SuV51/h1

Remove site from Plan.

Further to the publication of the above document, we have been asked by our Clients to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so we consider it necessary to
make a formal representation to the “soundness” of the Carmarthenshire Deposit Local
Development Plan in relation to the allocation for residential development at land Opp.
Village Hall, Cwmifor (LDP Ref. No. SuV51/h1) 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 8 residential units.
Plan A

(Extract of Proposals Map for Cwmifor and land Opp. Village Hall 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 SuV51/h1 was considered as part of this process and as a result the Council concluded as follows:
“The site represents a longstanding residential allocation and there are concerns over the deliverability of the whole site. Allocation to be reduced in size with reference SuV51/h1.”
It is clear from the above that the Council considers that the site is deliverable for the purposes of 8 houses, although it is not clear on what basis this conclusion has been made, especially as the Council state that there are concerns over the deliverability of the site as well as it being a longstanding residential allocation.
The allocation is greenfield in nature with its topography being relatively level. The eastern and southern perimeters of the allocation are covered with mature vegetation, trees and hedgerows. The western boundary is bordered by further agricultural land while the northern boundary is bordered by residential dwellings as can be seen from the aerial photograph below (outlined in red below).

Photograph 1
(Extract from Google Earth – June 2021)

Access to the allocation is currently gained via an existing agricultural access off the C2162 that being the main road running through Cwmifor (see below).

Photograph 2
(Streetscene of Access to Allocation Site)

Outline Planning Permission was saught after in 2007 for Residential Development and Community Car Park (E/16584). Outline planning was granted in 2013 however there have been no follow up applications relating to the granted outline consent. Full Planning Permission was then saught in 2019 for the Construction of Three dwellings (Phase 1 of larger scheme) including community car park, estate road, and associated detail (E/39651). This application was refused in February 2023 as the scheme had failed to address and satisfy the recently intorduce phosphate regulations with respect to foul water generation.
The site makes up part of an allocation in the Carmarthenshire Local Development Plan (2014) under Allocation (SC30/h1), and previously under Allocation CL34/a of the Carmarthenshire Unitary Development Plan (2006) (as can be seen below).

Plan B
(Extract of current LDP Proposal Map for land Opp. Village Hall, Cwmifor (Adopted 2014))

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

Despite having almost 20 years of support for the principle of residential development at the historic allocation from the Council, not a single housing unit has been delivered to date.

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

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

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

Test 3 – Will the Plan deliver?
The allocation fails to test the soundness as the site is clearly unable to deliver any new housing. The Welsh Governments Development Plans Manual (Edition 3) is quite clear with regard to rolling forward allocations and states that allocations “… rolled forward from a previous plan will require careful justification for inclusion in a revised plan, aligning with PPW. There will need to be substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered”. No evidence has been presented to demonstrate a change in circumstances to indicate the allocation will now be deliverable and so its continued allocation would lead to the plan being deemed unsound on this basis.

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

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

No change to the Plan

This representation comprises both an objection and a supporting submission. The proposer's land ownership at Cwmifor (a designated Tier 3 Sustainable Village) comprises an area of land ideally situated at the entrance to the village and opposite Cwmifor Village Hall.
A frontage portion (SuV51/h1) has already been identified as being suitable for residential development and has been included within development limits, the remainder of the land holding has however been excluded. The part-inclusion of this frontage portion is clearly supported, but an objection is hereby made to the exclusion of the remainder. The justification for including only part of the proposer's land will apply to the whole area.
The following objection is to the exclusion of the majority part of this site from the development limits for Cwmifor. A detailed planning application was submitted in respect of the objection site and which was to be reported to Planning Committee with a recommendation for approval. However, the day prior to that meeting, the application was held in abeyance, due to the decision of Natural Resources Wales (NRW) to impose phosphate discharge restrictions within the entire Tywi Valley SAC area.
It must be emphasised that the proposed scheme includes a key community benefit. The development of the full site will facilitate the provision of a community car park that will provide benefit to village residents and will ease on-road parking. The proposed parking area will be located immediately adjacent to the communal hub of Cwmifor – the village hall and Church. Existing parking provision in this locality is limited and therefore this community facility would be of considerable benefit.
The residential element of the scheme would comprise a high quality phased development and would draw on local Welsh vernacular architectural design elements, making every effort to be sustainable, both through the employment of local contractors, the use of local suppliers, and in the long term, through the provision of residential units within convenient walking distance of village services and facilities.
A frontage portion of the proposer’s land (SuV51/h1) comprises the only residential allocation within Cwmifor. It must be emphasised that the entire objection site is readily deliverable and would be entirely appropriate for a phased form of development.
The inclusion of the proposer’s land would not lead to additional environmental pressure, but instead will foster sustainable growth and allow for a wider choice of housing type within this Tier 3 Sustainable Village. Its development would be in keeping and in character with the settlement and will ensure a readily deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints and its short term delivery is assured.
The inclusion of this land within revised development limits would be fully supported.

