Strategic Policy – SP 15: Protection and Enhancement of the Built and Historic Environment

Showing comments and forms 1 to 4 of 4

Support

Second Deposit LDP

Representation ID: 5524

Received: 11/04/2023

Respondent: Pembrokeshire Coast National Park Authority

Agent: Pembrokeshire Coast National Park Authority

Representation Summary:

Both plans have regard to the need to generate more electricity from renewable sources. Pembrokeshire Coast National Park Authority has a renewable energy strategy policy seeking the delivery of appropriate renewable energy developments.
Both Authorities implement joint guidance on assessing the cumulative impact of wind turbines.
It would be useful to confirm if Carmarthenshire intends to bring forward the Cumulative Impact of Turbine Guidance in the replacement Local Development Plan.
Carmarthenshire includes renewable energy as part of Strategic Policy 16: Climate Change (parts c and d), and both CCH1: Renewable Energy within Pre-Assessed Areas and Local search Areas and CCH”: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas. Whilst Pembrokeshire does not have Local Search Areas, these policies are broadly in line with this Authority’s Renewable and Low Carbon Energy policy.
LSA for solar is shown on the Proposals map and it is considered that none of these are likely to have an impact on the Pembrokeshire Coast National Park.

Change suggested by respondent:

No change to the Plan

Full text:

2nd Deposit Revised LDP – Commentary

Reference and Comment

A. Spatial Strategy
The National Park Authority has no comment on the spatial strategy proposed.

No comment.

Reference and Comment Support/Object/
Other
B. Employment
The Spatial Strategy commentary above sets out where there is consistency of approach on where employment undertakings can take place in the County along with notes of clarification.

The employment and economic development strategy of Carmarthenshire County Council’s Preferred Strategy focusses on the Swansea Bay City Deal, and other Carmarthenshire-specific strategies. Carmarthenshire County Council and this National Park Authority are stakeholders in a Regional Strategic Economic study along with Pembrokeshire County Council and Brecon Beacons National Park Authority. The final report was published in October 2019. The study broadly concludes that there is sufficient strategic land available to meet demand across the area. The policy approach across the Pembrokeshire County Council, Carmarthenshire County Council and Pembrokeshire Coast National Park Authority is to protect strategic and smaller employment sites for employment use.
Support the general conformity of approach.

C. Housing Growth
Pembrokeshire Coast National Park Authority has no comment on the anticipated scale of growth proposed.

D. Affordable Housing
The National Park Authority has no comment.
No comment.

Climate Change
The Authorities have a shared understanding of the need to plan for climate change and to mitigate its impacts and to provide for high quality design to ensure that new development is adaptable to climate change.

This National Park Authority supports the approach taken to future-proofing communities in light of predicted sea-level rise and the identification of a Coastal Change Management Area, supported by the South Wales Shoreline Management Plan. Support in principle. Support Policy PSD1 Placemaking and sustainable places, Policy NE5 Coastal Management NE6: Coastal Development; and NE7 Coastal Change Management Area and SP16 Climate change.
Note: See comment across.

Visitor Economy
Both Authorities recognise the importance of the visitor economy to west Wales and aim to support the sector and attract visitors all year round. Both also recognise that some attractions require a countryside setting but that this should be the exception, and the majority of tourism related development being sustainably located. Support SP11 The Visitor Economy, VE1 Visitor Attractions and Facilities; VE2 Holiday Accommodation; VE3 Touring Caravan, camping and Non-Permanent Alternative Camping Accommodation; VE4 Static Caravan and Chalet Sites and Permanent Alternative Camping Accommodation.

Retail
Both Authorities’ strategies focus on the need to maintain / create vibrant and diverse town, district, and local centres. Retail provision in both Authorities is identified through the retail hierarchy with Carmarthenshire’s hierarchy being based on Sub Regional- High Order Town Centres, Mid Order Town Centres and Lower Order Town Centres. Support SP 2 Retail and Town Centres

Renewable Energy
Both plans have regard to the need to generate more electricity from renewable sources. Pembrokeshire Coast National Park Authority has a renewable energy strategy policy seeking the delivery of appropriate renewable energy developments.

Both Authorities implement joint guidance on assessing the cumulative impact of wind turbines

It would be useful to confirm if Carmarthenshire intends to bring forward the Cumulative Impact of Turbine Guidance in the replacement Local Development Plan.

Carmarthenshire includes renewable energy as part of Strategic Policy 16: Climate Change (parts c and d), and both CCH1: Renewable Energy within Pre-Assessed Areas and Local search Areas and CCH”: Renewable Energy Outside Pre-Assessed Areas and Local Search Areas. Whilst Pembrokeshire does not have Local Search Areas, these policies are broadly in line with this Authority’s Renewable and Low Carbon Energy policy.
LSA for solar is shown on the Proposals map and it is considered that none of these are likely to have an impact on the Pembrokeshire Coast National Park.
Support SP 15 Climate Change and CCH1 / CCH2

Environment
Both Plans seek to ensure that their Plan areas natural and historic environment and landscape will be protected from inappropriate development and, where possible, enhanced.

The Welsh language which continues to be an important component in the social, cultural and economic life of many communities will be protected and supported by managing development sensitively in areas where it has a significant role in the community. Support SP8 Welsh Language and WL1 Welsh Language and New Developments, SP14
PSD3: Green and Blue Infrastructure Network
Maintaining and Enhancing the Natural Environment. SP 15 Protection and Enhancement of the Built and Historic Environment and BHE2 Landscape Character. SP14 Maintaining and Enhancement of the Built and Historic Environment

Note See across for comment.

Regional Working
Strategic Policy – SP 14: Maintaining and Enhancing the Natural Environment: Reasoned Justification: 11.409 In addition, and reflecting the duties placed upon Local Authorities, the Plan has regard to the National Park designation and the purpose for which it is designated, where it may affect the consideration of planning proposals.
BHE2: Landscape Character Development proposals should relate to the specific landscape and visual characteristics of the local area, ensuring that the overall integrity of landscape character is maintained by: …. b) protecting international and national landscape designations including National Parks and Areas of Outstanding Natural Beauty (AONB) and their settings;

11.456 Carmarthenshire is characterised by diverse and high-quality landscape resources and areas of notable visual value. It also includes or borders a range of landscape designations, including the Brecon Beacons and Pembrokeshire Coast National Parks and Gower AONB.

Appendix 2 Regional and Local Strategic Context:
Regional working: Pembrokeshire Coast National Park Authority’s adopted LDP is broadly compatible with a hierarchical settlement structure and a consistency in the broad planning policy approach with Carmarthenshire. Continuing liaison will ensure a mutual understanding of the respective approaches including through regional arrangements and the scope and progress of the Strategic Development Plan. A proactive approach towards regional and sub-regional working is implicit on policy matters, evidence gathering and strategic considerations.

Minerals
The terrestrial sand and gravel landbank and the apportionment of provision to meet future needs is now considered on a regional basis with the RTS Second Review setting out the contribution that each constituent local authority should make towards meeting the demand for aggregates. There is no requirement for a landbank to be maintained within National Park (PPW 11)

Although Carmarthenshire is now in a separate sub-region to Pembrokeshire, previous combined working arrangements with regard to future apportionments and allocations for sand and gravel as suggested in the RTS1 as recommended to continue in RTS2 with the production of a Statement of Sub-regional Collaboration between Pembrokeshire, Carmarthenshire and Ceredigion to meet the allocation requirement of 3.626 million tonnes.

The Area of Search for Sand and Gravel is located to the west as shown on the Proposals Map, the northern end of which lies approximately 4.3km south east of the Pembrokeshire Coast National Park.
Support the compatibility of approach between the two Plans.
Support SP 18: Mineral Resources.

Waste
Both authorities’ policies on waste management are broadly aligned. Carmarthenshire acknowledges TAN 21 and the need for collaboration between local planning authorities to progress towards an integrated and adequate network for waste management.
Support
Support SP 19: Sustainable Waste Management

Sustainability Appraisal/Strategic Environmental Appraisal

Appendix E: Growth Options
1st Deposit LDP Preferred Growth Option: check shading for ISA3. The appraisal is ‘+/-‘and the shading is that of minor negative effect rather than the yellow of positive and negative effect.

