EME1: Employment- Safeguarding of Employment Sites

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Object

Second Deposit LDP

Representation ID: 5317

Received: 14/04/2023

Respondent: Tata Steel Europe Limited

Agent: Gareth Barton

Legally compliant? Not specified

Sound? No

Representation Summary:

Object Policy EME1 - Policy EME1 sets out criteria where, exceptionally, proposals which result in the loss of employment sites is acceptable. The wording to that policy does not make it clear whether all or some of the criteria need to be met. This should be clarified. It is considered that only some of the criteria would need to be met as not all the criteria would be relevant to every proposal.

Change suggested by respondent:

Clarification of policy required

Full text:

The Plan is currently unsound as it fails to allocate land at Maesarddafen Road/ Erw Las, Cefncaeau provide for residential development. The Plan is therefore not considered to be appropriate or effective.

Please refer to the accompanying cover letter and related enclosures for further details.

Cover letter:

I write on behalf of our client, Tata Steel Europe Limited (Tata Steel), in response to the current Carmarthenshire Second Deposit Revised Local Development Plan (RLDP) Consultation.

INTRODUCTION
Tata Steel owns and operates the Trostre Steel Works and owns Land at Maesarddafen Road/ Erw Las, Cefncaeau, which is allocated in the adopted Carmarthenshire Local Development Plan (2014) for residential development of 300 dwellings (site reference GA2/h35).
Part of this site (Land at Maesarddafen Road) was granted outline planning permission (reference: S/34991), for a residential development of up to 94 units on 7 March 2022. This permission remains extant. The Second Deposit RLDP includes this site as a proposed residential allocation (PrC2/H15).
An outline planning application for residential development is currently being considered by your Authority for the remaining land at Erw Las, which forms part of the current LDP allocation (GA2/h35). The application (reference: PL/05187) was registered on 29 December 2022 and the description of development is:
“The erection of new residential dwellings, vehicular access, open space and other associated infrastructure.”
Dialogue with the Council regarding this application is ongoing and we hope that it will be positively determined shortly.

The land in Tata Steel’s control at Erw Las, which forms part of the current LDP allocation (GA2/h35), is not retained as a residential allocation in the emerging RLDP.
Accordingly, the representations set out below:
• Provide support for the proposed residential allocation at Maesarddafen Road (PrC2/H15).
• Object to the failure to allocate land at Erw Las, Cefncaeau for residential development. A Sustainability Appraisal relating to this site, along with a site location plan accompanies this submission.
• Provide commentary on Policy EME1: Employment- Safeguarding of Employment Sites and request clarification of the policy wording.
Our detailed representations in relation to the RLDP are set out below. A copy of the requisite response form is also attached.

SUPPORT FOR POLICY HOM1 ALLOCATION PRC2/H15 – LAND AT MAESYRDDAFEN ROAD
Our client strongly supports the proposed residential allocation PrC2/H15 (Land at Maeryrddafen Road, Llanelli). The proposed allocation provides for approximately 94 new homes on the site.
The proposed allocation reflects that the site benefits from an extant outline planning permission for a residential development of up to 94 dwellings. This permission is dated 7 March 2022. The Council’s approval of this application clearly demonstrates the suitability and acceptability of the proposed development for residential development.
Carmarthenshire County Council’s Committee Report for the application (S/34991, dated 19 March 2019) confirms that the principle of development of the site is acceptable and the proposal complies with key planning policies and sustainability objectives.

The Committee report confirms that:
‘The site is well integrated with the existing pattern of development in Llwynhendy and is capable of accommodating a development of the scale and density proposed without compromising the quality of the scheme or detracting from the character and appearance of the surrounding area. The development will provide a wide range and choice of housing types and sizes which will be well related to the existing services and facilities in the wider Llanelli area as well as being within easy access of a variety of sustainable modes of transport. It will also contribute to the improvement of educational, open space and pedestrian and cycling facilities in the surrounding area. The level of contributions secured are considered to be commensurate with the scale and nature of the development.