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.

Remove site from Plan.

Representations to Carmarthenshire County Council 2nd Deposit Revised Local Development Plan
Consultation
Land Adjacent to Culla Road Roundabout (B4317), Carway (Candidate Site ref: SR/023/003)

CarneySweeney is instructed on behalf of our client, Ffos Las Ltd, to submit representations to the
current consultation on Carmarthenshire’s 2nd Deposit LDP. This letter accompanies the following:

 Completed Representation Form;
 Site Location Plan;
 Site Ref: SR/023/003 Reasonable Alternatives Site Assessment Proforma (Carmarthenshire
County Council, February 2023); and
 Candidate Site Submission Supporting Statement (prepared by WYG, first submitted at First
Deposit LDP candidate site consultation).

These representations are made in relation to land adjacent to Culla Road Roundabout (B4317),
Carway; a site which was submitted as a Candidate Site during the 2018 Call for Sites (Candidate Site
ref: SR/023/003). The site successfully passed all three stages of the LPA’s previous assessment
process, scoring highly. The site is in single ownership and is immediately deliverable. Notwithstanding
this, the site is not currently being progressed by the Council as a draft allocation. The LPA’s stated
reason for not currently allocating the site, as stated within its Site Assessment Table (2023), is:
“Whilst there are no adverse impacts to the development of this site, there is more suitable and
appropriate land available within the village to accommodate new development”.
Whilst not currently allocated, the site is included as a ‘Reasonable Alternative’ site by the LPA within
their Site Allocation Assessment - Reasonable Alternatives Report, February 2023. The report
reiterates that the site performed suitably in terms of the RLDP Site Assessment Methodology, including
Integrated Sustainability Appraisal objectives. A copy of the site’s proforma is also enclosed with this
submission and clearly demonstrates how favourably the site scores against the RLDP’s key objectives.