Appendix F: ISA Strategic Policies
SP 2: Retail and Town Centres: ISA Objective 1 has a positive assessment but no commentary.

SP 10: Gypsy and Traveller Provision: ISA Objective 8 is neutral. Could this be a positive since providing sites sustains Gypsy and Traveller culture?

Habitats Regulations Assessment

Comments:

Thank you for considering and incorporating PCNPA’s comments on the Habitat Regulations Assessment Report (2020) as detailed in the appendices to the Habitats Regulations Assessment Addendum report.

4.3 Interim action plan – land available for constructed wetlands.
It is suggested that it would be beneficial to include discussion of the identified lands current use (e.g. to eliminate land of existing or other potential nature conservation value from consideration).
Other discussion points:
The long-term use of wetlands as nutrient sinks is not well understood.
The ability of wetlands to remove nutrients may be influenced by climate change scenarios, e.g. drying out, flood events.

Page 8 (PPP) – while not yet adopted, we note that consultation recently (February 2023) closed on Dŵr Cymru Welsh Water’s draft Water Resources Management Plan 2024
Typos
“3.2.15 ‘screened out screened out’
3.3.2 ‘unlikely to have a significant effects’
4.2.17 ‘there are important’
4.2.20 ‘which can demonstrate not cause the failure’
4.3.1 ‘ready in conjunction’

Attachments:

Representation (29.61 KB)
email - redacted (363.94 KB)

Our response:

Support welcomed

Support

Second Deposit LDP

Representation ID: 5530

Received: 11/04/2023

Respondent: Pembrokeshire Coast National Park Authority

Agent: Pembrokeshire Coast National Park Authority

Representation Summary:

Environment
Both Plans seek to ensure that their Plan areas natural and historic environment and landscape will be protected from inappropriate development and, where possible, enhanced.

Change suggested by respondent:

No change to the Plan

Full text:

Attachments:

Representation (29.61 KB)
email - redacted (363.94 KB)

Our response:

Support welcomed

Object

Second Deposit LDP

Representation ID: 5861

Received: 13/04/2023

Respondent: Cllr. Carys Jones

Number of people: 38

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Submitted on behalf of all Plaid Cymru Councillors on Carmarthenshire County Council – April 2023

Observations:
• There is very little guidance on the functional re-use of chapels and churches in rural communities apart from their historic surroundings and facades.
• Many church and chapel buildings in rural areas are converted for holiday/second home use. This is not consistent with the interests of “local listing” to preserve the contextual integrity of the community asset.
CONSIDERATIONS:
1. To acknowledge that the LDP could include measures to assess, secure and re-use closed Places of Worship for the benefit of the community.
2. To encourage conversations between representatives of closing Places of Worship, planners and the community before disposal of the asset.
3. To consider placing covenants on Chapels and Churches being converted to dwellings to ensure they are permanent residential dwellings rather than second homes in order to protect the historic integrity of the building for the future.
4. To require that CADW exercises flexibility in its approach to the re-use of local historic assets so that they remain of value and interest to the community

Change suggested by respondent:

Amend the Plan

Full text:

Submitted on behalf of all Plaid Cymru Councillors on Carmarthenshire County Council – April 2023

