Matters Arising Changes 2026

Insert the following text after paragraph 4.23 and Figure 4: Swansea Bay City Deal.

New Paragraph Numbers

Future Wales: National Plan 2040

Future Wales: National Plan 2040 is set in the context of a vision that will help deliver sustainable places across Wales by 2040, by supporting placemaking and ensuring that development is directed to the right places, making the best use of resources, creating and sustaining accessible healthy communities, protecting our environment and supporting prosperity for all. The Revised LDP aligns with the provisions of Future Wales and its 11 outcomes (as set out in Chapter 3 of Future Wales) and supports its role in driving sustainable growth and combating climate change by guiding strategic development over the next 20 years.

The policies and provisions of the Revised LDP form the framework for implementing and delivering the vision and its strategic objectives, as well as the corporate and strategic priorities of the Council. These policies and provisions include the embedding of sustainable development principles in the Revised LDP, ensuring it makes a positive contribution towards aligning with the content of Future Wales. Consequently, it supports the delivery of the 11 outcomes including sustainable growth, sustainable management of natural resources and reduced pollution, the Welsh language, biodiverse and connected ecosystems and vibrant rural places with access to homes, jobs and services etc.

There are various provisions in Future Wales that directly relate to Carmarthenshire, with Llanelli and Ammanford/Cross Hands falling within the broadly defined Swansea Bay National Growth Areas. Policy 28 of Future Wales identifies the Swansea Bay and Llanelli National Growth Area (NGA) as an area that, will be the main focus for growth and investment in the South West Region. The LDP recognises this as a focus for growth and investment through the identification of its settlements within the top tier of the settlement hierarchy.

Similarly, Carmarthen is identified as a Regional Growth Centre and Newcastle Emlyn forms part of the mid-Wales Regional Growth Area in accordance with (Policy 25).

Future Wales makes provision for managed growth in these area which relates to their important sub-regional functions and strong links across the South West Wales region. It also identifies the need: for the management of natural resources, flooding and the protection and enhancement of areas of environmental and landscape importance and that they should inform strategic decisions on locations for growth and new infrastructure; decarbonising society and responding to the threats of the climate emergency should be central to all regional planning; and recognises the potential Carmarthenshire has of this location for new renewable and low carbon energy-related development, innovation and investment.

The role of placemaking flows through national planning policy and the Revised LDP embeds it as a central component within it. Future Wales, as part of this agenda, also sets out a number of strategic placemaking principles, including enabling urban areas to support ecosystem resilience as well as increasing the population density of towns and cities which are intended to create sustainable and socially inclusive places.

Insert the following text after the change proposed above in response to AP1/1.

New Paragraph Numbers

Strategic Development Plans (SDP)

The SDP for the South West Region is defined by the administrative area of the Corporate Joint Committee (CJC) and set out in Future Wales. Formally constituted in January 2022, the CJC for South West Wales was created through the provisions of the Local Government and Elections (Wales) Act 2021. The Committee is made up of representation from Carmarthenshire Council, Neath Port Talbot Council, Pembrokeshire Council and Swansea Council, as well as the Bannau Brycheiniog National Park Authority and the Pembrokeshire Coast National Park Authority.

The Committee has a pivotal strategic role within the region in improving regional planning, the coordination and delivery of transport, land use planning, economic development and energy. This role reflects the wider focus on regional working and collaboration across what is a diverse region, consisting of extensive rural areas and urban areas, all of which are set in and around some of Wales’s most important natural and built historic environments.

Future Wales requires SDPs to accord with the requirements of Policy 19. In this respect, they must consider and respond to the national sustainable placemaking outcomes set out in Future Wales which, in combination, seek to create a more sustainable, healthy, equitable and fairer Wales. SDPs will be expected to demonstrate how the spatial framework they develop, and the key choices they make, will contribute to delivering the Outcomes. The future role of SDPs and the relationship with the Revised LDP has been a consideration in the development of this Plan, with regional collaboration as an important component. In this regard, specific reference is made to the spatial definition of the NGA prepared jointly by the authorities across the region. This has been used to inform the provisions of the Revised LDP and will form part of the evidence for the forthcoming SDP. It demonstrates the aligning of the spatial strategies and settlement hierarchies of the Revised LDP and the SDP with the provisions of Future Wales and its outcomes.

Carmarthenshire has, and will continue to, work collaboratively with authorities across the South West Wales region, and those within the mid Wales region, on the future provisions and content of the SDP. Whilst the SDP is in its initial stages, the Council has worked proactively with neighbouring authorities on the governance arrangements and formative requirements for its preparation. The Council has also developed shared evidence which will support the preparation and delivery of the Revised LDP and will help to inform and underpin the content of a future SDP. This includes evidence in relation to Development Viability, Local Housing Market Assessments, Population and Household projections, the Swansea Bay and Llanelli National Growth Area Definition Project, Two County Economic Study for Carmarthenshire and Pembrokeshire, and the South West Wales Stage 1 Strategic Flood Consequence Assessment.

Amend Strategic Objective SO4 as follows:

Amend Policy SP1 to reflect the change in housing numbers as set out under MAC 011. As well as including cross reference to Policy SP3.