It is our firm view the Council should re-consider its decision not to allocate this site for housing
development, and to this end we wish to make the following representations.
Candidate Site Description and Context
Full details of the site’s characteristics and development potential are provided within the enclosed
Candidate Site Supporting Statement (2018) prepared by WYG. This Statement was previously
submitted to the LPA as part of the Call for Sites process.
In summary, the candidate site (ref: SR/023/003) comprises c. 5.3ha of land which is bound by existing
residential development to the north, comprising the built settlement of Carway, and to the south by the
Persimmon housing development at Ffos Las racecourse. The site’s location is considered highly
sustainable, given its immediate proximity to Carway, Ffos Las racecourse and Trimsaran, and
associated facilities. The allocation and subsequent ongoing delivery for housing of the adjacent
Persimmon sites1 also establishes the sustainability of this location to accommodate new housing.
The site is free from physical constraints, being relatively flat with no existing buildings. The site is not
located within any heritage, ecological or nature conservation designations and lies within Flood Zone
A.
The site can be readily accessed from the existing B4327 Culla Road Roundabout, with a secondary
access point available at Heol Dyffryn Aur to the south.
As outlined above the site is immediately deliverable and as previously concluded by officers there are
no adverse impacts to the development of this site.
Pre-Application Advice (ref: PRE/01319)
Since the previous Candidate Site submission Ffos Las Ltd has sought pre-application advice from
Carmarthenshire County Council in respect of the proposed development of the site for housing. A
written response was received from the LPA in March 2023 (application ref: PRE/01319).
Whilst the current NRW Development Advice Map identifies the site within flood zone A, the preapplication
response notes that based on the emerging draft NRW Flood Map for Planning, part of the
site lies within flood zone 3 (see Fig. 2 below). The pre-application response advises that in accordance
with TAN 15 (which is due to be adopted for decision making in June 2023) vulnerable development
such as housing is generally not permitted in Flood Zone 3.
1 Pursuant to outline planning permission for mixed use development at Ffos Las racecourse and surrounding land (pp ref:
S/11568).
www.carneysweeney.co.uk
Figure 1: NRW Flood Map for Planning extract for Carway
Whist we acknowledge the above, it is important to note only a small proportion of the site is affected
by this Flood Zone 3 designation and, most importantly, it lies partly within Flood Zone 3 for surface
water and small watercourses only and is not deemed at risk of river and sea flooding. The latest
available version of the TAN 15 (January 2023, Consultation Version), is clear that vulnerable
development such as housing is generally not considered acceptable in areas that are flood zone 3 for
Rivers and Sea flooding specifically:
“Where development is proposed in any area facing flood risk from rivers and the sea, the
planning authority will need to be satisfied that its location is justified. It is important that areas
in Zone 3 are used only as a last resort, and not at all for new highly vulnerable development.”
(TAN 15 Consultation Version 2023, pp 10.10) (our emphasis).
Whereas, in terms of surface water flood risk, TAN 15 (Jan 2023) notes:
“Locally appropriate approaches can be incorporated into the Development Plan using local
policies, and in the decision-making process for planning applications.” (pp 4.8).
“The [Flood Map for Planning] shows areas at risk of flooding from surface water and small
watercourses, split into ‘Flood Zone 2’ and ‘Flood Zone 3’. These are considerations for
planning authorities and must be integrated into plan-making processes and decision-making.
For some developments it will be possible and appropriate to include management and
mitigation measures (refer to section 8).” (pp 5.2) (our emphasis added).
“A Flood Consequences Assessment will be required for any new development proposal
located fully or partly in Flood Zones 2 and 3 - Surface Water and Small Watercourses.” (pp
8.7).
The emerging TAN15 does not preclude housing development within surface water Flood Zone 3; such
development will generally be acceptable, subject to detailed design and appropriate management and
mitigation.
Accordingly, any future development proposals at the site would be supported by a Flood
Consequences Assessment and Drainage Strategy and would be subject to the separate SAB approval
process to secure sustainable surface water drainage measures. This is eminently achievable at the
detailed design stage and, therefore, should not be considered a barrier to the allocation of the site.
Additionally, it should be noted that significant drainage infrastructure has already been implemented
at this location as part of the delivery of, firstly, Ffos Las racecourse and latterly the housing allocation
being delivered by Persimmon immediately to the south (site allocation ref. SeC8/h1).
In respect to other potential site-specific requirements, namely, further ecological investigation, we
envisage this being carried out to help inform detailed development proposals and ensure Biodiversity
Net Gain (BNG) is delivered by on site delivery and/or by offsetting.
Housing Need and Supply
The Council’s pre-application advice concludes that while development of the site would be considered
contrary to the development plan (given the site’s current status outside the existing settlement
boundary), there is noted potential for small areas of local needs housing adjacent to the development
limits (in Carway) provided there is an established genuine local need.
We note the 2nd Deposit Plan Strategic Policy – SP4 ‘A Sustainable Approach to Delivering Homes’
states that:
“In order to ensure the overall housing requirement of 8,822 homes for the plan period is met,
provision is made for 9,704 new homes in accordance with the settlement framework in order
to promote the creation and enhancement of sustainable communities.”
Various population and household growth projections were assessed to reach the above requirement
figure. The ten-year based projection from Turley’s Housing and Economic Growth Report was chosen
to be taken forward for the RLDP, which projects a total population increase of 14,468 and a
requirement for 588 new homes per year.
We understand this annual housing requirement reflects build rates since 2007, which are
approximately 501 homes per year (paragraph 4 of the Housing and Economic Growth Report, Turley,
November 2022). However, this figure is less than half that of the 2014 LDP housing target, which was
1,013 dwellings per annum. Carmarthenshire Council has failed to deliver sufficient homes to meet local
demand for a longstanding period; basing future delivery on inadequate past build rates merely
compounds the longstanding issue of undersupply going forward into the new plan period.
The supporting Housing and Economic Growth report importantly notes that:
“Undersupply may though have contributed towards residents of Carmarthenshire living in
larger households than was previously anticipated, some potentially being left with no choice