SECOND REVISED LOCAL DEVELOPMENT PLAN 2018 - 2033
CYNGOR SIR GÂR
RESPONSE TO PUBLIC CONSULTATION March/April 2023
This document attempts to measure the aims of the LDP against the specific proposals as regards RURAL
DEVELOPMENT, SUSTAINABLE RURAL COMMUNITIES and the WELSH LANGUAGE.
It is compiled from the point of view of Local Members who attempt to build strong rural communities
within the limitations presented in the Local Development Plan and the the Planning environment.
Critical issues faced by rural communities at this time include:
• De-population – loss of young people, leading to loss of young families, leading to loss of
generation of children and further young people – a cycle which rural communities cannot control
nor influence;
• Altered demographic – increasing purchase and occupation of residential dwellings by older
couples or individuals, either retired or preparing for retirement, both local and from afar –
ultimately leading to “retirement villages”;
• Market forces – demand of older generations who have the means to purchase a rural lifestyle
pushing property prices beyond the reach of younger working families;
• Media marketing – “lifestyle” programming on TV and other media encouraging urban dwellers to
aspire to idyllic rural locations thus squeezing local lower earners from access to the local market;
• Tourism – economic considerations from the (sporadic) visitor industry is prioritised above the
economic contribution of (permanent) rural residential working families;
• Yr Iaith Gymraeg – Planning Statements placing the Welsh Language in a priority position while
Planning Policy failing to protect or develop Welsh Language rural strongholds;
• Community – traditional rural community structures breaking due to fragmented demographic,
contrasting cultures and consequential loss of cultural heritage;
• Community Services – lack of young families stepping into and running the voluntary community
services such as sports clubs, PTAs, Church/Chapel groups, social events etc.;
• The Family – breakdown of “family care cycle”. While young families are not living near their
parents, care of the elderly by the younger generation and childcare by the older generation
cannot be provided, resulting in isolation and additional pressures on Care Services.
• Local Culture – not necessarily being recognised or acknowledged by new demographic. Absence of
younger generation to inherit and exercise local culture and tradition resulting in their demise and
disappearance.
How can the LDP support ordinary people in ordinary rural communities to develop their economy,
language and culture?
TAN 6: 2.1.2 “Planning authorities should assess the needs and priorities of rural communities. They
should interrogate published sources of information such as the Wales Rural Observatory, and if
necessary commission research to identify rural economic and social conditions and needs.”
The Wales Rural Observatory ceased to exist in 2014. The most recent report on rural communities was
published in 2013. Many of the issues above were identified at that time:
“A common concern … was that disproportionately high housing prices, fuelled by demand for
commuting, second homes, holiday homes and retirement accommodation, was taking owner
occupation beyond the reach of many people resulting in young people and young families being
driven out of the communities where they worked or had grown up.”
Ten years later, however, these issues remain unaddressed in national and local policies.
2
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
As recommended, Carmarthenshire County Council has commissioned its own research to identify rural
needs:
MOVING RURAL CARMARTHENSHIRE FORWARD – Report and Recommendations of the Carmarthenshire
Rural Affairs Task Group – June 2019:
“As a local authority we cannot directly influence decisions that are made in Cardiff, London and
Brussels but we can strongly urge our representatives to do whatever they can to safeguard the
future of rural Carmarthenshire and rural Wales. This is essential so that future generations can
live, work and spend their leisure time in communities where valued traditions can be maintained,
but are also resilient enough to adapt to an ever-changing social and economic landscape. This
report seeks to encapsulate that crucial balance between preservation and progression.”
There is a disconnect between the recommendations in the MOVING RURAL CARMARTHENSHIRE
FORWARD report – supporting the efforts of local people to maintain and develop rural communities –
and the inflexibility of the planning framework.
_____________________________________________________________________________________
OBSERVATIONS AND CONSIDERATIONS ON
SPECIFIC ASPECTS OF THE LDP
(A number of observations and considerations are common to more than one Strategic Policy)
LDP: HOM3 - Homes in Rural Villages
11.90 This part of the Plan's rural policy framework seeks to establish a flexible but controlled approach to
the delivery of new homes within those (Rural Villages) 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.
PPW Housing 4.2.1: Planning authorities must understand all aspects of the housing market in their
areas, which will include the requirement, supply and delivery of housing. This will allow planning
authorities to develop evidence-based market and affordable housing policies in their development
plans and make informed development management decisions that focus on the creation and
enhancement of Sustainable Places.
TAN 2.2.1: Many rural communities can accommodate development, particularly to meet local needs.
New development can help to generate wealth to support local services, ensuring that communities are
sustainable in the long term. A key question for the planning authority, when identifying sites in the
development plan or determining planning applications, is whether the proposed development
enhances or decreases the sustainability of the community. In particular, planning authorities should
support developments that would help to achieve a better balance between housing and employment,
encouraging people to live and work in the same locality.
Observations:
• The policies exert much control but very little flexibility within rural settlements.
• The “character of the countryside” is not defined in planning terms. It seems to refer to the
appearance of the countryside while it should, in fact, refer to all aspects of rural life. It is the
biodiversity, the nature, the traditions and, primarily, the local knowledge of the history and culture
of that part of the countryside which forms the character.
• If we lose the local residents then we lose that knowledge and protection.
3
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
• The criteria-based assessment prioritises maintaining the character of the countryside above
maintaining a local community.
• The policies fail to recognise the contribution of the local community to maintaining the character of
the countryside through its knowledge, traditions and protective practices.
CONSIDERATIONS:
• To apply additional flexibility to policies for rural villages to allow the needs of the
community to be met.
• To acknowledge the role of village residents in the enhancement and protection of the
“character of the countryside”.
• To measure the contribution a development makes to the well-being of the community
as opposed to considering only the perceived potential harm.
• To assess and recognise the scale of development required in rural villages to secure their
future as community strongholds.
LDP: HOM3 - Guidance on Acceptable Plots
Infill sites within these rural villages will take priority over other locations;
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;
• Proposals located in open fields adjoining a group, which have no physical features to provide
containment will not be considered acceptable.
Observations:
• While infill sites should take priority over other locations, this should not exclude other locations.
• These rigid limitations appear logical in theory, but they are not practical in many rural settlements.
• The limitations do not take into account variances in our local topography.
CONSIDERATIONS:
1. To consider further potential development capacity in and around rural villages.
2. To apply rounding-off of boundaries to include capacity which logically allows sensitive
development.
3. To evidence actual harm against the potential for community benefit in setting and
respecting development boundaries.
LDP: HOM3 - Housing within development limits
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.
Observations:
• A settlement of 100 houses may only grow by 10 homes during the life of the LDP.
• A hamlet of 10 homes may only grow by 1 home during the life of the LDP.
• The rigidity of the 10% cap is not sympathetic to the aspiration to build sustainable rural
communities.
4
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
• While an exception is provided for Affordable Housing, the needs of a community may also include
market housing such as bungalows, “downsize” accommodation and dwellings to fit growing
families.
• If the linguistic and cultural vitality of rural villages is encouraged to grow from the inside, then rigid
caps are not appropriate.
CONSIDERATIONS:
1. To measure each application for a residential dwelling on its merits in the context of its
community, not only the context of development boundaries.
2. To assess the potential for development within or bordering the development limits in
the context of the particular settlement, and provide flexibility of boundaries where the
geography/topography does not allow expansion.
3. To provide for exceptions where affordable/local needs housing cannot be
accommodated within or bordering the development limits.
4. To consider the need for market housing to meet the needs of those who will not qualify
for Affordable Housing.
5. To remove the 10% cap above the number of existing homes in the settlement.
LDP: HOM4: Homes in Non-Defined Rural Settlements
Proposals for new single homes in settlements, hamlets and groups of dwellings which are not identified
under Strategic Policy SP3 will be permitted where they meet a local need for affordable housing and
conform to the following:
• It represents sensitive infill development of a small gap within an otherwise continuous built-up
frontage; or, is an appropriate rounding off of the development pattern;
• The development is of a scale that is consistent with the character of the area;
• The proposal will not result in an intrusive development in the landscape, and will not introduce a
fragmented development pattern;
• The size of the property reflects the specific need for an affordable dwelling in terms of the size of
the house and the number of bedrooms;
• That the occupancy of the dwelling is restricted both on first occupation and in perpetuity to those
who have a need for an affordable dwelling.
11.93 There are a notable number of small settlements or groups of dwellings throughout the County which
have not been defined within the settlement framework, and as such do not have development limits.
11.94 It is also noted that such provision needs to be delivered within the backdrop of a national agenda
centred on sustainability with placemaking at its heart. In this respect reference is made to the provisions of
PPW Ed.11 which requires that all residential development away from existing settlements or centres be
strictly controlled. The policy therefore in reflecting the provisions of national policy restricts local
affordable need dwellings in rural areas to established groups of dwellings.
PPW Strategic Placemaking 3.44: Consideration should be given to whether specific interventions from
the public and/or private sector, such as regeneration strategies or funding, are required to help deliver