In addition, the development satisfies the sustainability requirements of the LDP from an environmental quality and utility provision perspective by implementing a drainage strategy that will dispose of foul and surface water in a sustainable and controlled manner as well as providing betterment to the capacity of the public sewerage system. Furthermore, and as outlined in the appraisal above, there are no highway, amenity, or ecological objections to the development.’ (Page 13)
The conclusions drawn in granting outline planning permission remain unchanged when considered against national planning policy/guidance and the emerging RLDP. The site remains well integrated to the existing pattern of development, accessible to a range of sustainable modes of transport and capable of accommodating the scale and density of new homes proposed.

The site has been marketed by Harris Lamb Property Consultancy and offers have been received. We understand that discussions are progressing and Tata Steel has entered into an exclusivity period with a preferred developer. This demonstrates that the site is viable and deliverable in the short term.
POLICY HOM1: HOUSING ALLOCATIONS
Whilst supportive of the proposed allocation at Maeryrddafen Road, Llanelli (PrC2/H15) through Policy HOM1 (as set out above), our client strongly objects to the failure to allocate land at Erw Las, Cefncaeau for residential development.
The proposed site (see attached plan) forms part of a wider allocation within the adopted LDP (alongside land at Maesyrddafen Road) for a development of 300 residential homes (GA2/h35). As outlined above, the Council has already granted outline planning permission for up 94 units on part of this allocated site (application reference: S/34991 – land at Maesyrddafen Road). Whilst land at Maesyrddafen Road is proposed as an allocation in the RLDP, the remaining land within Tata Steel’s control at Erw Las is not carried forward as a proposed allocation.

Our client strongly supports the continued allocation of land at Erw Las for residential development. This would provide for additional new homes to come forward on a sustainable site, which is currently allocated in the adopted LDP.
The site is subject to an outline planning application for residential development (application ref: PL/05187) which was registered on 29 December 2022 and is currently being considered by Carmarthenshire County Council. We hope that the application will be determined positively shortly.
The plans and suite of supporting technical documents submitted alongside the application demonstrate that there are no significant constraints that would prevent the development of the site for the proposed use and confirm that the development complies with relevant planning policy.

Interest from the market has been received in relation to the site at Erw Las. This demonstrates that the site is both viable and deliverable in the short term.
In summary, Tata Steel wish to see its land at Erw Las retained as an allocation for residential development of circa 100 dwellings. The land holding (and existing allocation) also includes residual land which provides the opportunity to bring forward a considerable area of new public open space and green infrastructure.
Sustainability Appraisal
Accompanying this submission is a Integrated Sustainability Appraisal for the proposed site at Erw Las, Cefncaeau. The Sustainability Appraisal follows the template provided within the Council’s ‘Integrated Sustainability Appraisal (ISA) Guide for Promoters of Sites for Development’ (February 2023).
The appraisal confirms that the site represents a sustainable development option. The Integrated Sustainability Appraisal does not raise any significant constraints beyond those that could be mitigated through the detailed design of the development.
The technical documents prepared to support the outline planning application (application reference: S/34991) further establish the suitability of the site to provide residential development.
The site is also well served by good quality pedestrian routes and public footpaths providing links to the centre of Llanelli. A play area and area of open space is located directly to the north of the site to the rear of Tir Einon. The site is within walking distance of existing bus stops on Heol Hen, Maes Ar Ddafen Road and Llwynhendy Road, providing access to a range of destinations within Llanelli and further afield, including Llanelli Town Centre and the Trostre and Pemberton Retail Parks.
In addition to the Trostre and Pemberton Retail Parks, a range of services and facilities are located along Llwynhendy Road. A range of key services and facilities are therefore located within a 300-1500m walk of the site, ensuring the site has good accessibility.
Furthermore, there are clear similarities between the assessment of the allocated site at Maesyrddafen Road and the proposed site at Erw Las. Both sites were considered jointly in the adopted LDP and form a single allocation, acknowledging the close physical and functional relationship between the two sites, which includes a footpath running between the sites. It is considered that the land at Erw Las land performs as well as the proposed allocation at Maesyrddafen Road.
The land controlled by Tata Steel at Erw Las would provide a viable and deliverable allocation that could be brought forward quickly. As demonstrated above, a significant amount of technical work has been completed to support the outline planning application, confirming that the site is not impeded by significant technical constraints. The site could therefore be brought forward swiftly, contributing to the continuous supply of deliverable sites and thereby helping to address the identified need for new housing.
The development of the site will also help to sustain and enhance the existing services and facilities available within Llanelli, resulting in a wide range of spin-off benefits for the local community.

