with the Council on a Statement of Common Ground, so that the site allocation can be developed aligned with the aspirations of both parties.

No change to the Plan

Thank you for consulting Welsh Water, we welcome the opportunity to continue to engage in the LDP process and we offer the following representation for your consideration:
Issues Identification We note and welcome the inclusion of issue 23 regarding infrastructure capacity to support development. The availability of our infrastructure capacity is a key element – particularly in rural areas - in ensuring sustainable and viable development sites.
Strategic Objectives The availability or capacity of infrastructure is a key aspect in determining the sustainability of a settlement, therefore we support the inclusion of SO6 and SO14.
Strategic Growth and Spatial Options We note that the Council identifies a growth requirement of 8,822 new homes over the revised LDP period 2018-2033.
Preferred Spatial Option Whilst we are supportive of the hybrid option and are pleased to note that it acknowledges the need for development to be supported by a range of appropriate infrastructure, there will inevitably be certain areas – particularly in the more rural locations of the County – where water or sewerage infrastructure is limited in its availability.
Placemaking, Infrastructure and Cohesive Communities We welcome the sentiment of paragraph 9.43. Where there is insufficient infrastructure capacity and development wishes to connect in advance of our AMP capital investment, planning obligations or a commercial agreement are the most appropriate way in ensuring delivery of necessary supporting infrastructure. We also welcome the inclusion of paragraph 9.47 and further commentary can be found in respect of the policy INF4.
Policies
SG1: Regeneration and Mixed-Use Sites Please see appendix 1 for site allocation comments.
SG2: Reserve Sites We note that the reserve sites will only be released for development if the allocations fail to deliver the required growth, and that the decision to utilise the sites will be made as part of a formal plan review. As such we will be happy to provide comments regarding capacity to accommodate sites in due course.
SG3: Pembrey Peninsula Most of the peninsula is unsewered and does not have a water supply with only elements of the southeast of the peninsula currently served by either. As such, any proposals for development may require significant offsite water mains and sewers to connect to existing networks. Further to this, the Pembrey Wastewater Treatment Works (WwTW) that serves the southeast of the peninsula may require additional capacity to accommodate any further development and developers may need to fund reinforcement works at the WwTW.
HOM1: Housing Allocations Please see appendix 1 for site allocation comments.
SP6: Strategic Sites Given that both sites have extant planning permission we have nothing specific to advise.
EME3: Employment Proposals on Allocated Sites The following provisions are applicable to all individual development plots located within allocated employment sites:
• We will work with your authority to support sustainable economic development however your authority and potential developers should be aware that the obligations of a water and sewerage undertaker extends to ‘domestic’ supplies only. Where an employment allocation results in higher demands of water supply and/or trade effluent discharges we recommend and welcome early consultation with Dwr Cymru Welsh Water.
• The individual plots available for development can represent a substantial area of land for which the potential demands upon our assets are unknown at present. It is essential that we understand these demands to allow us to assess the impact on our assets. It may be necessary for water and/or sewerage hydraulic modelling assessments (HMAs) to be undertaken at the developer’s expense to establish where the proposed development could connect to the existing networks, and to identify any required infrastructure improvements.
• Water mains and/or sewerage infrastructure required for any potential development site can be acquired through the requisition provisions of the Water Industry Act 1991 (as amended).
• Welsh Water always has rights of access to its assets. Where there are water mains and/or sewers crossing sites then protection measures in respect of these assets will be required, usually in the form of an easement width or in some instances a diversion of the asset.
• If any development site gives rise to a new discharge (or alters an existing discharge) of trade effluent, directly or indirectly to the public sewerage system, then a Discharge Consent under Section 118 of the Water Industry Act 1991 is required from Welsh Water. Please note that the issuing of a discharge consent is independent of the planning process and a consent may be refused despite planning permission being granted.
SP9: Infrastructure The availability or capacity of infrastructure is key in determining a settlement’s sustainability as such we welcome the provisions of this policy in requiring development to ensure sufficient capacity is available or if not, that suitable arrangements are in place to provide the necessary capacity.
With specific regard to water and sewerage infrastructure, where there is insufficient capacity and where no reinforcement works are programmed within the respective AMP Capital Investment Programme, the requisition provisions can be entered into for water and sewerage network infrastructure. The requisition provisions do not apply to wastewater treatment works (WwTW) and planning obligations, or a commercial agreement, may be necessary.
We welcome the reference in the supporting text to Drainage and Wastewater Management Plans (DWMPs). Welsh Water is embarking on the preparation of developing Drainage and Wastewater Management Plans (DWMP) which Welsh Government may be minded making statutory in due course. Growth information is built into our DWMP and forms an important element of our planning which aims to understand how we will continue to deliver effective sewerage services and manage the proactive development of natural flood management for a growing population in the face of climate change and other challenges.
Critically the DWMP considers the impact of changing population on our assets and the subsequent effect to customers and on the environment. As such we believe that the DWMPs will play a role in delivering a holistic, prioritised approach to the management of our drainage and sewerage network in the years ahead, and will complement other planning documents including LDPs, the NDF, and SDPs. To maximise the potential benefits, we are continuing to work closely with our stakeholders and LPAs in the continued development of our DWMP.
INF1: Planning Obligations Where there is insufficient infrastructure capacity available to accommodate a site and development wishes to connect in advance of any AMP capital investment, planning obligations or a commercial agreement are the most appropriate way in ensuring delivery of necessary supporting infrastructure.
INF4: Llanelli Wastewater Treatment Surface Water Disposal We are supportive of the provisions of this policy and the supporting text; moreover, we are pleased to note that the matter has been given its own specific policy. We have also prepared a consultation response to the Burry Inlet SPG which provides further detail on this matter.
SP10: Gypsy and Traveller Provision - Please see appendix 1 for site allocation comments.