the strategy and specific development proposals.
PPW Development in the Countryside 3.60: Development in the countryside should be located within
and adjoining those settlements where it can best be accommodated in terms of infrastructure, access,
habitat and landscape conservation. Infilling or minor extensions to existing settlements may be
acceptable, in particular where they meet a local need for affordable housing or it can be
demonstrated that the proposal will increase local economic activity. However, new building in the
open countryside away from existing settlements or areas allocated for development in development
plans must continue to be strictly controlled.
5
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
PPW Housing Delivery 4.2.24: In the open countryside, away from established settlements recognised
in development plans or away from other areas allocated for development, the fact that a single house
on a particular site would be unobtrusive is not, by itself, a good argument in favour of permission;
such permissions could be granted too often, to the overall detriment of the character of an area.
11.95 Whilst the Revised LDP is supported by a robust evidence base it is acknowledged that details of
housing need changes over time. Affordable housing proposals will be required to submit evidence
demonstrating the specific local need and ensure that the proposal provides for the size, type and tenure of
houses required. Proposals to meet speculative local need application will not be considered, rather they
should relate to an identified need from individuals/families within the specific area.
11.96 Where available, local housing needs surveys should be utilised in providing this evidence.
Alternatively, other forms of evidence may be considered appropriate including Strategic Housing Market
Area Assessments and local needs/Lettings registers.
Observations:
• Each regulation is based on geography and existing development patterns. The “protection” of the
settlement image takes priority over the actual needs of local people.
• There is no provision at all for dwellings which are not Affordable Housing. Not all local people need
Affordable Housing, but they have Local Housing Needs for a variety of reasons.
• Small Settlements or Groups of Dwellings are common in our rural countryside. While needing to be
“controlled”, exceptions should be possible where there is evidenced local need.
• Such exceptions should not be limited to Affordable Housing as many mature members of the
community do not qualify. Older members of the community have a strong need to remain in their
community for reasons of health, mental health and social interaction.
• Box-ticking to qualify for Local Needs does not always allow local people to express their unique
needs or to argue their case outside the specific requirements.
• While Local Needs/Letting registers may confirm the needs of young families seeking housing, many
members of the community who have local needs are excluded from housing registers.
• Retiring local farmers or other rural workers will not qualify for Affordable Housing in their life-long
community. No provision is possible for families or individuals who need to stay within their support
network in Non-Defined Rural Settlements.
CONSIDERATIONS:
1. To prioritise the needs of the people and the community over the visual or conceptual image
of the settlement.
2. To use the actual housing needs of applicants to drive the policy, not devise a policy which
excludes the very housing needs it is intended to address.
3. To provide some capacity with the policy for those who do not qualify for Affordable
Housing but whose needs are equally important.
4. To define what “too often” means in granting permissions in the open countryside, and
consider the local needs of individuals above non-defined caps.
5. To consider the need within the community for young families, not only the need of a family
to live in a location.
6. To provide a needs-assessment which is not exclusively a “box-ticking” exercise.
7. To prioritise matching the needs of individuals with the needs of the community over
reducing numbers on Housing Registers.
LDP: AHOM2 - Affordable Housing - Exceptions Sites
Proposals for 100% affordable housing development on sites adjoining the Development Limits of defined
settlements (Tiers 1-3 in Policy SP3), will, in exceptional circumstances be permitted where it is to meet a
genuine identified local need (as defined within the Glossary of Terms) and where:
6
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
• 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;
• The benefits of the initial affordability will be retained for all subsequent occupants;
• It is of a size, scale and design compatible with an affordable dwelling and available to low or
moderate income groups;
• There are no market housing schemes within the settlement, or projected to be available which
include a requirement for affordable housing.
TAN 6: 2.2.4: They (planners) should also ensure that any sites identified for development are effectively
available and likely to be brought forward for development by the owner. This is particularly important in
smaller settlements, where a limited number of landowners may control land supply
TAN 2: 10.12: It is important that there is adequate housing provision in rural areas to meet the needs
of local people and to contribute to the delivery of sustainable communities. Development plans must
set out how planning at the local level will contribute to meeting identified rural affordable housing
needs.
TAN 2: 10.16 Local planning authorities must set out in their development plan their definition of ‘local
need’ for affordable housing in rural areas, within the overall aim of contributing to the delivery of
sustainable communities. This can include:
• existing households needing separate accommodation in the area;
• people whose work provides essential services and who need to live closer to the local
community;
• people with a family connection or long standing links with the local community; and
• people with a job offer in the locality who require affordable housing.
For some of these categories the area within which needs will be considered ‘local’ must also be
defined in the development plan. This may include:
• the village or group of villages;
• the community council area;
• an electoral ward or group of wards;
• the local authority area.
TAN 2: 10.14 Rural exception sites are not appropriate for market housing.
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 departure from these standards may be considered
appropriate where they are to meet the occupant's needs and are clearly evidenced and justified.
Observations:
• Availability of land dictates the potential for Exception Sites.
• While Exception Sites provide the potential for Affordable Housing adjoining Local Development
boundaries, this may not be possible in many rural villages.
• The topography of our area does not always permit development outside existing settlements and
steep gradients make affordable construction unviable.
• Where land may be available, other factors may not meet requirements such as Highways, SAB
assessments etc. thus limiting the potential for development.
• Non-availability of land in and around Defined and Non-Defined Rural Settlements results in no housing
to meet local needs.
7
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
• There are natural boundaries between communities which dictate social interaction. A nearby
community, across a river or motorway, may be more alien to a local individual than a town twenty
miles further afield.
• There is no provision at all for market housing in many rural settlements. If you don’t qualify for Local
Needs, or there is no Local Needs capacity in your community – you can’t live there.
• The size, scale and design of Affordable Housing cannot accommodate a growing family, especially
where children are not all of the same gender and vary in age.
• “Exceptional Circumstances” may not be so exceptional. Some quite ordinary circumstances exclude
local people from qualifying for Local Need.
• Young families wishing to return to their area to bring up their children and who have owned a
home in another area will not qualify for Affordable Housing, but cannot afford open market
housing.
• There is no guidance on what constitutes an “exception”. The policy accommodates nuclear families
with 2.4 children. There is no provision for Blended Families whose needs are more varied and
extensive.
CONSIDERATIONS:
1. To acknowledge that Exception Sites are at the discretion of local landowners, access/highways
restrictions, SAB requirements and other limiting factors.
2. Where no Exception Sites can be identified, to exercise flexibility in considering alternative sites
which may deviate from the current permitted sites.
3. Where particular individual “locality” needs are identified, to consider applications for nonaffordable
housing development in the interest of the individual, the family and the community.
4. To consider the definition of “local” in the context of the individual and the community rather
than by a radius of concentric miles.
5. To assess the needs of growing families when calculating the size, scale and design of Affordable
Housing in order to provide long-term security and a decent quality of life.
6. To acknowledge the housing aspirations of young families in rural areas as a material planning
consideration.
LDP: EME4 - Employment Proposals on Non-Allocated Sites
Proposals for employment development on non-allocated sites, but within the development limits of a
defined settlement will be permitted where:
• it is demonstrated that no other suitable existing or allocated employment sites or previously
developed land can reasonably accommodate the proposal;
• the development proposals are of an appropriate scale and form, and are not detrimental to the
respective character and appearance of the townscape/ landscape;
• The development is compatible with its location and with neighbouring uses.
Employment proposals outside the development limits of a defined settlement (Policy SP3) will be permitted
where:
• The proposal is directly related to a settlement or hamlet; or
• The proposal is supported by a business case which demonstrates that its location is justified; and
• The proposal is of an appropriate scale, size and design.
11.165 For proposals outside the development limits of a defined settlement, they must show that they are
directly related to a settlement or hamlet, or supported by a business case which justifies its location. The
Plan 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. Many commercial and light manufacturing
activities can be appropriately located in rural areas without causing unacceptable disturbance or other
adverse effects. In this respect, the development of small businesses would address any local need for
employment accommodation.
8
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
PPW: The Rural Economy 5.6.4 To unlock the full potential of rural areas, planning authorities should
adopt a positive approach to employment arising from foundation and innovative and technology
based sectors, including research and development, in addition to employment arising from the
traditional agriculture, forestry and leisure sectors. Proposals for diversification, new startups and
micro-businesses should also be encouraged, where appropriate, to generate new job and wealthcreating
opportunities.
TAN 6: 2.2.2: Development plans should define local need taking into account the social, economic and
environmental characteristics of the area. Where possible existing definitions of local need,
for example affordable housing to meet local need, should be adopted, or if necessary modified
to include other land uses.
Observations:
• There is no connection provided between Employment on Non-allocated Sites and the needs of rural
villages to remain sustainable. Living and working within the community is vital to its existence.
• Some capacity has to be provided to acknowledge the place of small-scale businesses within rural
communities. There is no provision for small-scale commercial enterprises.
• The increase in home-working needs to be supported by flexibility across all genres of employment.
Additional space may be needed – inside and outside development limits – to accommodate future
working practices.
• This will be mitigated by reduction in travel and healthier work-life balances, thus meeting the aims
of our well-being goals.
CONSIDERATIONS:
1. To apply flexibility in meeting the needs of local people to work within their community.
2. To provide working spaces which accommodate local employment in areas outside or
without development limits.
3. To encourage satellite working as and when technology permits during the lifetime of the
LDP.
LDP: SP 8 - Welsh Language and Culture
The Plan supports development proposals which safeguard, promote and enhance the interests of the
Welsh language and culture in the County. Development proposals which have a detrimental impact on the
vitality and viability of the Welsh language and culture will not be permitted unless the impact can be
mitigated. All development proposals subject to WL1, will be expected to identify measures which enhance
the interests of the Welsh language and culture.
11.174 The Plan seeks to 'promote the Welsh language and culture'[59] and is committed to contributing to
the Welsh Government's long-term aim of achieving 1 million Welsh speakers by 2050[60]. To deliver on this
aim, the Council will support, promote, and enhance the Welsh language as a viable community language
by ensuring that there are sufficient and proportionate employment and housing opportunities to sustain
both the rural and urban communities in the County and by implementing an effective monitoring
framework. In doing so, the Plan seeks to ensure that the local population have the opportunity to remain in
Carmarthenshire rather than leave in search of work opportunities and housing, as well as the opportunity
to return. Through aiming for sustainable growth, the Plan will also maximise opportunities for non-Welsh
speakers who move to the County to be integrated into community life at a scale and pace that will not
undermine the vitality and viability of the Welsh language and culture.
11.177 The Plan also seeks to safeguard, promote, and enhance the Welsh language in Carmarthenshire
through other relevant policy objectives, namely through the provision of housing and affordable housing,
promoting a vibrant economy and employment opportunities and the provision and retention of community
facilities, amongst others.
9
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
TAN 20: 1.4.8 Section 70(2) of the Town and Country Planning Act 1992 (TCPA) clarifies that
considerations relating to the use of the Welsh language may be taken into account when determining
applications for planning permission, so far as they are material to the application. This may apply to
any application in any part of Wales. This provision does not give any additional weight to the Welsh
language above any other material consideration.
LDP: WL1 - Welsh Language and New Developments
All development proposals throughout Carmarthenshire will be required to safeguard, promote and
enhance the Welsh language … Proposals which do not accord with the Plan's housing trajectory will be
required to provide a phasing plan outlining the timescales for delivering the homes proposed on the site
and demonstrate that they would not have a negative impact upon the Welsh language which cannot be
mitigated.
11.178 The Welsh Language Action Plan sets out the measures to be taken to safeguard, promote and
enhance the Welsh language. The Welsh Language Action Plan should also outline how the development
proposes to make a positive contribution towards the community's Welsh language groups. This could,
amongst others, include providing support and funding towards organisations and bodies that provide
activities, facilities and education for Welsh speakers and learners, and support and funding towards Welsh
language classes. Welsh Language Impact Assessments (WLIA) will be required to outline the anticipated
impacts of the proposed development upon the Welsh language in the County. The Welsh Language
Supplementary Planning Guidance[61] provides further guidance on when a WLIA is required, clarifying
what constitutes a large scale development, as well as how to produce a WLIA.
11.182 The ISA of the LDP is required to assess the likely effects of the LDP upon the Welsh language. This is
done iteratively at key stages throughout the Plan's production. The likely anticipated effects are presented
in the ISA report, and further information is available within the LDP's evidence base.
TAN 20: 3.3.2 Evidence from the language impact assessment may be material to the application and
may inform whether measures to mitigate or enhance the impacts of the development on the use of
the Welsh language should be applied.
Welsh Language County Strategic Forum: “Language planning work within the LDP process, particularly
the development of a new methodology to measure the impact of land use on the Welsh language” notes
a “Lack of national guidance and dependable information on the impact of construction on the Welsh
language in terms of numbers of permitted locations for house building and their geographical locations.”
Carmarthenshire Welsh Language Promotion Strategy 2023 – 2028: p.7 Despite the positive contribution
of all the above policies, a number of factors that most adversely affect the Welsh language in
Carmarthenshire remain outside their scope. The affordability of housing for local young people for
example is largely influenced by the open market and private sector profits. The same is true with regard
to the influx of older people from outside Wales into Welsh-speaking communities. After the first
Strategy's efforts to work with estate agents to try to gain useful information to address this problem, it
must be recognised that it is only Welsh Government who are in a position to meaningfully influence these
factors. We look forward to working together on innovative efforts by the government in this area of work
and to explore new law-making forces that could mitigate harmful effects on the Welsh language.
Welsh Government: CYMRAEG 2050: a Million Welsh Speakers: Development and the Welsh language -
p.63: The land use planning system should contribute to the vitality of the Welsh language by creating
suitable conditions for thriving, sustainable communities, supported by an awareness of the relevant
principles of language planning. Decisions regarding the type, scale and exact location of developments
within a specific community has the potential to have an effect on language use, and as a result on the
sustainability and vitality of the language. This calls for strengthening the relationship between language
planning and land use planning.
10
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
Cyngor Sir Gâr: Notice of Motion 10.7.2019 (unanimously supported): “This council believes that the
whole of Carmarthenshire is an ‘area of linguistic sensitivity and significance’ and that the planning system
has a crucial role to play in supporting the Welsh language across the county. To this end, we believe that
the language should be a Material Planning Consideration in all applications for the development of five or
more houses in rural areas and ten or more in urban areas in every community, irrespective of the
percentage of Welsh speakers.
Observations:
• Cyngor Sir Gâr’s Notice of Motion identifies the whole county as an area of linguistic sensitivity and
as such should be recognised as a positive material consideration in rural areas.
• In reality, the Plan does not acknowledge the importance of small rural communities in its
safeguarding and enhancement of the Welsh Language. Many of our rural villages are the
strongholds of first-language Welsh-speakers and form the foundation of Welsh language and
culture throughout the county. Welsh speakers are concentrated in these areas, but the ability of
young families to live and work within these communities is limited by the Plan and other regulatory
factors.
• The Plan addresses two aspects of Welsh-language safeguarding:
a) It requires assessments on the impact of developments on the Welsh language;
b) It provides for activities, facilities and education which promote the Welsh language;
• The Plan does not provide for sensitive development within the small community strongholds of the
language. Welsh-speakers who cannot build or buy within their villages, or in the surrounding areas,
cannot support the language in their native communities.
• Local people may have access to land which would reduce costs and make the building of their own
home viable. Proportionate development on private land should be made possible where
appropriate.
• Rural Welsh-language villages need proactive policies to offer accommodation in the community –
both to young families in need of Affordable Housing and to those requiring market housing.
• Assessments of the likely effects of the LDP on the Welsh language will depend on the detail
available and be data-led.
• Pre-planning Welsh-language Assessments are appropriate for larger developments in service
centres and towns, however, external assessments do not evidence the actual prosperity of the
language in small villages and communities.
• Welsh-language impact assessments are commissioned by the applicant and may not always be
independent.
• A reversal of thought is required so that the needs of the Welsh language influences the LDP rather
than the LDP attempting to react to perceived needs.
• The data on Welsh-speakers in Carmarthenshire has not yet been based on the 2021 Census and is
out of date.
• There is very little planning guidance attached to the Welsh Government policy to achieve one million
Welsh speakers by 2050.
• While the CYMRAEG 2050 policy calls for strengthening the relationship between language planning and
land use planning, Welsh Government’s own planning policies make this impossible.
CONSIDERATIONS:
1. To recognise the Linguistic Sensitivity of the whole county and the potential of rural
communities to increase the number of Welsh-speakers if supported proactively through the
LDP.
2. To move from assessing impact to providing positive measures to develop Welsh-language
strongholds.
3. To acknowledge that strict controls on market housing in rural areas harms Welsh-language
communities.
4. Where development is evidenced through local need, to balance the potential visual harm to
rural areas against the potential benefit to language and culture.
11
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
5. To provide a body to conduct Welsh-language impact assessments which is independent of
the applicant and the Local Planning Authority.
6. To re-assess Welsh-language impact policies as soon as the 2021 Census data is available.
7. To recognise the need for Welsh Government to explore new approaches to planning in
rural areas in order to enable local Welsh Language Strategies to be implemented and to
enable CYMRAEG 2050 to be a realistic possibility.
LDP: SP11 - The Visitor Economy: Respecting the County's social, economic and environmental fabric.
11.234 All parts of the County possess qualities that contribute to the overall sense of place. These include
landscape, nature conservation, social fabric and built environment. These are assets which must be
protected for our future generations and cannot be unduly compromised by tourism related development.