POLICY EME1: EMPLOYMENT- SAFEGUARDING OF EMPLOYMENT SITES
The Tata Steel owned Trostre Steelworks is designated within the RLDP as an existing employment area through Strategic Policy 7 (SP7): Employment and the Economy. Policy SP7 recognises the contribution of existing employment sites as part of the employment portfolio in meeting ongoing need.
Policy EME1 safeguards sites identified for employment purposes for such uses (specifically Class B1, B2 and B8 uses). Our client welcomes the designation of the Trostre Steelworks as an existing employment site. Tata also welcome the support for employment related proposals within this area as provided by both Policy EME1 and EME2, which allows for the extension and / or intensification of existing employment enterprises.
Policy EME1 sets out criteria where, exceptionally, proposals which result in the loss of employment sites is acceptable. The wording to that policy does not make it clear whether all or some of the criteria need to be met. This should be clarified. It is considered that only some of the criteria would need to be met as not all the criteria would be relevant to every proposal.
Support is, however, given to criterion (f) of Policy EME1 which allows uses which are complementary to the primary employment use of the surrounding area. This recognises that non B-class uses and ancillary uses can be appropriate for locations within an employment site. Examples (not exhaustive) of such uses could include those relating to education or visitor centres.

Summary
I trust that the above representations assist and changes are made to reflect the position of Tata Steel in the preparation of the Plan as it progresses.
I would be grateful if Turley/Tata can be kept informed of future stages of the emerging Revised Carmarthenshire Local Development Plan.
If you require any further information please do not hesitate to contact me.

Attachments:


Our response:

The policies and proposals of the LDP are considered sound and deliverable emerging from a robust evidence base and having been formulated with regard to, and in a manner consistent with the Sustainability Appraisal. All the criteria of Policy EME1 would need to be addressed at the planning application stage.

Support

Second Deposit LDP

Representation ID: 5318

Received: 14/04/2023

Respondent: Tata Steel Europe Limited

Agent: Gareth Barton

Representation Summary:

The Tata Steel owned Trostre Steelworks is designated within the RLDP as an existing employment area
through Strategic Policy 7 (SP7): Employment and the Economy. Policy SP7 recognises the contribution
of existing employment sites as part of the employment portfolio in meeting ongoing need.
Policy EME1 safeguards sites identified for employment purposes for such uses (specifically Class B1, B2
and B8 uses). Our client welcomes the designation of the Trostre Steelworks as an existing employment site. Tata also welcome the support for employment related proposals within this area as provided by both Policy EME1 and EME2, which allows for the extension and / or intensification of existing employment enterprises.

Support is given to criterion (f) of Policy EME1 which allows uses which are complementary to
the primary employment use of the surrounding area. This recognises that non B-class uses and ancillary
uses can be appropriate for locations within an employment site

Change suggested by respondent:

No change

Full text:

The Plan is currently unsound as it fails to allocate land at Maesarddafen Road/ Erw Las, Cefncaeau provide for residential development. The Plan is therefore not considered to be appropriate or effective.

Please refer to the accompanying cover letter and related enclosures for further details.

Cover letter:

I write on behalf of our client, Tata Steel Europe Limited (Tata Steel), in response to the current Carmarthenshire Second Deposit Revised Local Development Plan (RLDP) Consultation.

INTRODUCTION
Tata Steel owns and operates the Trostre Steel Works and owns Land at Maesarddafen Road/ Erw Las, Cefncaeau, which is allocated in the adopted Carmarthenshire Local Development Plan (2014) for residential development of 300 dwellings (site reference GA2/h35).
Part of this site (Land at Maesarddafen Road) was granted outline planning permission (reference: S/34991), for a residential development of up to 94 units on 7 March 2022. This permission remains extant. The Second Deposit RLDP includes this site as a proposed residential allocation (PrC2/H15).
An outline planning application for residential development is currently being considered by your Authority for the remaining land at Erw Las, which forms part of the current LDP allocation (GA2/h35). The application (reference: PL/05187) was registered on 29 December 2022 and the description of development is:
“The erection of new residential dwellings, vehicular access, open space and other associated infrastructure.”
Dialogue with the Council regarding this application is ongoing and we hope that it will be positively determined shortly.