Strategic Policy – SP1: Strategic Growth

The LDP will provide for the future growth of a sustainable economy and housing requirement through the provision of:

1. 9,814 new homes to meet the identified housing requirement of 8,822.
2. A minimum of 71.21ha of allocated employment land.

The focus on regeneration and growth reflects the Council's core strategic ambitions with development distributed in a sustainable manner consistent with the spatial strategy and settlement framework (Policy SP3).

Amend Policy SG1 to explain the proposed use and quantum of development.

SG1: Regeneration and Mixed-Use Sites

New paragraph after para 11.16

New paragraph number: Reference is made to Policy CCH4 to ensure that there is no adverse effect on the integrity of nutrient sensitive protected sites.

Delete Policy SG2 - Reserve Sites and its reasoned justification from the Plan, with consequential amendments to Policy SG3 – Pembrey Peninsula taking its place as the new Policy SG2.

In addition, all other subsequent cross referencing amended accordingly throughout the Plan.

Amend Policy SP2 as follows:

Strategic Policy – SP 2: Retail and Town Centres

Proposals for retail and other town centre use development will be considered in accordance with the following retail hierarchy and the provisions below:

1. Proposals for retail and other appropriate town centre uses within the Carmarthen town centre boundary (including leisure, civic, cultural, education, business (including B1(a) offices), health and residential (on upper floors)) which support the growth of Carmarthen as a sub-regional retail town centre will be permitted where they maintain and enhance the vitality, viability and attractiveness of Carmarthen Town Centre. Proposals should not:
   1. undermine the retail function of the centre, or have a detrimental effect upon the vitality or viability of the area; and
   2. create a concentration of non-retail ground floor frontage detrimental to the retail character and function of the area.
2. The vitality, viability and attractiveness of ourthe retail centres will be maintained and enhanced along with the range of their existing uses, including local markets. Proposals within the town centre boundaries, which widen the range of uses and encourage convenient and accessible shopping, services, public services and facilities, and employment/business opportunities will be supported.

c) Proposals for convenience stores outside of the defined town centre boundary will be subject to:

1. The submission of an impact assessment to demonstrate that the proposal would not have an adverse effect on the vitality and viability of the existing retail centre;
2. Evidence of a sequential test having been applied to the site selection;
3. Evidence of quantitative and qualitative need for the development; and,
4. Evidence of the site’s accessibility to sustainable modes of transport.

dc) Proposals for retail and other town centre uses within the town centre boundary will be supported which, where applicable:

1. Provide opportunities for independent retail and commercial sectors;
2. Support and do not undermine the continued retail function of the high and mid order town centres;
3. Promote and diversify the education, leisure, cultural facilities, and the night-time economy;
4. Provide for the creation of quality public spaces and environmental improvements including the preservation and enhancement of the distinctive local character of the historic built and natural environment, and a commitment to high quality design;
5. Improve places for pedestrians, cyclists and people with health conditions or impairments including enhancing public transport, accessibility, access to public facilities and conveniences, car parking, signage, and the street scene; and,
6. Protect, enhance, and integrate with the Green and Blue Infrastructure network.

d) Outside of the above town centre boundaries the following forms of retail provision and other town centre uses may be permitted in accordance with national policy:

1. New non-food retail warehouse units (including garden centres, car showrooms and ancillary supporting facilities), appropriate leisure facilities on designated retail parks and trade centre uses on employment sites, where they are supported by the relevant evidence. noted below:
   1. an impact assessment demonstrating that the proposal would not cause harm to established town centres;
   2. evidence that a sequential approach has been undertaken indicating that there are no suitable available and sustainable sites in locations within or immediately adjoining defined town centres;
   3. evidence of quantitative, qualitative and/or other relevant need for the development;
   4. evidence of the site’s accessibility to sustainable modes of transport.
2. Proposals for small local convenience shopping facilities in rural and urban areas within the development limits where they are of a scale appropriate to that settlement. Rural retail proposals will be considered in accordance with policy RTC2.

Amend paragraph 11.34 as follows:

Insert new paragraph after 11.40:

New paragraph number

The Retail Study indicates that there is no capacity for additional comparison goods retail floorspace in Carmarthenshire over the Plan period, and that proposals for additional comparison floorspace will therefore need to demonstrate that there is a need for the additional provision. Similarly, the Retail Study indicates that there is an oversupply of convenience floorspace in Carmarthenshire, however, this varies across the County and the Study suggests that there is some capacity for additional convenience floorspace in Zone 1 – Carmarthen and Zone 3 – Ammanford Cross Hands, as identified in the Study. Notwithstanding this, proposals for convenience floorspace will need to demonstrate that there is a retail need for additional convenience floorspace in accordance with Technical Advice Note 4 Retail and Commercial Development (2016).

Amend paragraph 11.43 as follows to define small local convenience stores:

Provision outside the sub-regional and mid order centres, including local village shops, make an important contribution to the retail function of Carmarthenshire. In this respect, those centres fulfilling a convenience retail need and smaller scale day to day shopping need provide diversity consistent with the objectives of sustaining communities and minimising the need to travel. These settlements and their retail offer can complement the established retail function of those higher up the hierarchy as well as contributing to the implementation of the Plan’s Strategy. Proposals for convenience retail outside of the town centre boundary in such centres may be required to appropriately evidence the retail need to ensure the retailing activities within the town centres are not undermined. Their scale should be appropriate and proportionate to the relative settlement but generally should not exceed 200 square metres gross of floorspace. Proposals which exceed this threshold should demonstrate that there is a need for the level of retail floorspace identified.