11.235 There should also be an emphasis on providing quality in all aspects of a proposal. In considering the
acceptability of proposals, consideration will be given to location, siting, design and scale, access to the
primary and core highway network and the impact of any resultant traffic generation. Furthermore, the
extent to which the site is serviceable by public transport, walking and cycling are important considerations.
Proposals should reflect the character and appearance of the area with appropriate landscaping and
screening utilised as required.
11.239 The County's rural areas are well placed to accommodate proposals for high quality and sustainable
proposals that are of an appropriate scale. Proposals should respect the County's assets whilst supporting
vibrant rural communities.
11.240 Some tourism related developments, by their very nature, must be located in the countryside. It is
important that these developments do not have any significant negative impact on the landscape, natural
environment, or amenity. In terms of the detailed policies for the Revised LDP, the emphasis is on providing
clarification on the two notable challenges and opportunities facing the visitor economy in Carmarthenshire
which are attractions (somewhere to go) and accommodation (somewhere to stay).
LDP: VE2 - Holiday Accommodation
Proposals for high quality serviced accommodation, including appropriate extensions to existing
accommodation, will be permitted where they are located within, or directly related to a defined settlement
(Policy SP3).
Proposals for serviced and self-catering accommodation that are located outside of the above locations will
only be permitted where they consist of the re-use and adaptation (including conversion) of existing
buildings in conjunction with policy RD4.
All proposals set out above should reflect and respect the role and function and sense of place of the area,
most notably in terms of scale, type, character, design, layout and appearance - as well as those uses
already located in the vicinity of the site.
11.247 Where planning permission is given for permanent holiday accommodation, the Council will
consider the attachment of conditions restricting the use to holiday accommodation only. Seasonal
occupancy conditions may also be used to prevent the permanent residential occupation of such
accommodation. In addition, in areas where the prevalence of second homes and holiday homes are known
to be a serious issue within communities, the Council will consider placing restrictions upon permitted
development rights to change existing dwellings to holiday homes and second homes.
LDP: VE4 - Static Caravan and Chalet Sites and Permanent Alternative Camping Accommodation:
Proposals for new Static Caravan and Chalet Sites will be permitted where:
• they are within or directly related to a defined settlement (Policy SP3), or, they are located or
demonstrate a spatial and functional relationship with a relevant existing tourism facility or
attraction;
• they are of high quality in terms of design, layout and appearance, and will not have an
unacceptable adverse effect upon the surrounding landscape and/or townscape;
12
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
• they will not lead to a significant and unacceptable intensification in the provision of sites in the
locality;
Proposals for the enhancement and extension of existing sites will be permitted where:
• it will increase the vitality, sustainability and environmental quality of the site;
• it will not result in an unacceptable increase in the density of units and/or the overall scale of the
site.
• it will not have an unacceptable harm on the surrounding landscape, seascape and / or townscape;
• it provides (where appropriate) for the significant improvement of the overall quality, appearance
and setting of the site.
11.256 This policy recognises that appropriate high-quality proposals should be supported. This recognises
the need to provide a diverse accommodation offer in terms of providing a range and choice of places to
stay within the County.
TAN13: TOURISM – Published in 1997, this document is woefully inadequate to address the needs of
accommodating visitors in 2023 and the future.
Observations:
• “The County’s rural areas are well placed to accommodate proposals for high quality and
sustainable proposals that are of an appropriate scale” suggests that tourism developments take
priority over residential developments. Nowhere does the Plan refer to residential development
located in the countryside in such positive terms, but tourism is accommodated with flexibility.
• The re-use and adaptation (including conversion) of existing buildings outside a settlement is
permitted for visitor accommodation but not for housing for local people.
• No evidence is provided to illustrate why holiday accommodation is considered to have less impact
on the countryside than residential dwellings. This in no way suggests that there be should be
competition between both uses, but it is not clear how holiday accommodation makes a greater
contribution to sustainable communities than housing for local people.
• A “spatial and functional relationship with a relevant existing tourism facility or attraction” includes
the open countryside. If static Caravans and Glamping Pods are of a scale, layout and design
appropriate to the setting, and if properly screened, such developments provide diversification
income to rural areas while providing much needed visitor accommodation.
• The rigidity of travel planning restrictions where public transport is not readily available bars much
unintrusive development.
• While Static Caravan, Chalet and Glamping Pod Sites in rural areas are subject to rigid planning
regulation, the ownership and use of these units as second homes prevents the purchase of
residential family dwellings for holiday purposes. This helps protect traditional rural homes from
second home use, while purchasing a chalet on a park is far less costly as a second home than
purchasing a house.
CONSIDERATIONS:
1. To question if the visitor economy is prioritised over local needs, and consider both
community benefits on equal terms.
2. In light of the recent policy on Second Homes/Holiday Homes Council Tax Premium, to
consider permitting residential use of existing holiday accommodation in the open
countryside which may no longer remain viable.
3. To recognise that small, well-designed accommodation sites in the open countryside provide
diversification opportunities to farming communities and contribute to the local economy.
4. To encourage well-sited Static Caravan, Chalet and Glamping Pod Sites in areas heavily
affected by second home use as an attractive option to potential second home purchasers.
5. To provide a balance of residential and tourism accommodation in rural areas to encourage
mutual support between communities and visitor economy.
6. To replace TAN13 with guidance which is appropriate and relevant to the life of the Plan.
13
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
LDP: SP 12 - Placemaking and Sustainable Places
11.269 The Act means that public bodies such as local authorities must work to ensure that developments
should acknowledge and seek to improve the economic, social, environmental, and cultural well-being of an
area.
Observations:
• With regards to social and cultural well-being, there is no provision for placing small rural
communities at the centre of policy, or for building the policies around the needs of village
communities.
CONSIDERATIONS:
1. To recognise the place of small communities in achieving the aims of the Well-being and
Future Generations Act.
2. To allow rural communities to improve and grow on a par with urban communities.
LDP: SP 13 - Rural Development
11.366 The rural settlements of the County have an important role to play in improving the sustainability of
the wider geographical area in which they are located as well as the County's overall sustainability. The
Plan's strategy and settlement hierarchy reflects the significant role which the rural communities play
through supporting growth of a proportionate scale which can make a positive contribution towards the
long-term sustainability of the rural economy and rural communities.
11.367 Proportionate and sensitive development can provide the level of growth required to retain and
enhance the services and facilities provided in the County's rural settlements. It can also serve to safeguard
and promote the Welsh language in rural areas and enhance rural employment opportunities. However, the
Plan seeks to ensure that development and growth does not have negative impacts upon a community's
sustainability. Key to this is ensuring that development is not permitted at a scale or rate which would affect
the community's ability to absorb and adapt to growth and change. This is imperative when considering the
impacts which development can have upon the local infrastructure, the vitality of the Welsh language and
the sustainability of the countryside and natural environment.
11.368 National planning policy has historically sought to restrict unnecessary development in countryside
locations, principally to prevent sporadic and unsustainable growth and to maximise use of infrastructure,
resources and services more commonly available in established urban areas.
11.369 Whilst this principle remains relevant and applicable, there is an enhanced recognition of the
countryside as a place of work, as a home for many, a place to visit for others and a vital ecosystem for
everyone. The Plan is committed to addressing and safeguarding the needs of rural communities. To this
end, the Council established a Rural Affairs Task Group with the aim of assessing the needs of rural
communities and taking positive steps to address these. This Plan supports the aims and outcomes from the
Task Group principally through policies relating to the provision of housing and affordable housing; the
economy and employment; the Welsh language, and the natural environment. Development proposals will
need to demonstrate that they accord with these policies as well as the provisions of national planning
policy.
PPW: Placemaking in Rural Areas 3.38: The countryside is a dynamic and multi-purpose resource. In
line with sustainable development and the national planning principles and in contributing towards
placemaking outcomes, it must be conserved and, where possible, enhanced for the sake of its
ecological, geological, physiographic, historical, archaeological, cultural and agricultural value and for
its landscape and natural resources. The need to conserve these attributes should be balanced against
the economic, social and recreational needs of local communities and visitors. Fostering adaptability
and resilience will be a key aim for rural places in the face of the considerable challenge of maintaining
the vibrancy of communities and availability of services as well as contributing to the Cohesive
Communities well-being goal.
14
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
11.373 This understanding of diversity is reflected within PPW in its consideration of sustainable transport
requirements. It recognises there is a need to reflect different approaches to sustainable transport in
defining growth within rural settlements.
TAN 6: 2.2.3 Where development proposals are intended to meet local needs, planning authorities
should recognise that a site may be acceptable even though it may not be accessible other than by the
private car. Development not intended to cater primarily for local needs should continue to be located
in market towns, local service centres or clusters of smaller settlements where a sustainable functional
linkage can be demonstrated and which are accessible by public transport.
Observations:
• “The Plan is committed to addressing and safeguarding the needs of rural communities” - the Plan
does not address the needs of rural communities.