The land in Tata Steel’s control at Erw Las, which forms part of the current LDP allocation (GA2/h35), is not retained as a residential allocation in the emerging RLDP.
Accordingly, the representations set out below:
• Provide support for the proposed residential allocation at Maesarddafen Road (PrC2/H15).
• Object to the failure to allocate land at Erw Las, Cefncaeau for residential development. A Sustainability Appraisal relating to this site, along with a site location plan accompanies this submission.
• Provide commentary on Policy EME1: Employment- Safeguarding of Employment Sites and request clarification of the policy wording.
Our detailed representations in relation to the RLDP are set out below. A copy of the requisite response form is also attached.

SUPPORT FOR POLICY HOM1 ALLOCATION PRC2/H15 – LAND AT MAESYRDDAFEN ROAD
Our client strongly supports the proposed residential allocation PrC2/H15 (Land at Maeryrddafen Road, Llanelli). The proposed allocation provides for approximately 94 new homes on the site.
The proposed allocation reflects that the site benefits from an extant outline planning permission for a residential development of up to 94 dwellings. This permission is dated 7 March 2022. The Council’s approval of this application clearly demonstrates the suitability and acceptability of the proposed development for residential development.
Carmarthenshire County Council’s Committee Report for the application (S/34991, dated 19 March 2019) confirms that the principle of development of the site is acceptable and the proposal complies with key planning policies and sustainability objectives.

The Committee report confirms that:
‘The site is well integrated with the existing pattern of development in Llwynhendy and is capable of accommodating a development of the scale and density proposed without compromising the quality of the scheme or detracting from the character and appearance of the surrounding area. The development will provide a wide range and choice of housing types and sizes which will be well related to the existing services and facilities in the wider Llanelli area as well as being within easy access of a variety of sustainable modes of transport. It will also contribute to the improvement of educational, open space and pedestrian and cycling facilities in the surrounding area. The level of contributions secured are considered to be commensurate with the scale and nature of the development.

In addition, the development satisfies the sustainability requirements of the LDP from an environmental quality and utility provision perspective by implementing a drainage strategy that will dispose of foul and surface water in a sustainable and controlled manner as well as providing betterment to the capacity of the public sewerage system. Furthermore, and as outlined in the appraisal above, there are no highway, amenity, or ecological objections to the development.’ (Page 13)
The conclusions drawn in granting outline planning permission remain unchanged when considered against national planning policy/guidance and the emerging RLDP. The site remains well integrated to the existing pattern of development, accessible to a range of sustainable modes of transport and capable of accommodating the scale and density of new homes proposed.

The site has been marketed by Harris Lamb Property Consultancy and offers have been received. We understand that discussions are progressing and Tata Steel has entered into an exclusivity period with a preferred developer. This demonstrates that the site is viable and deliverable in the short term.
POLICY HOM1: HOUSING ALLOCATIONS
Whilst supportive of the proposed allocation at Maeryrddafen Road, Llanelli (PrC2/H15) through Policy HOM1 (as set out above), our client strongly objects to the failure to allocate land at Erw Las, Cefncaeau for residential development.
The proposed site (see attached plan) forms part of a wider allocation within the adopted LDP (alongside land at Maesyrddafen Road) for a development of 300 residential homes (GA2/h35). As outlined above, the Council has already granted outline planning permission for up 94 units on part of this allocated site (application reference: S/34991 – land at Maesyrddafen Road). Whilst land at Maesyrddafen Road is proposed as an allocation in the RLDP, the remaining land within Tata Steel’s control at Erw Las is not carried forward as a proposed allocation.

Our client strongly supports the continued allocation of land at Erw Las for residential development. This would provide for additional new homes to come forward on a sustainable site, which is currently allocated in the adopted LDP.
The site is subject to an outline planning application for residential development (application ref: PL/05187) which was registered on 29 December 2022 and is currently being considered by Carmarthenshire County Council. We hope that the application will be determined positively shortly.
The plans and suite of supporting technical documents submitted alongside the application demonstrate that there are no significant constraints that would prevent the development of the site for the proposed use and confirm that the development complies with relevant planning policy.