New paragraph to be inserted after para 11.55

New paragraph: Reference is made to Policy CCH4 to ensure that there is no adverse effect on the integrity of nutrient sensitive protected sites

Amend Policy RTC1 as follows:

RTC1: Protection of Local Shops and Facilities

Proposals which would result in the loss of a local shop, service or community facility (including Public Houses) outside of the Town Centres identified within Strategic Policy SP2 will only be permitted where:

1. Its loss would not be detrimental to the social and economic fabric of the community;
2. There is another shop or service of a similar compatible use available for customers within the settlement or within a convenient walking distance.

In the absence of an alternative provision, proposals resulting in the loss of the local shop, or service will only be permitted where all reasonable attempts have been made to marketit can be demonstrated that the business for sale or let has been marketed for over a continuous 12 month period and have failed.

To ensure the appropriate reference is had to the provisions of Policy CCH4 it is proposed to add the following sentence to the reasoned justification of Policy RTC2 after para 11.66

New paragraph number: Reference is made to Policy CCH4 to ensure that there is no adverse effect on the integrity of nutrient sensitive protected sites.

Amend policy SD1 as follows:

SD1: Development Limits

Development Llimits are defined on the proposals map for those settlements identified as Principal Centres, Service Centres and Sustainable Villages within Strategic Policy SP3.

Proposals within defined Ddevelopment Llimits will be permitted, subject to policies and proposals of this Plan, national policies, and other material planning considerations. In rural settlements and outside defined development limits there will be a presumption against inappropriate development.

New Paragraph Number: Development limits are a key mechanism for helping to manage future growth by defining the area within which development would normally be permitted, subject to material planning considerations. The development limits have been applied to the Principal Centres, Service Centres and Sustainable Villages as defined in Strategic Policy SP3: Sustainable Distribution – Settlement Framework.

11.75In preparing this Plan, development limits have been defined across all settlements within Tiers 1, 2, and 3, in order to:

• Prevent inappropriate development in the countryside and provide certainty and clarity as to where exceptions proposals (adjacent to limits) may be considered appropriate;
• Prevent coalescence of settlements (or separate parts of the same settlement), unacceptable ribbon development or a fragmented development;
• Identify those areas within which development proposals would be permitted (see above); and,
• Promote effective and appropriate use of land concentrating growth within defined settlements.

New Paragraph Number: In rural settlements (Tier 4) and outside the defined development limits proposals for development will be strictly controlled and will only be supported in accordance with Plan policies, and/or if a countryside location is deemed essential given the nature of the proposal, in-line with National Planning Policy and Guidance.

New Paragraph Number: The presumption against any inappropriate proposals outside defined settlement boundaries provides clarity as to the appropriate locations for future development and will ensure growth is strategically managed. The consideration of potentially appropriate housing beyond settlement boundaries will be undertaken having regard to the policies of the plan (specific reference should be had to AHOM2) and National Planning Policy and Guidance.

New Paragraph Number: National Planning Policy and Guidance and the policies of this Plan recognise that local employment opportunities within rural settlements are important to sustain and improve communities. Reference is made to Policy EME 4 which makes provision for appropriate employment proposals outside the development limits, as well as EME2 in relation to the expansion of existing rural enterprises. In line with National Planning Policy it recognises that small-scale enterprises have a vital role to play in the rural economy and contribute to both local and national competitiveness and prosperity. In this respect many commercial and light manufacturing activities can be appropriately located in rural areas without causing unacceptable disturbance or other adverse effects allowing for diversification of the rural economy. This is particularly relevant to the County’s rural areas where the Plan supports rural employment and enterprises.

11.76 Not all land on a Proposals Map and Inset Maps is identified for a particular development, or the subject of a specific policy. Significant areas of land can appear as unannotated land in the Plan. Proposals for development will be considered on their individual merits against the provisions of this LDP, and other material considerations.

New paragraph number: Reference is made to Policy CCH4 to ensure that there is no adverse effect on the integrity of nutrient sensitive protected sites.

Amend first paragraph of Policy SP4 as follows:

In order to ensure the overall housing requirement of 8,822 homes for the plan period is met, provision is made for 9,7049,814 new homes in accordance with the settlement framework (Policy SP3) in order to promote the creation and enhancement of sustainable communities.

Consequential amendment to para 9.57, first bullet point:

• Provide for 9,704 9,814 new homes to deliver a housing requirement of 8,822 homes;

Amend paragraph 11.79 as follows:

11.79This Plan factors in a number of housing supply components to meet this housing need, together with flexibility (uplift) to ensure that the overall aim of the strategic policy to provide new homes is met. The housing supply provides a flexibility allowance of 11.24% The housing supply and is made up of the following components:

• Housing Allocations (5+ homes)
• o Land bank Commitments
• o Completed Dwellings
• Windfall Allowance
• o Small Site Component (less than 5 homes)
• o Windfall Component (5+ Homes)
• Flexibility (+10%)

Consequential changes to Paragraph 9.11:

9.11In delivering the number of homes set out above, this Preferred Strategy includes an additional flexibility as part of its supply (uplift) to ensure the delivery of sustainable growth and to overcome any potential unforeseen deliverability issues. A 11.24% 10% flexibility allowance through a further 992 882 homes, is included. This equates to a housing supply of 9,814 9,704 dwellings to deliver the 8,822 homes.