• The Rural Affairs Task Group states that:
“There is of course a recognition of the need for sensitive consideration of a number of factors
when looking at development in rural areas but the Task Group feels that current planning
policy from Welsh Government does not give enough flexibility to enable development, based
on local need, in our most rural communities.”
• While the preservation of the countryside is important, the policy “moth-balls” rural villages as
static entities and “enhances” them by keeping them attractive to visit and view. The policies invite
people to observe the attractive characteristics – culture, tradition, Welsh-language without
attempting to develop these characteristics and make them sustainable.
• Sustainable transport policies are limiting the development of rural housing while they encourage
extending the development of holiday accommodation. The travel footprint of weekly visitors to
and around rural areas is not measured against the travel footprint of weekly activities of local
residents.
CONSIDERATIONS:
1. To place rural communities at the heart of the Strategic Policy.
2. To provide “…enough flexibility to enable development, based on local need, in our most
rural communities”.
3. To define “enhancement” in material terms as regards sustaining and developing the
language, culture and heritage of our rural areas.
LDP: Rural Enterprise Dwellings
11.379 As noted through national policy, a rural enterprise dwelling is required where it 'is to enable rural
enterprise workers to live at or close to their place of work'. This includes encouraging younger people to
manage farm businesses and supporting the diversification of established farms.
11.380 It is not the role or the intention of the Revised LDP to replicate the provisions of national planning
policy. Consequently, reference should be had to the provisions of PPW and Technical Advice Note 6 (TAN6)
in the determination of applications for new rural enterprise dwellings. National policy clearly states that
such proposals should be carefully examined to ensure that there is a genuine need.
11.381 Applications for rural enterprise dwellings should be accompanied by a rural enterprise dwelling
appraisal, with permission only granted where it provides conclusive evidence of the need for the dwelling.
TAN 6: 4.1.1 The Assembly Government’s vision for housing is for everyone in Wales to have the
opportunity to live in good quality, affordable housing, to be able to choose where they live and decide
whether buying or renting is best for them and their families. This vision is applicable to both urban
and rural areas.
15
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
Observations:
• The bar for proving “conclusive evidence of the need for the dwelling” is uniquely high for Rural
Enterprise Dwellings in comparison with other housing categories. The amount of necessary
evidence and the years required to compile data makes such applications prohibitive.
• TAN6: 4.1.1 contradicts the lengthy and detailed restrictions placed on individuals and families
attempting to remain in their local community.
• The need to live near a rural enterprise should not be assessed on the employment needs of the
enterprise alone. Families support rural enterprises in many other ways, not only through their
employment on the site.
• Families in alternative fields of employment who have strong ties to the site should be encouraged
to remain within their traditional and cultural setting.
CONSIDERATIONS:
1. To bring the requirements of Rural Enterprise Dwellings in line with the requirements of
all other housing requirements – including urban housing and One Planet Development
housing.
2. To apply the same test of need for a rural enterprise dwelling as that for a dwelling on a
One Planet site.
3. To recognise the potential contribution of Rural Enterprise Dwellings to the sustainability
of language, culture and heritage.
4. To acknowledge that creating an additional dwelling on a rural enterprise site supports
the business and family whether or not the residents are in the employment of the
enterprise.
LDP: RD2 - Conversion and Re-Use of Rural Buildings for Residential Use
Proposals for the conversion and re-use of suitable rural buildings for residential use will be permitted
where:
• the existing use has ceased, and its re-use would not result in the need for an additional
building;
• the design and materials are of a high quality, and the form and bulk of the proposal, including
any extensions, curtilage and access arrangements are sympathetic to and respect: the
surrounding landscape, rural character of the area and the appearance of the original building;
• Proposals for extensions should be proportionate and reflective of the scale, character and
appearance of the original building;
• the original building is structurally sound and any rebuilding works, necessitated by poor
structural conditions and/ or the need for new openings in walls, do not involve substantial
reconstruction;
• where applicable, the architectural quality, character and appearance of the building is
safeguarded and its setting not unacceptably harmed.
TAN 6: 3.6.1 Whilst residential conversions have a minimal impact on the rural economy,
conversions for holiday use can contribute more and may reduce pressure to use other houses in the
area for holiday use.
Observations:
• While RD2 permits the conversion of suitable rural buildings for residential use, the majority of
these buildings lie outside the development limits of rural villages and therefore cannot be
permitted as residential dwellings.
• This excludes a number of surplus farm buildings from being converted to homes for young local
families, although they can be converted for holiday use.
16
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
• It is asserted that residential conversions for holiday use can contribute more to the local economy.
Is there evidence that holiday accommodation contributes more to the local economy than
residential families? This statement does not consider factors such as holiday accommodation being
owned by individuals well outside the “local economy” and where the income goes directly out of
the local area, county or country.
• It does not consider the contribution a residential family makes to the local economy on a daily,
weekly and annual basis. A data-based study would provide evidence of this assertion.
CONSIDERATIONS:
1. To apply the same impact measurements of conversion to holiday cottages/barns on the
open countryside as to conversion to residential cottages/barns in the open countryside.
2. To provide evidence of the carbon footprint benefit of tourist against that of residents.
3. To permit re-use/conversion of surplus rural buildings for residential use side by side
with holiday use.
LDP: 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:
• 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;
• 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;
• There are no adverse effects on the setting or integrity of the historic environment.
11.104 The renovation of abandoned dwellings can make a small but important contribution to the needs of
an area. The architectural value of a number of derelict or abandoned dwellings often reflects the
traditional vernacular and should be recognised in the submission of such proposals. Extensions, access
requirements or other aspects associated with the proposal should be sympathetic to the character of the
original building and the landscape. Proposals which seek to make a positive contribution to the landscape
qualities of the area will be encouraged.
Observations:
• There is very little policy detail or guidance on the re-use of derelict dwellings or ruins to provide
homes for local families. The guidance for derelict dwellings is arbitrary and open to interpretation.
• Sir Gâr no longer has a “tradional vernacular” style of dwelling. Most modern houses have for
decades been built with breeze blocks. It is reasonable that farm buildings constructed from such
materials, possibly with re-facing, should be considered for adaptation as dwellings.
• As part of the Levelling Up strategy, the UK Government has consulted on the “Right to Regenerate”
bill which promises to re-use derelict buildings in public ownership, but not in private ownership.
• Farming unions are encouraging rural owners not to allow their property to fall into the
“Abandonment” category which will require full planning permission for re-instatement as a
residential dwelling.
CONSIDERATIONS:
1. To acknowledge the historic use of a derelict/abandoned dwelling in the open countryside in
order to return it to its traditional residential use.
2. In 2023, to recognise the reality of the nature of the construction of many 20th Century rural
buildings and consider their sensitive re-use as dwellings.
3. To encourage proposals which seek to make a positive contribution to the landscape
qualities of the area.
17
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
RE-USE OF PLACES OF WORSHIP
11.450 Many elements of the County's built and historic environment are protected through legislation or
other policy provisions, and as such do not require policies in the revised LDP. The Plan does not therefore
include policies in relation to facets of the built heritage such as Scheduled Monuments as they are
adequately protected elsewhere.
TAN24: Historic Assets of Special Local Interest - 8.1 - Historic assets that the local planning authority
may consider to be of special local interest are not accompanied by any additional consent
requirements over and above those required for planning permission. However, if such assets are to
contribute successfully to the conservation or enhancement of local character their status needs to be
clear in the development management process. If a local planning authority chooses to identify historic
assets of special local interest, it must include policies for their preservation and enhancement in the
local development plan.
Managing Change to Listed Places of Worship in Wales – Welsh Government: 5.13 Closed or Closing
Places of Worship: Listed places of worship may have a continuing and valuable contribution to make
to the community even when they are no longer required for worship. Before they cease to be used for
worship, it is important that there is no unnecessary delay in finding alternative uses compatible with
the significance of the fabric, interior, contents and setting of the building.
CADW - Historic Assets Of Special Local Interest: Local planning authorities may choose to identify
historic assets of special local interest - known as ‘local listing’ … Local listing is important because it
provides the base for local planning authorities to develop policies for their protection and
enhancement. This means that local planning authorities can manage change through the planning
system so that local historic assets continue to contribute to the vitality of the area … Local listing also
provides an opportunity for a community to get involved in the identification of historic assets of
special local interest and in caring for them appropriately.
Observations:
• There is very little guidance on the functional re-use of chapels and churches in rural communities
apart from their historic surroundings and facades.
• Many church and chapel buildings in rural areas are converted for holiday/second home use. This is
not consistent with the interests of “local listing” to preserve the contextual integrity of the
community asset.
CONSIDERATIONS:
1. To acknowledge that the LDP could include measures to assess, secure and re-use closed
Places of Worship for the benefit of the community.
2. To encourage conversations between representatives of closing Places of Worship, planners
and the community before disposal of the asset.