Interest from the market has been received in relation to the site at Erw Las. This demonstrates that the site is both viable and deliverable in the short term.
In summary, Tata Steel wish to see its land at Erw Las retained as an allocation for residential development of circa 100 dwellings. The land holding (and existing allocation) also includes residual land which provides the opportunity to bring forward a considerable area of new public open space and green infrastructure.
Sustainability Appraisal
Accompanying this submission is a Integrated Sustainability Appraisal for the proposed site at Erw Las, Cefncaeau. The Sustainability Appraisal follows the template provided within the Council’s ‘Integrated Sustainability Appraisal (ISA) Guide for Promoters of Sites for Development’ (February 2023).
The appraisal confirms that the site represents a sustainable development option. The Integrated Sustainability Appraisal does not raise any significant constraints beyond those that could be mitigated through the detailed design of the development.
The technical documents prepared to support the outline planning application (application reference: S/34991) further establish the suitability of the site to provide residential development.
The site is also well served by good quality pedestrian routes and public footpaths providing links to the centre of Llanelli. A play area and area of open space is located directly to the north of the site to the rear of Tir Einon. The site is within walking distance of existing bus stops on Heol Hen, Maes Ar Ddafen Road and Llwynhendy Road, providing access to a range of destinations within Llanelli and further afield, including Llanelli Town Centre and the Trostre and Pemberton Retail Parks.
In addition to the Trostre and Pemberton Retail Parks, a range of services and facilities are located along Llwynhendy Road. A range of key services and facilities are therefore located within a 300-1500m walk of the site, ensuring the site has good accessibility.
Furthermore, there are clear similarities between the assessment of the allocated site at Maesyrddafen Road and the proposed site at Erw Las. Both sites were considered jointly in the adopted LDP and form a single allocation, acknowledging the close physical and functional relationship between the two sites, which includes a footpath running between the sites. It is considered that the land at Erw Las land performs as well as the proposed allocation at Maesyrddafen Road.
The land controlled by Tata Steel at Erw Las would provide a viable and deliverable allocation that could be brought forward quickly. As demonstrated above, a significant amount of technical work has been completed to support the outline planning application, confirming that the site is not impeded by significant technical constraints. The site could therefore be brought forward swiftly, contributing to the continuous supply of deliverable sites and thereby helping to address the identified need for new housing.
The development of the site will also help to sustain and enhance the existing services and facilities available within Llanelli, resulting in a wide range of spin-off benefits for the local community.

POLICY EME1: EMPLOYMENT- SAFEGUARDING OF EMPLOYMENT SITES
The Tata Steel owned Trostre Steelworks is designated within the RLDP as an existing employment area through Strategic Policy 7 (SP7): Employment and the Economy. Policy SP7 recognises the contribution of existing employment sites as part of the employment portfolio in meeting ongoing need.
Policy EME1 safeguards sites identified for employment purposes for such uses (specifically Class B1, B2 and B8 uses). Our client welcomes the designation of the Trostre Steelworks as an existing employment site. Tata also welcome the support for employment related proposals within this area as provided by both Policy EME1 and EME2, which allows for the extension and / or intensification of existing employment enterprises.
Policy EME1 sets out criteria where, exceptionally, proposals which result in the loss of employment sites is acceptable. The wording to that policy does not make it clear whether all or some of the criteria need to be met. This should be clarified. It is considered that only some of the criteria would need to be met as not all the criteria would be relevant to every proposal.
Support is, however, given to criterion (f) of Policy EME1 which allows uses which are complementary to the primary employment use of the surrounding area. This recognises that non B-class uses and ancillary uses can be appropriate for locations within an employment site. Examples (not exhaustive) of such uses could include those relating to education or visitor centres.

Summary
I trust that the above representations assist and changes are made to reflect the position of Tata Steel in the preparation of the Plan as it progresses.
I would be grateful if Turley/Tata can be kept informed of future stages of the emerging Revised Carmarthenshire Local Development Plan.
If you require any further information please do not hesitate to contact me.