Consequential changes to the monitoring framework:

Amend HOM1 table as follows (note that the site references will be subject to minor editorial change to ensure consistent and consecutive numbering reflecting the deletion of sites identified as commitments and the inclusion of additional sites) as well the reasoned justification.

Include annotation (💧) to identify the following sites which have an element of flood risk.

PrC1/h12 💧 - Castell Pigyn Road, Abergwili

PrC1/MU1 💧 - West Carmarthen

PrC2/SS1💧 - Pentre Awel

SeC7/h3 💧 - Golwg Yr Afon

Consequential amendments to the proposals map as well as the interactive map to include 💧 annotating flood risk next to site reference and to amend interactive map to include reference to flood risk policies.

Include new paragraph after para 11.87:

New paragraph number: Reference is made to Policy CCH4 to ensure that there is no adverse effect on the integrity of nutrient sensitive protected sites.

Proposals map amended to include annotation for sites that are subject to flood risk:

Amend policy HOM2 as follows:

HOM2: Housing within Development Limits

Proposals for housing developments on unallocated sites within the development limits of a defined settlement in Tiers 1, 2 and 3 of the Settlement Framework (Policy SP3) will be permitted, provided they are in accordance with the principles of the Plan’s strategy, policies and proposals.

11.88Sites capable of accommodating five or more dwellings feature as allocated housing sites in the Plan (refer to Policy HOM1). However, within the development limits of defined settlements there may be opportunities for development on unallocated sites. Within the settlement hierarchy, land that has not been allocated is referred to as a windfall site in relation to housing development. Proposals should reflect the character of the area and be compatible with the provisions of the Plan and, in particular, the principles of sustainable development and placemaking set out in Policy PSD1.

New paragraph after para 11.88:

New paragraph number: Reference is made to Policy CCH4 to ensure that there is no adverse effect on the integrity of nutrient sensitive protected sites.

Amend Policy HOM3 to the following

HOM3: Homes in Rural Villages

In those settlements identified as rural villages under Policy SP3, proposals for small scale developments of 1 to 4 dwellings will be permitted provided that: will be permitted for the following:

1. The scale and design of the proposed development is appropriate to the scale, form and character of the settlement, taking into account the cumulative impact of incremental development; and
2. The scale and nature of the development will maintain or enhance the vitality of the rural community within the settlement; and
3. The proposed development consists of, and represents a:
   1. minor infill of a small gap between the existing built form; or
   2. logical extensions and/or rounding off, of the development pattern where they adjoin the boundary of one property which forms part of the rural village group. All proposals which adjoin a group (as opposed to infill sites) will be required to demonstrate the following:
      1. there is an existing physical or visual feature which provides a boundary for the group - reducing pressure for unacceptable ribbon development or rural sprawl; or
      2. where such a feature does not exist, there should be potential for such a feature to be provided so long as it is in character with the scale and appearance of the group; or
   3. Conversion or the sub-division of large dwellings.

Proposals will not be permitted where:

4. they are in open fields adjoining a group which have no physical features to provide containment; and / or
5. they are located beyond clear physical features which form strong boundaries for a group (e.g. main roads, substantial tree belts, rivers etc.)

Proposals for more than 4 dwellings will not be considered appropriate except where they relate to 100% affordable housing schemes and strictly accord with the policy criteria listed above.

• minor infill of a small gap between the existing built form; or,
• logical extensions and/or rounding off of the development pattern that fits in with the character of the village form and landscape; or
• conversion or the sub-division of large dwellings.

Such proposals will be subject to other detailed planning considerations set out within LDP policies.

Reference made to the guidance on acceptable plots in the County’s rural villages (see below).

Proposals which exceed the 10% cap above the number of existing homes in the settlement, as at the LDP base date, will not be permitted except where they conform to Policy AHOM1 in relation to the provision of affordable homes.

11.89The settlement framework for the Plan area identified in Strategic Policy SP3 recognises and reflects the area’s diversity and that of its communities. In identifying the Rural Villages, the Plan seeks to make provision for those settlements which make an important contribution within their community and offer opportunities for small scale and appropriate new homes within rural settings.

11.90This part of the Plan’s rural policy framework seeks to establish a flexible but controlled approach to the delivery of new homes within those settlements. The Plan utilises a criteria-based assessment to define small scale housing opportunities in rural villages and to meet the need for new homes in rural parts of Carmarthenshire at a scale and at locations which maintain the essential character of the countryside. Where settlements defined within the policy come under significant pressure from the cumulative impact of housing development, the Council will prepare a capacity assessment to determine any potential for further rural housing growth within that settlement.

11.91In order to reflect the rural character and to prevent unacceptable and potentially detrimental levels of growth, a cap of 10% over and above the number of existing homes, as of the base date of the Plan in the settlement will be allowed.