but to stay in the family home or share with other adults due to a shortage of available housing.”
(pp 5).
There is clear, genuine local need. The strong market interest and swift and ongoing delivery of the
existing allocation in Carway directly adjacent to the site is a strong demonstration, itself, of local need.
We consider the housing targets proposed within the 2nd Deposit are insufficient to address previous
undersupply and meet the demands of the growing local population across the new plan period. We
consider housing targets should be lifted accordingly.
In order to achieve the RLDP’s goals to “promote the creation and enhancement of sustainable
communities” (RLDP Policy SP4), additional housing should be directed towards sustainable
settlements such as Carway. Carway is an identified Service Centre within the settlement hierarchy and
is accordingly appropriate for additional housing allocations (as per RLDP Strategic Policy SP3).
The subject site adjacent to Culla Road Roundabout (ref: SR/023/003) represents a sustainably located
site, as established in principle by the neighbouring allocated sites (refs: SeC8/h1, which has been built
out and SeC8/h3, which benefits from outline planning consent). Furthermore, the site is immediately
deliverable and by the Council’s own measure scored highly in the LPA’s candidate site assessment
process. Based on the Council’s Site Assessment Table (2023), the only reason for rejecting the site
www.carneysweeney.co.uk
as an allocation is a perceived lack of need. However, we encourage the Council to revisit its previous
conclusion on this in the context of the Council’s persistent undersupply of housing and added
uncertainty regarding the deliverability of the Council’s proposed housing allocations. Paragraph 4.2.10
of Planning Policy Wales 11 (PPW) stresses the importance that “The supply of land to meet the
housing requirement proposed in a development plan must be deliverable.”
Phosphates and SAC
We understand one of the principal reasons for the Council’s current consultation on a 2nd Deposit Plan
was to evaluate NRW’s guidance on riverine phosphate levels. Within the County, there are two riverine
Special Areas of Conservation (SAC) that are affected by this guidance: the Afon Teifi and Afon Tywi.
Planning applications for development that may increase phosphate levels in these rivers need to
demonstrate nutrient neutrality for development to proceed.
The 2nd Deposit Plan’s evidence base includes a Nutrient Mitigation Options Technical Review report
prepared by Ricardo (June 2022). The report notes that the Pencader Sewage Treatment Works and
Llandovery Waste Water Treatment works have the highest number of planning applications
constrained by phosphorus (page iv of the report). Therefore, it is apparent that future housing
development in Pencader and Llandovery is particularly constrained by the need for nutrient neutrality.
There is now, in our view, significant doubts as to the deliverability of the housing sites allocated within
the 2nd Deposit in these two settlements in particular, namely:
 Ref: SeC14/h2 Land adjoining Maescader, Pencader for 24 dwellings;
 Ref: SeC14/h1 Blossom Garage, Pencader, for 30 dwellings;
 Ref: SeC15/h1 Land to north of Dan y Crug, Llandovery, for 61 dwellings;
 Ref: SeC15/h2 Land adjacent to Bryndeilog, Tywi Avenue, Llandovery, for 8 dwellings.
In particular, we question the deliverability of site allocation ref: SeC14/h2 Blossom Garage. This site
has been subject to a recent planning application refusal (ref: W/39283). One of the principal reasons
for refusal was the site being located within the catchment of Afon Tywi SAC and not demonstrating
phosphate neutrality or betterment.
We note allocation ref: SeC15/h1 in Llandovery listed above has been allocated for many years and
remains undeveloped. The LPA’s supporting Site Assessment Table (2023) indeed notes concerns
over the deliverability of this site, and therefore reduces the size of the allocation within the 2nd Draft
Deposit RLDP. The riverine SAC phosphates constraint makes this site even less deliverable.
Other settlements in the County that have housing allocations near to riverine SACs are Newcastle
Emlyn (which is also largely constrained by SSSI and Conservation Area designations) (allocations for
51 units); Pont-Tyweli (14 units); Cwmifor (8 units); Carmarthen (1,283 units); Burry Port (501 units);
Llanelli (1,516 units); and Llangennech (94 units).
It is highly likely that proposed housing allocations in locations affected by riverine SACs phosphate
constraints will not be deliverable, either in part or in full. Indeed, site ref SeC14/h2 above has already
failed to achieve planning permission. Combined, we understand the above affected settlements are
allocated to provide an estimated 3,590 homes. On an assumption that just c.25% of these allocations
failed to be delivered due to the riverine SAC phosphate constraint, this would lead to a significant
shortfall of c.897 homes throughout the Plan period.
Notwithstanding sites affected by the SAC phosphates constraint, there are other sites throughout the
County exhibiting deliverability issues. For instance, existing allocation Ref: SeC16/h1 - Llandeilo
Northern Quarter has been reduced in size due to deliverability concerns. We understand this site has
been allocated for a longstanding period without being delivered. Similarly, we note the below existing
allocations, totalling 115 units, have been reduced in size due to concerns over deliverability:
 Opposite Village Hall in Cwmifor for 16 units (ref: SC30/h1);
 Land at Maesarddafen, Llanelli for 94 units (ref: PrC2/h15);
www.carneysweeney.co.uk
 Heol Y Graig, Llwynhendy for 5 units (ref: PrC2/h28).
The 2nd Deposit Plan’s current reliance on riverine SAC phosphate affected housing allocations, and
other failed/constrained allocations gives rise to significant uncertainty as to the Plan’s effectiveness,
and, indeed, soundness.
Meanwhile, the subject land adjacent to Culla Road Roundabout (candidate site ref: SR/023/003) has
been excluded, on the seemingly sole basis that there is no need for the allocation. In regard to the
riverine SAC phosphate constraint, land at Culla Road is entirely unconstrained. As outlined previously
and acknowledged by officers there remain “…no adverse impacts to the development of this site…”.
We stress the site should be reconsidered for allocation.
Figure 3: Aerial view of Carway, overlaid with the existing settlement limit boundaries (shown in blue) and the
indicative site boundary (outlined in red)
Figure 3 clearly demonstrates the potential for development of the site as a logical “completion” or
“rounding” of the settlement of Carway, which is currently in two parts and physically divorced by the
subject site. Infilling the land between both parts of the settlement presents an opportunity to cohesively
develop the Service Centre settlement, without extending the built limits of the settlement or incurring
any further into the surrounding countryside. There has been significant market interest in the site from
housing developers, which indicates strong demand for the delivery of the site to meet local housing
need in Carway. The accompanying Supporting Statement sets out the merits to delivering the site for
much needed housing.