Attachments:


Our response:

Support welcomed

Object

Second Deposit LDP

Representation ID: 5324

Received: 14/04/2023

Respondent: Mr B Owen

Agent: JCR Planning Ltd

Legally compliant? Not specified

Sound? No

Representation Summary:

Objection to the omission of site AS2/064/004 in Betws, Ammanford for employment purposes:
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 employment opportunities within this Tier 2 Service Centre. Its development would be in keeping with adjacent development but will ensure a readily deliverable source of modern and sustainable units for the community.
In addition, development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised employment 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.
It is considered that this site is both sustainable and readily deliverable and its allocation should be fully supported.

Change suggested by respondent:

Include site within Plan

Full text:

LAND ADJACENT TO PONTAMMAN ROAD (A474) AND
HEOL DWR, GLYNMOCH, GLANAMMAN, AMMANFORD,
SA18 2EY.
This representation proposes an extension to the existing industrial area
(EME1 Old Coal Yard) alongside the A474/Heol Dwr at Glynmoch, Glanamman
and objects to its exclusion from the designated employment allocation.
Glanamman/Garnant comprises a designated Tier 2 Service Centre and is able
to accommodate significant employment land and thereby provide a range of
employment opportunities.
The proposed site will utilise the existing access at Heol Dwr and represents an
appropriate and modest rounding-off of the existing employment site. Its
designation will offer an envisaged 3 no. small industrial units which will
provide a valuable modern, sustainable and energy efficient employment
opportunity set within an attractive and environmentally beneficial site. Inward
investment to the Aman Valley will be encouraged and opportunities provided
for vital job creation.
No residential properties will be affected by the proposed land use and all
highway requirements are readily satisfied. Environmental benefits and
biodiversity enhancement will result from strategic tree and shrub planting
along the boundary of the site with the A474 which will provide a pleasant
landscaped frontage at this gateway to Glanamman. In addition, the proposer
is offering to plant a tree belt in order to screen the existing industrial area in
order to further enhance the approach to the settlement.
The accompanying schematic site layout drawing demonstrates that an
appropriate layout can be readily devised to satisfy all normal development
control considerations.
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 employment opportunities within this Tier 2 Service Centre. Its
development would be in keeping with adjacent development but will ensure a
readily deliverable source of modern and sustainable units for the community.
In addition, development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised employment 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.
It is considered that this site is both sustainable and readily deliverable and its
allocation should be fully supported.

Attachments:


Our response:

There is sufficient and more appropriate land available for employment purposes within the settlement to accommodate its employment need.

Object

Second Deposit LDP

Representation ID: 5540

Received: 13/04/2023

Respondent: Cllr Tina Higgins

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Objection to the safeguarding of Land off Heol Ddu (Tycroes) as an existing employment area under Policy EME1.
This is an area of land situated off an unclassified road known as Heol Ddu. The land is close to Teglan Park a large housing estate leading off from Penygarn Road.
Although the land was used for factories, the land has planning permission for residential properties. Consideration should be given to the type of light industry that would be acceptable there due to the close proximity to Teglan Park.
Access – Heol Ddu is an unclassified road accessed from the A483. The road is not suitable for commercial traffic. The road would need to be improved and SWTRA consulted.
Noise disturbance to nearby dwelling – Close proximity to Teglan Park will in no doubt have an impact on residents’ quality of life due to noise as well as dust.

Change suggested by respondent:

No change to the Plan, however observations in this representation would need to be considered as part of any subsequent planning application.

Full text:

For ease of reference, I have used the reference numbers from the first deposit as well as road names to identify areas that I am commenting on.
I fully support protecting of green space in Tycroes ward. All green spaces within the ward should be protected from development. Access to use these areas for recreational purposes is essential to the community to maintain and improve both physical and mental health well being. Nature is also a vital part of education.
In Tycroes -
Land including the woodland between Heol Brown and Hafod Road, the football field on Heol Brown as well as the land between Number 4 and 6 Heol Brown and to the right of number 8 Heol Brown as you are looking at it from Heol Brown and opposite the entrance to Tirprys (a public footpath runs through it) should be protected from development.
The woodland by Heol Brown park is home to a variety of wildlife e.g. foxes and badgers. Sightings also include a rare butterfly and owls who nest there. Residents state that this land was a gift from the Coal Board to the village of Tycroes to be used for recreational purposes. Residents feel very strongly that this should remain as an area for recreational activities. Access to this area would be from Hafod Road Tycroes which is a narrow lane.
Another consideration is that permission to develop this land would need to be sought from the Coal Board.
Land between Heol Ddu and Teglan Park – Access to this land is off a corner on Heol Ddu and also from Teglan Park. The area is used by children and should also be protected from development. I believe that there is a covenant in place restricting the use of the area to recreational purposes only.