11.92Further guidance in the form of SPG will be published to support the interpretation and application of the above and the policy. The guidance will form part of a suite of SPG to support with the design and siting considerations in general and will enable proposals to effectively integrate with and contribute to the development of cohesive and sustainable communities.

New paragraph number: Reference is made to Policy CCH4 to ensure that there is no adverse effect on the integrity of nutrient sensitive protected sites.

Guidance on Acceptable Plots

1.  Infill sites within these rural villages will take priority over other locations;
2.  Where appropriate, sites adjoining a rural village are also acceptable. Such sites will be required to adjoin the boundary of one property which forms part of the rural village group. All proposals which adjoin a group (as opposed to infill sites) will be required to demonstrate the following:
   • there is an existing physical or visual feature which provides a boundary for the group - reducing pressure for unacceptable ribbon development or rural sprawl;
   • where such a feature does not exist, there should be potential for such a feature to be provided so long as it is in character with the scale and appearance of the group;
3. Proposals located in open fields adjoining a group, which have no physical features to provide containment will not be considered acceptable; 4. Proposals which are located beyond clear physical features which form strong boundaries for a group (e.g. main roads, substantial tree belts, rivers etc.) will not be considered acceptable
4. Proposals which are located beyond clear physical features which form strong boundaries for a group (e.g. main roads, substantial tree belts, rivers etc.) will not be considered acceptable

To amend policy the reasoned justification of HOM4, to ensure the appropriate reference is had to the provisions of Policy CCH4. New paragraph after para 11.97:

New paragraph number: Reference is made to Policy CCH4 to ensure that there is no adverse effect on the integrity of nutrient sensitive protected sites.

To amend policy the reasoned justification of HOM5, to ensure the appropriate reference is had to the provisions of Policy CCH4. New paragraph after para 11.101:

New paragraph number: Reference is made to Policy CCH4 to ensure that there is no adverse effect on the integrity of nutrient sensitive protected sites.

Amend policy HOM6 as follows:

HOM6: Specialist Housing

Proposals for new care home developments and extensions to established specialist housing facilities will be permitted within or adjoining the development limits of defined existing settlements (Policy SP3) where:

1. It reflects the needs of the proposed occupants in respect of their safe and convenient access to shops, services, community facilities and public transport or active travel routes; and,
2. It provides a suitable and appropriate quality, design, and type of accommodation as well as the level of support and care for the intended occupiers

Proposals for specialist housing outside and not adjoining the defined development limits will only be permitted if it can be demonstrated that they are needed, viable and sustainable and where:

3. It is ancillary to an existing care home and not disproportionate to it in scale; or,
4. It represents the appropriate conversion of an existing property, which is suitable to the needs of the proposed occupants and accords with both criterion a) and b) above.

New paragraph to be added after para 11.103:

New paragraph number: Reference is made to Policy CCH4 to ensure that there is no adverse effect on the integrity of nutrient sensitive protected sites.

Amend Policy HOM7 as follows:

HOM7: Renovation of Derelict or Abandoned Dwellings

Proposals for the renovation of derelict or abandoned dwellings outside the Development Limits of a defined settlement (Policy SP3) will be permitted where:

a) It can be demonstrated that a significant part of the original structure is physically sound and substantially intact requiring only a limited amount of structural remedial works;

b) The building demonstrates and retains sufficient quality of architectural features and traditional materials with no significant loss of the character and integrity of the original structure;

c) There are no adverse effects on the setting or integrity of the historic environment.

In exceptional instances where it can be demonstrated that the original dwelling played a recognised and significant role in the history, culture, and development of Carmarthenshire, the use of photographic or documentary evidence may be accepted as a means to illustrate the original details of the dwelling.

New paragraph to be added after para 11.105:

New paragraph number: Reference is made to Policy CCH4 to ensure that there is no adverse effect on the integrity of nutrient sensitive protected sites.

Amend Policy HOM8 as follows:

HOM8: Residential Caravans

Proposals for temporary residential caravans will be permitted where:

a) The caravan is required to house an essential worker, in agriculture, forestry or other appropriate employment undertaking who must live on site rather than in a nearby settlement; or,

b) The caravan is required in conjunction with the construction of a single dwelling on a self-build plot, or during the construction of a replacement dwelling; and,

c) The caravan or mobile home will be located close to other buildings where possible and will not cause significant access, parking, infrastructural or amenity problems; and,

d) They will not have an unacceptable adverse impact on wider landscape or nature conservation objectives.

New paragraph to be added after para 11.106:

New paragraph number: Reference is made to Policy CCH4 to ensure that there is no adverse effect on the integrity of nutrient sensitive protected sites.

To amend policy the reasoned justification of HOM9, to ensure the appropriate reference is had to the provisions of Policy CCH4. New paragraph after para 11.111:

New paragraph number: Reference is made to Policy CCH4 to ensure that there is no adverse effect on the integrity of nutrient sensitive protected sites.

Amend Policy SP5 and its supporting reasoned justification to the following:

Strategic Policy – SP 5: Affordable Homes Strategy

The Plan will maximise the delivery of affordable homes up to 2033 through the provision of a minimum target of 2,111 1,900affordable homes. This will support the development and enhancement of sustainable, balanced communities.

