SeC19/h1

No change to the Plan.

We are instructed by Mr. N. Morgans to make a formal representation with regards to the
above land and the Second Deposit Draft of the Carmarthenshire Replacement Local
Development Plan.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/163/010, seeking the allocation of their land for residential development within the
settlement limits of Whitland as part of the Replacement Local Development Plan.

The Candidate Site comprised two irregular-shaped field enclosures, together with a cluster
of farm outbuildings, set off the eastern flank of Trevaughan Road, to the southern edge of
Trevaughan, Whitland. Residential properties form the northern perimeter of the site, being
bungalows, which have rear garden perimeters sharing a common boundary with the site.
The opposite side of the B4328 is dominated by the “Riverlea” agricultural vehicles and
machinery wholesaler’s depot, which extends south to an equivalent point as the Candidate
Site’s southern field boundary.

The land therefore clearly represented a logical extension opportunity to the existing
settlement and its extents are illustrated by the red line below at Plan A.

Following due consideration, the Council included the northern field and outbuildings at Park
View as a Residential Allocation in its First Deposit Draft of the Local Development Plan,
published in January 2020. However, for reasons outlined by the Council in their current
submissions, a revised Second Deposit Local Development Plan has now been prepared
and published in January 2023. It is subject to public consultation. As part of the current
consultation process into the Second Deposit Local Development Plan, the Council have
again published a “Site Assessment Table” (January 2023), which provides details of the
Council’s analysis of each received Candidate Site submission. We note that our clients’ land was considered as part of this process and as a result the Authority concluded as follows: “Part of the site it be allocated with reference SeC19/h1. This is to allow small scale development within the town.”

Plan A- Location Plan of Candidate Site

As a result of the above, Plan B represents an extract of the Deposit LDP Proposals Map for Whitland, clearly now identifying part of our client’s land as a Residential Allocation (shaded brown) within the defined settlement limits:

Plan B – Extract from part of the Proposals Map for Trevaughan in Whitland

Our clients therefore welcome and SUPPORT the decision of the Authority to partly concur with the representations previously made in relation to a proportion of our clients’ land at Park View.

We can also confirm that the land continues to not face any ecological, flood risk related, highway, infrastructure or land ownership constraints that would restrict its ability to be delivered during the Plan period.

We therefore fully support the decision of the Authority to allocate the land for the purposes of Residential Development as part of the Carmarthenshire Replacement Local Development Plan.

Concerns relating to its inclusion

BROWNFIELD SITES -policy
In respect of all unused sites , particularly brown field but not ruling out Housing/retail sites , that have been vacant for more than eg. 25 years then the planning allocation should automatically be mixed use or white land. There is no reason such sites cannot be used for allotments, parking, leisure, innovative trendy housing even built with containers for example.

The former creamery site in Whitland SR/163/007 is an example of such central dereliction and a shameful waste of an area close to services that could have been useful to the town and surrounding areas. It is an eysore and affects visual amenity and the wellbeing of residents.
The inspector, as I understand, removed the lower part of the site from the development line due to a flood plain. Given that the reason for the great flood of 1986 in Whitland is rectified and there are further flood barriers this decision was unfortunate and the site could not even be used for allotments, community car parking, retail and even much needed Housing. Going forward if climate change may impact any parts of the site then it is up to the owners of such sites to provide the requisite studies to suit the proposed uses.
Whitland has excellent transport infrastructure and good work opportunities but needs something exciting doing with this disused site.


RURAL TRANSPORT
There is only a remote chance of rural buses that can be run economically and sustainably on a daily basis at times to suit people who would otherwise use a car.
Disused railway lines such as that was formerly in the UDP as a route from Whitland to Cardigan ( Cardi Bach ) should be protected as these routes were instrumental in the sustainibility and economic generation of rural hamlets. Following closure these villages en route became stagnant. Old railway routes use as pathways and cycle routes enables safe connections between communities and these can used by young people to prevent rural isolation and reliance on parental taxis.. With the increase in the use of electric bikes it ebables Community for less athletic persons as well as potential tourism. Cafes or local historic features along the routes enable rural enterprise supporting the circular economy.

WHITLAND TOWN CENTRE
This designated outline is inaccurate in my view as it omits various very longstanding retail units of half a century or more.see attached map for proposal as a matter of fact.


LOCAL CONCERN
SR/163/010 Residents are concerned about the velocity of the off flow from the hill above this development and indeed this velocity lifted tarmac off a bridge and it does cause localised flooding. The site lacks footways and any such development requires very careful management of downward water flows on both sides of this allocation in case homes here suffer from such velocity and mud spills from the hillside above as do current residences.




HOUSING
Rural needs are greatly restricted by the policies related to affordable Housing. There is a greater level of self employment in rural areas and to provide work life balance homes of sufficient size are resticted by WAG Policy. A home Office, utility area sufficient to manage outerwear from rural surroundings, workshop are essentials to manage rural living in a fast paced environment. Some young people do return after study or working away but much of this depends upon availibility of skilled employment and the possibility of creating a home for life and self employed or remote work in one unit. Affordibility of a larger build size is a restriction but does not take into account that the build may be incremental and if budget is restricted (according to figures presented for build size) then persons can complete the more expensive internal works as budget becomes available.
People (and animals) are healthier in well ventilated, well designed spaces.
Affordable homes generally do not have sufficient garden size as did the old council homes and Commercial estates, in my view, are too uniform. Whilst budgets can be restrictive there is no excuse for inadequate design.
There has not been a housing needs survey for this revision and reliance on the Housing register is not a reflection of the many aspirations of those who wish to return home to contribute to the Community raise families or retire on their family farms.
The same applies to rural enterprise which is essential to the circular economy. Supporting SMEs to thrive where they can find a niche keeps a rural area vibrant and innovative.
Land banking that is tied up in pension schemes perhaps is another issue that restricts potential from none allocated sites.
I recognise this may not be as concise or eloquent as other submissions but there seems to be a mismatch of understanding between urban and rural living needs.

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.

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.