There is a further large area of green open land between Tycroes, Penybank and Pantyffynon. This area has footpaths that are used on a regular basis. Any building on this land would be detrimental to the rural feel of the area currently enjoyed by the residents.
Land known as Cwmfferws Park between Cwmfferws Road and Hendre Road, bordering on to Ammanford Road. This should also be protected from development.

Footpaths within the ward are well used but the council should improve access and make every effort to maintain them. Tycroes has a walking group that meet at least twice a week and use these footpaths.
PrC3/h32
This area of land, currently a greenfield site, is outside the development limits and is not in the current LDP. The land referenced as PrC3/h32 is not one area of land but two separate areas. One half (the land behind Penygarn Road leading to the Rugby Club) already had planning permission for 37 houses which was granted in December 2019. The dwellings have now been built and occupied. This planning permission was approved with the reason given that the need for social housing allowed for an exemption from the County Council’s own policy. This was an exception, not the rule and should not be used to set a precedent to have more development on the other half of the land reference PrC3/h32 behind Tycroes Road (as far as number 69 Tycroes Road and Numbers 5 – 7 in Ffordd Y Deri.
Flooding issues - There is already known flooding issues within the ward. Further development could make matters worse.
Access to the dwellings – Access to the 37 dwellings built on one half of PrC3/h32 is through Ffordd Y Deri off Tycroes Road. Ffordd Y Deri is also a narrow road unsuitable for further traffic. The volume of traffic coming out on to Tycroes Road has increased. It is likely that most households would have two vehicles which will result in a sustained volume of traffic using the road throughout the day.
Ecology and Environment – Bats and Badgers have been sighted here. Bats are a protected species and any disturbance to their natural habitat would be catastrophic for the species. Valuable trees would be at risk should there be any further development.
Education
Tycroes Primary School is full to capacity. Provision of education to extra children is a real concern with some years currently running to full capacity and children already being refused admission.
In conclusion, the amount of houses that have been built is more than sufficient to meet local needs.
Land off Heol Ddu – Previously a factory site and others
This is an area of land situated off an unclassified road known as Heol Ddu. The land is close to Teglan Park a large housing estate leading off from Penygarn Road.
Although the land was used for factories, the land has planning permission for residential properties. Consideration should be given to the type of light industry that would be acceptable there due to the close proximity to Teglan Park.
Access – Heol Ddu is an unclassified road accessed from the A483. The road is not suitable for commercial traffic. The road would need to be improved and SWTRA consulted.
Noise disturbance to nearby dwelling – Close proximity to Teglan Park will in no doubt have an impact on residents quality of life due to noise as well as dust.
Education
Tycroes Primary School is full to capacity. There is room for a small extension, however any further building would impede on the school play areas. Provision of education to extra children is a real concern.
Other general ward observations

Agricultural land - The land in the ward currently used for agriculture should remain as it is. This enhances the rural feel of the ward and provides employment to local residents.

Business and retail parks - The ward is adequately served by a business park to the north of the ward and shops in the centre of Tycroes.

Planning - There is already planning permission for approximately 250 residential dwellings within the ward. This is more than adequate for current and future needs. Any further provision to this number could mean empty properties.
In general residents in the ward feel very strongly that there is that there is no need for further development in the ward. The residents also feel strongly that green field sites should be kept as they are.
Llanedi – The Village Green in front of Y Garreg Llwyd and opposite Tafarn Y Deri.
I request that this area is protected from development. This area is used regularly and has been for many years by children playing and various village groups to hold events such as the one held during the jubilee in 2022.

Attachments:


Our response:

The policies and proposals of the LDP are considered sound and deliverable emerging from a robust evidence base and having been formulated with regard to, and in a manner consistent with the Sustainability Appraisal. Existing employment sites annotated on the LDP Proposals Map are based upon the most up to date evidence, and are protected in accordance with national planning policy. The observations made in this representation would need to be considered as part of any subsequent planning application on this site.