11.116 Whilst the LDP and planning system seeks to support the delivery of affordable homes, it is only one of few mechanisms used to meet this need. This is reflected in the Council’s Affordable Housing Delivery Plan which sets out a five-year vision for delivering affordable housing. The LDP’s contribution to the target is set out in SP5 through:

• On-site provision of affordable housing as a percentage of the overall development, or on sites acquired by social housing providers;
• Off-site affordable housing in lieu of on-site provision;
• Commuted sum contributions to support the delivery of affordable housing; and
• Local Need housing.

New paragraph Number: In combining all methods of affordable housing contributions through the planning system the target set out in Policy SP5 is the starting point for the provision of Affordable Housing within the county, with the Plan seeking to maximise the provision where applicable.

11.117 Reference is also made to the Carmarthenshire Rural Needs Study 2019 which identifies a higher proportion of larger dwellings within the rural areas that contribute to higher house prices^52. The LDP looks to support the growth of more affordable units within the rural communities to promote development for first time buyers or those in low-income households.

Amendment to Policy AHOM1:

AHOM1: Provision of Affordable Homes

On-site Contributions

An on-site contribution towards affordable housing will be required on all market housing allocations and windfall sites of 10 or more homes to meet the affordable housing target set out in Policy SP5. The percentage target level for affordable housing is based on the scale of development:

a) sites comprising 10 – 19 homes will be required to provide an affordable housing contribution of 10%;

b) sites comprising 20 - 50 homes will be required to provide an affordable housing contribution of 12%;

c) sites comprising 51 – 100 homes will be required to provide an affordable housing contribution of 20%;

d) sites of 101 homes or more will be required to provide an affordable housing contribution of 25%.

The affordable housing target percentage noted is a target to be used as a starting point for affordable housing negotiations.

Where adjacent and related residential proposals result in combined numbers meeting or exceeding the above thresholds, the Council will seek an element of affordable housing based on applying the above target percentages to the aggregate number of dwellings.

Proposals will be required to ensure that the dwelling remains affordable for all subsequent occupants in perpetuity.

Commuted Sums

A commuted sum towards affordable housing will be required from proposals comprising 1 – 9 dwellings. Commuted sum charges will be based on floor space (cost per sq.m).

Proposals for single dwellings categorised as 3-bed, 4-person dwellings or smaller, and less than 88 square metres will be exempt.

Where the above requirements cannot be achieved due to their impacts upon a proposal's financial viability, a variation may be agreed on a case-by-case basis.

11.118 Policies AHOM1 and AHOM2 aim to assist the Council to meet its housing need and in particular to deliver the affordable housing need identified in Policy HOM1.

11.119 The policy sets out the affordable housing contributions to be provided. The requirements of the policy reflect the findings of the Revised LDP’s ongoing Viability Study and takes into consideration other factors such as the LHMA, past delivery rates and the need for flexibility to allow for variances between sites.

11.120 The Policy’s requirements for on-site contributions apply to all proposed housing developments located within settlement boundaries with a capacity to deliver a net increase of 10 dwellings or more new homes. Those sites which fall outside of the settlement boundaries will be subject to the requirements of Policy AHOM2.

New paragraph number: The affordable housing target percentage noted within the policy is a target to be used as a starting point for affordable housing negotiations.

New paragraph number: Where adjacent and related residential proposals result in combined numbers meeting or exceeding the above thresholds, the Council will seek an element of affordable housing based on applying the above target percentages to the aggregate number of dwellings.

New paragraph number: Proposals will be required to ensure that the dwelling remains affordable for all subsequent occupants in perpetuity.

11.121 The policy’s requirements for commuted sums apply to all proposed open market proposals resulting in a net increase of 1 – 9 new dwellings, with the exception of single dwellings which are categorised as 3-bed, 4-person homes and not exceeding 88 square metres in internal, habitable floor space.

11.122 The mix of dwelling sizes, types and tenure required to be provided on each site will vary according to the specific needs of the locality at the time of application. This will need to take into consideration the latest information on housing need from the LHMA, alongside any relevant local information such as the Council’s waiting list and any recently delivered affordable housing units within the area.

New paragraph: Reference is made to Policy CCH4 to ensure that there is no adverse effect on the integrity of nutrient sensitive protected sites.

Amend Policy AHOM2 as follows:

AHOM2: Affordable Housing- Exceptions Sites

Proposals for 100% affordable housing development on sites adjoining the Ddevelopment Llimits of defined settlements (Tiers 1-3 in Policy SP3), and in those settlements identified as Rural Villages (Tier 4) will, in exceptional circumstancesbe permitted where it is to meet a genuine identified local need (as defined within the Glossary of Terms) and where:

1. The site represents a logical extension to the development limits and is of a scale appropriate, and in keeping with the character of the settlement;
2. The benefits of the initial affordability will be retained for all subsequent occupants;
3. It is of a size, scale and design compatible with an affordable dwelling and available to low or moderate income groups;
4. There are no market housing schemes within the settlement, or projected to be available which include a requirement for affordable housing.

New paragraph number: All new affordable local need housing will be restricted to those who can demonstrate they have a need to live in the Town and Community Council area and are in Affordable Housing Need. Reference is drawn to the Glossary of Terms which considers the Local Need Eligibility, and the criteria which must be satisfied to permit local need housing.