SP12: Placemaking and Sustainable Places We specifically welcome the inclusion of criteria k) in Policy SP12. Disposing of surface water in a sustainable manner ensures that it will not communicate with the public sewerage network, which protects the environment and ensures that there is sufficient capacity in the public sewerage network for foul-only flows from development sites. On the theme of SuDS, we welcome the inclusion of the supporting text at paragraphs 11.273 to 11.275 regarding the recently established SuDS Approval Boards (SABs).
PSD3: Green Infrastructure Network We welcome the provisions of this policy and the supporting text. The integration of SuDS as a Green Infrastructure asset is something that we are particularly supportive of.
SP16: Climate Change We are supportive of the inclusion of SuDS in new development and as such welcome the provisions of criterion b) of this policy.
CCH4: Water Quality and Protection of Water Resources we welcome the requirement in supporting paragraph 11.510 that the necessary infrastructure needs to be in place or will be provided to serve development however we would highlight that in cases where there are no plans in place for infrastructure improvements in our AMP investment programme, developers can pay for the necessary infrastructure themselves through the requisition provisions of the Water Industry Act (WIA) 1991 or via Planning Obligations Agreements under the TCPA 1990. It should be noted that the requisition provision of the WIA 1991 only applies to sewerage network reinforcement works, not to WwTW schemes. Funding to deliver reinforcement works at a WwTW can be delivered via Section 106 of the Town and Country Planning Act 1990.
In relation to improving water quality, we are investing an additional £60m specifically to reduce phosphate in the five failing Special Area of Conservation (SAC) rivers in our operating area. This includes schemes at Lampeter and Llanybydder WwTWs that are due for completion by March 2025. In the next investment period 2025 to 2030 (AMP8) we will target investment with the ambition that none of our WwTWs are the cause of ecological failure. Through our phosphorus investment plan, we will have removed 90% of the phosphorus load from our WwTWs discharging to failing SAC rivers, playing our part in allowing these special rivers to meet their water quality targets and to relieve pressure on development restrictions. We expect to complete this programme of work by 2032. Whilst our investment will remove a significant amount of phosphorus from our sewage, in most cases it will not result in SACs complying with the water quality targets on its own. This is not something that Welsh Water can do on its own and it will take the combined efforts of all the contributing sectors to achieve this.

We will be engaging with our regulators and local planning authorities through the Tywi and Teifi Nutrient Management Boards (NMB) which can provide the governance, strategic direction and local intelligence/decision making needed if we are to be successful in relieving the pressure on planning restrictions and restoring river quality.
With regard to supporting text in paragraph 11.516, there are several locations within the County where we abstract water that is treated prior to entering the public water supply network. As such, we fully support the provisions in the supporting text of this policy in preventing the degradation of water resources.

TRA1: Transport and Highways Infrastructure Improvements There may be locations where proposed developments / routes pass over public sewers and water mains. Under the Water Industry Act 1991 we have rights to always access our apparatus and protection measures in respect of these assets will be required either in the form of an easement width or a possible diversion of the asset. We welcome early engagement once further detail is available.
MR1: Minerals Proposals We welcome the inclusion of criterion e) and k) of this policy.
We hope that the above information will assist you as you continue to progress the LDP2 and would encourage the LPA to continue to liaise with Welsh Water at each stage of the process. In the meantime, should you require any further information please do not hesitate to contact us at Forward.Plans@dwrcymru.com or via telephone on 0800 917 2652.