Summary
To summarise the above:
 Candidate site ref: SR/023/003 ‘Land adj. Culla Road Roundabout (B4317), Carway’ was
submitted as part of the 2018 Call for Sites. It scores highly across all stages of the LPA’s
assessment process;
www.carneysweeney.co.uk
 Pre-application advice (ref: PRE/01319) notes the site lies within Flood Zone 3 in the emerging
TAN15. The site lies within Zone 3 for surface water and small watercourses flooding only (i.e.
not river or sea flooding), whereby development for housing is generally acceptable; in
accordance with TAN 15 (Jan 2023);
 Site specific assessments such as ecological surveys etc. can be provided as part of any future
proposals at the site, to ensure Biodiversity Net Gain is achieved. There are no insurmountable
site constraints identified at this stage. The site is readily deliverable;
 The proposed provision for 9,704 homes within the RLDP to meet an identified requirement for
8,822 homes at c.500 homes per year is considered insufficient and will compound
longstanding undersupply. The County should be targeting an increase in annual build rates,
in order to provide for the future population growth and meet local need;
 Based on current draft allocations the riverine SAC phosphate constraint will likely significantly
constrain the delivery of housing across the County over the emerging plan period, particularly
in Pencader and Llandovery. The Council’s previous conclusions on need should be thoroughly
reassessed. The proposed site at land adjacent to Culla Road Roundabout (ref: SR/023/003)
is unconstrained and immediately deliverable.
 The sustainability of this site location is established and confirmed by the Council’s own site
assessment process. Delivery of the site for housing will logically complete the Carway
settlement and meet clear and genuine local need. There has already been significant market
interest in the site by developers. The site should be allocated for housing within the RLDP.
We trust that the above/ enclosed representations will be taken into consideration as part of the future
progression of Carmarthenshire’s RLDP.
We look forward to being kept informed of the RDP’s progress and hearing from you in due course.
Should you require any further information or wish to discuss further please do not hesitate to contact
us.