11.123 The granting of planning permission will be subject to conditions and planning obligations which ensure the affordable housing remains available to meet future local affordable housing needs.

11.124 An affordable dwelling must be compatible with WG’s Design Quality Requirement standards to limit its size, scale and design to ensure that the dwelling falls within a reasonable and acceptable affordable dwelling cost for future occupants. In exceptional circumstances, a A departure from these standards may be considered appropriate where they are to meet the occupant’s needs and are clearly evidenced and justified.

New paragraph: Reference is made to Policy CCH4 to ensure that there is no adverse effect on the integrity of nutrient sensitive protected sites.

Amend Policy SP7 as follows:

Strategic Policy – SP 7: Employment and the Economy

Sufficient lLand has been allocated for the provision of 71.21 hectares of employment provision for the Plan period in accordance with the Plan’s Settlement Framework (Policy SP3) and sustainability principles.

The sustainable approach to the provision of employment land reflects the following:

1)a) The allocation and delivery of:

a)1. Pentre Awel, Llanelli and

b)2. Yr Egin – Creative Digital Cluster, Carmarthen;

2.b) Allocating employment land in sustainable location which accords with the sustainability principles of the Plan;

3.c) Safeguard existing employment sites – recognising their contribution as part of the employment portfolio in meeting ongoing need;

4.d) Supporting small scale sustainable employment developments and enterprises in lower tiered settlements.

5.e) Ensuring support is provided to entrepreneurship as part of the creation of a diverse and growing economy;

6. f) Allow appropriate small scale employment opportunities and rural enterprises in the countryside to support rural communities and to deliver a diverse and sustainable rural economy.

Insert new paragraph relating to Pentre Awel before paragraph 11.140.

In considering the allocation and delivery of employment land within Pentre Awel, not all employment activities relate to B class uses and consequently it does not form part of the 71.21ha of employment land provision set out in Policy SP7.

Deletion of paragraphs 11.142 – 11.145 with the inclusion of the new reasoned justification

11.142 The Council has undertaken evidence gathering to provide an understanding of the future employment need notably around the Welsh Government’s nine priority sectors.56 Further evidence has been prepared in conjunction with Pembrokeshire County Council to establish quantitative analysis of forecast demand for employment sites at the larger than local level. This Two County Study was supplemented by market and employer evidence in relation to market demand. In addition, work has been undertaken in relation to the links between equating the levels of employment land and jobs with the requirement for new homes growth for the County.

11.143 The Two County Study seeks to achieve a balance between fulfilling the requirements of Technical Advice Note 23 on Economic Development (February 2014), whilst placing a strong emphasis on flexibility, realism of sector growth and ability to meet demand at a regional scale.

11.144 TAN 23 considers that ‘land provision targets may be higher than anticipated demand, to allow for the chance to meet demand. The Practice Guidance to the TAN (August 2015) considers that, where justified, land provision targets maybe higher than anticipated demand, to allow for the chance that the assessments are too low and to ensure that no opportunities are missed. In acknowledging the importance of not solely relying on employment forecasts when identifying a portfolio of employment land, the Two County Study emphasises the demand and confidence of indigenous businesses to remain and grow, and a desire by stakeholders to preserve locational advantages and strategic assets for future growth.

11.145 In recognition of the above, the Two County Study has identified a portfolio of sites within the study area which are considered to offer strategic benefits and opportunity for growth and job creation.

Evidence for future employment need

New paragraph numbers

The Council has undertaken evidence gathering to provide an understanding of the future employment need within the County and notably around the Welsh Government’s nine priority sectors. Two pieces of evidence have been produced which include the Housing and Economic Growth Report (November 2022), and a Two Counties Study which has been prepared in conjunction with Pembrokeshire County Council.

Strategic Policy SP7: Employment and the Economy sets the framework to enable the delivery of a balanced level of employment land to accommodate the new jobs and identified need through the Two County Economic Study for Pembrokeshire and Carmarthenshire and the Housing and Economic Growth Report.

The Two County Study established quantitative analysis of forecast demand for employment sites at the larger than local level and was supplemented by market and employer evidence in relation to market demand. The Housing and Economic Growth Report further considered the links between equating the levels of employment land and jobs with the requirement for new homes growth for the County.

The Revised LDP’s background evidence provides the narrative for the relationship between housing growth, job creation and employment land provision. In extrapolating data from the demographical modelling, it suggests that the preferred scenario of 8,822 dwellings could accommodate 276 new jobs per year, which would not support fully the Experian forecast of 354 jobs per year. To achieve this, it would require a more pronounced labour force behavioural change within the County; however, the Plan seeks to consider several factors in determining a level of sustainable growth.

The WG’s Practice Guidance - Building an Economic Development Evidence Base to Support a Local Development Plan considers that where justified, land provision targets may be higher than anticipated demand, to allow for the chance that the assessments are too low and to ensure that no opportunities are missed. They should also allow for flexibility, competition, and choice. However, persistent oversupply of employment land may cause harm where the planned land supply exceeds demand, so that allocated employment sites remain vacant for long periods and frustrate development for other land uses.

The Revised LDP allocates 71.21 hectares of employment land which could provide an estimated 6,652 jobs, and whilst it is recognised that the homes to jobs calculation, and job creation to employment land provision does not align with the Revised LDP it must be noted that there is not an exact and direct relationship between housing and jobs, and thus any relationship can only be read as indicative.

It is also important to note that the level of new homes must be deliverable and evidenced. In this regard any increase in new homes to correspond with the potential jobs created through new employment allocations would result in an undeliverable over-provision of new housing within the County.

Nevertheless, the Housing and Economic Growth Report assessed the patterns of commuting from the 2011 Census which identified a commuting ratio of 1.09, indicating a net outflow of commuters from Carmarthenshire. The Plan, through the allocation of 71.21ha, seeks to re-balance the commuting ratio to reduce the outflow of Carmarthenshire’s residents to work and to promote investment and sustainable forms of growth within the County.

The scale of employment land identified within the Plan ensures flexibility and deliverability and reflects the analysis set out within the Two County Study and the Housing and Economic Growth Report. Its importance is to support the investment and ambition of Carmarthenshire’s strategic regeneration plan and other economic growth strategies as well as the Swansea Bay City Deal and South West Wales Regional Economic Delivery Report.

EME1: Employment- Safeguarding of Employment Sites

Sites identified for employment purposes through policy SP7 and existing employment sites will be safeguarded for such uses (B1, B2, B8 and those identified through relevant policy provisions).

Exceptionally, pProposals which result in their loss will only be permitted where it can be demonstrated that:

a.a) The site or premises is no longer required or suitable for employment use;

b.b) The proposed use could not reasonably be located elsewhere in accordance with the policies of this Plan;

c.c) There is sufficient quantity, quality and variety of employment land or premises that can be brought forward to meet the employment needs of the County and the local area;

d.d) There are no economically viable industrial or business employment uses for the site and premises;

e.e) An employment use is incompatible with adjoining/surrounding uses; and

f.f) Where applicable the proposed uses are complimentary to the primary employment use of the surrounding area and will not cause an unacceptable impact on the operations of existing businesses.

Amend paragraph 11.153 as follows:

11.153 This policy seeks to ensure that existing employment sites are protected from alternative (non-B class) uses. In order to maintain an adequate supply of employment land which provides for a range and choice of potential uses, this policy seeks to protect defined employment areas from non-employment uses which should be in better and potentially more appropriate locations. A schedule of existing employment sites is provided in Appendix 12 and shown on the Proposals Map. Proposals for alternative (non-B) uses will need to justify why the site or premises is no longer required (for economic reasons) or suitable (become inappropriate for the location) for employment use. In terms of economic reasons, in the absence of an alternative provision, proposals resulting in the loss of an employment use will only be permitted where it can be demonstrated that business uses are no longer viable at the site. This must include evidence to show that appropriate and reasonable efforts have been made to market the site for sale or lease for its existing, or similar, employment use. The type of information must include the following:

• The length of time the site or property has been vacant; and,
• A Marketing Strategy detailing the type of use which the site/property has been marketed for and its duration – there must be a minimum of 12 months appropriate marketing; and
• The amount of interest in the site during the marketing period, including the type and number of queries, together with the reason(s) for the ultimate lack of take-up/interest.

Insert new paragraph before 11.154.

New paragraph: Where a proposal seeks a change of use to B1(a) office use on a safeguarded employment site, reference to the town centre first approach as set out in national policy should be considered. Particular regard should be had to Policy 6: Town Centre First as set out in Future Wales: the National Plan 2040, and paragraph 4.3.18 of PPW which relates to the sequential approach when determining planning applications for retail and B1 uses.

11.154 In recognition of the pressures on employment areas from alternative uses (non-Class B), the policy accepts that some flexibility may in some instances be required. Such uses are often partial B class uses combining a small-scale retail element with predominantly business, industrial or storage use, or are sui generis. It is also accepted that in meeting the needs of such uses, employment areas are often likely to be more acceptable than other locations such as residential areas, or even town centres. Any retail element will be expected to be ancillary to the primary use, and for trade purposes as opposed to the public.

Amend Policy EME2 as follows

EME2: Employment – Extensions and Intensification

Proposals for extensions (of existing employment buildings) and/or intensification of existing employment enterprises will be permitted provided that:

a) a. The development proposals are will not likely to cause environmental damage or prejudice other redevelopment proposals;

b) b.The proposal does not extend and/or intensify a use or activity that might result in adverse amenity issues, or may not be compatible, with neighbouring uses; and

c) c. The development proposals are is of an appropriate scale and form compatible with its location.

Proposals for the expansion of existing rural enterprises will be supported subject to the above provisions and the policies and proposals of this Plan.

Amend paragraph 11.157 as follows

11.157 This policy relates to extensions to existing buildings and/or the intensification of uses on existing employment enterprises, in both rural and urban locations. The intensification of existing employment enterprises may include the small-scale extension of the existing site, and which may include new buildings associated with the extension, if these are considered necessary to the operation. However, Pproposals which seek to extend and/or intensify a use or activity will not be favourably considered if they are not compatible with surrounding uses, or likely to result in adverse amenity issues which would prejudice other redevelopment proposals.

New paragraph to be included after para 11.159

New paragraph: Reference is made to Policy CCH4 to ensure that there is no adverse effect on the integrity of nutrient sensitive protected sites.