3. To consider placing covenants on Chapels and Churches being converted to dwellings to
ensure they are permanent residential dwellings rather than second homes in order to
protect the historic integrity of the building for the future.
4. To require that CADW exercises flexibility in its approach to the re-use of local historic assets
so that they remain of value and interest to the community.
LDP: RD3 - Farm Diversification
Proposals for farm diversification developments which strengthen the rural economy will be permitted
where:
• It is compatible with, complements and supports the principal agricultural activities of the existing
working farm;
• It is of a scale and nature appropriate to the existing farm operation;
18
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
• It has appropriate regard to the highways and transport infrastructure;
• It would not have an adverse impact on the character, setting and appearance of the area and the
surrounding landscape.
11.393 Diversification in rural areas can often add to the income streams and economic viability of farms,
strengthen the rural economy, and add to wider employment opportunities.
11.394 Farm diversification proposals are intended to supplement and support the continuation of the
existing farming activity. Proposals should be accompanied by evidence detailing a justification for the use
and its relationship with the existing farming activity.
11.396 In considering proposals for farm diversification it is acknowledged that their rural context means
that they cannot always be well served by public transport. Consequently, whilst its availability will be taken
into account when considering the nature and scale of the proposal, the potential for certain diversification
proposals which can only be accessible by private car is acknowledged. Such proposals should have regard
to the sustainable transport hierarchy.
Observations:
• While diversification in rural areas is encouraged, the capacity for young families to live and work on
rural sites outside development limits is severely restricted, bordering on the impossible. This is
detrimental to the sustainability of village communities.
• Many farm diversification plans are thwarted at the outset due to their rural siting, thus falling
under the myriad restrictions on development in the open countryside.
• The perceived negative aspects of potential development outweigh the likely positive impacts on
community sustainability.
CONSIDERATIONS:
1. To provide for local families who wish to remain in or return to their community to live and
work in their rural area.
2. To examine the potential community benefit as a material consideration.
3. To provide more flexibility in the sources of income which contribute to a rural enterprise to
allow spouses, partners and their progeny to remain in or return to their family homesteads.
GENERAL - MOVING RURAL CARMARTHENSHIRE FORWARD – Report and Recommendations of the
Carmarthenshire Rural Affairs Task Group – June 2019:
3.2.4: “The Council is currently in the process of revising its Local Development Plan and the Task Group
feels there is a need to redress the current balance to enable appropriate and suitable development
within our rural towns and communities. This development needs to be taken forward based on local
need rather than national targets and regulations. There should of course be a thorough consideration
and understanding of the impact that any residential or business development may have on the nature
and construct of rural communities, especially in terms of its possible positive or negative impact on
the Welsh language, and the size of development should also be comparative to the existing
community, but suitable development in our rural communities needs to be enabled in order to ensure
the sustainability of our rural communities going forward.”
Observations:
• The Task Group has analysed and attempted to address and evidence the critical issues
referenced above. However, it is apparent that the Local Development Plan continues to be led
by national targets and regulations rather than by genuine local need.
19
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
WALES RURAL OBSERVATORY - 2013:
The Experiences and Aspirations of Young People in Rural Wales (2013) Housing availability and
affordability - Young families’ experiences of the local housing market in the study areas also indicated
that the current planning system was considered too regulatory and rigid, and often hindered the
development of simple solutions to rural housing needs.
The Experiences and Aspirations of Young People in Rural Wales (2013): Access to the decisionmaking
process - There is growing awareness and interest among the public and policy-makers of the
important and critical role that young people play in forming and sustaining sustainable communities.
This is particularly crucial in terms of rural communities, where the ageing population trend is
particularly marked and where there has been a steady decline in the proportion of the younger
population. Despite this, young people are too often excluded from the decision-making process.
Observations:
• The conclusion of this study summarises the issues faced in our rural communities. Although this
study was published in 2013 there is no evidence that these conclusions are considered in the
development of planning policies.
SUMMARY OF CONSIDERATIONS IN RESPECT OF THE SECOND REVISED LOCAL DEVELOPMENT PLAN
1. The Plan looks at rural communities from the outside. There is no recognition of the living,
breathing, day-to-day rural village. The Plan needs to reverse its perspective.
2. The needs of real people are secondary to ideas, policies, regulations and planning
aspirations. The needs of rural families should be the primary consideration.
3. The projected image of the countryside takes priority over the people who live in it. The
people who create, enhance, protect and conserve this image should be heard.
4. Prohibiting development in many rural communities is contrary to the planning presumption
to permit reasonable development in other geographic or demographic areas. The planning
presumption should be applied consistently across all areas.
5. The Plan does not consider the needs of local people who do not fit the Local Needs criteria.
Young professionals – teachers, nurses - who are not first-time buyers do not qualify for
Affordable Housing but can’t afford open market houses in their rural villages. The Plan
should apply the needs of the community as a material consideration and provide for all
young families.
6. Ordinary circumstances in urban areas are considered exceptional in rural areas. The Plan
should not mitigate against rural families and young people.
7. The social and economic benefits of small rural businesses are outweighed by the
requirement to project a particular image of the countryside. Small rural businesses are part
of the culture and inheritance of the countryside and should be encouraged within the Plan.
8. The Plan provides for projected damage to the Welsh language and culture in future
developments. It does not provide for the development of the Welsh language and culture
in its existing strongholds. The Plan is reactive to Welsh-language issues, not proactive. The
rural policies within the Plan should emanate from the Welsh-language strongholds to
achieve CYMRAEG 2050.
9. The Plan prioritises the visitor economy over local needs in rural communities. The tourist,
throughout the year, may eat, sleep and breathe the open countryside, but the local
resident may not. The Plan should provide for parity of opportunity between all rural
enterprises.
10. Amended Planning Use Classes (2022) requires that planning permission is needed to change
a residential dwelling to a holiday/second home. It will take many years for this amendment
to impact on rural house prices and availablity. The Plan should consider applying flexibility
while these factors bring some equity to housing availability in rural areas.
11. Placemaking and Sustainable Places policies are imposed on rural villages. The policies
should be formulated from the inside outwards, not the outside inwards.
20
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
12. Active Travel and other Carbon Net Zero requirements prohibit residential dwellings in rural
areas. The Plan excuses the visitor industry from similar carbon footprints. The Plan should
apply the same standards to residents and visitors alike and encourage both to work side by
side to reach targets.
13. The requirements for Rural Enterprise Dwellings are practically impossible to meet. This
does not conform with aspirations for sustainable rural communities. The requirements for
ALL residential dwellings across rural areas should be applied equally.
14. Any initiative inside or outside village development boundaries which could benefit local
residents is likely to be prohibited. Strengthening communities should be a material
consideration when assessing local initiatives.
15. Villages without settlement boundaries will not be able to accommodate the needs of their
own residents. The Plan must provide opportunities for such communities to flourish.
Rural villages are not Still Photographs.
They create, motivate, initiate, provide and support like any other community.
It is imperative that the Future Wales National Plan 2040 and the Carmarthenshire Local Development
Plan 2018 – 2033 acknowledge and respect the identity and function of our rural communities.
_______________________________________________________________________________________
Compiled and submitted by Plaid Cymru County Councillors, Cyngor Sir Gâr – April 2023
Cyng. Liam Bowen Cyng. Kim Broom
Cyng. Mansel Charles Cyng. Andrew Davies
Cyng. Bryan Davies Cyng. Ann Davies
Cyng. Glynog Davies Cyng. Handel Davies
Cyng. Karen Davies Cyng. Llinos Mai Davies
Cyng. Terry Davies Cyng. Arwel Davies
Cyng. Alex Evans Cyng. Colin Evans
Cyng. Hazel Evans Cyng. Linda Evans
Cyng. Tyssul Evans Cyng. Deian Harries
Cyng. Ken Howell Cyng. Peter Hughes Griffiths
Cyng. Meinir James Cyng. Gareth John
Cyng. Carys Jones Cyng. Betsan Jones
Cyng. Hefin Jones Cyng. Alun Lenny
Cyng. Jean Lewis Cyng. Neil Lewis
Cyng. Dai Nicholas Cyng. Aled Vaughan Owen
Cyng. Denise Owen Cyng. Dorian Phillips
Cyng. Darren Price Cyng. Emlyn Schiavone
Cyng. Russell Sparks Cyng. Dai Thomas
Cyng. Gareth Thomas Cyng. Elwyn Williams
21
LDP: Carmarthenshire County Council Second Deposit Revised Local Development Plan - Written Statement
TAN: Welsh Government Planning Policy and Guidance: National Policy - Technical Advice Note
PPW: Welsh Government Planning Policy Wales – Edition 11 2021
APPENDIX
Many elements of our planning system create complex dilemmas for Local Members and particularly for
Planning Committee Members when performing our roles and respecting our responsibilities:
• The role of the Local Member is to make the ward community a better place to live and work – to
improve quality of life and to develop and support plans which enhance and protect the
community, the environment and our future generations.
• The responsibility of the Local Planning Member is to observe the legislation, regulations and
guidance which are set down on our behalf to maintain Order within our communities, the Local
Authority and beyond.
The conflict between Members’ roles and Planning Members’ responsibilities gives rise to situations
where councillors are forced to compromise one in favour of the other. The Local Member is regularly
faced with two options:
• To support officers’ recommendations which are damaging to their own community in order to
conform with legislation, or
• To reject officers’ recommendations and act contrary to legislation in order to protect their
residents’ well-being.
It is not possible to reconcile this conflict under current planning policies.

Attachments:

Letter (439.90 KB)

Our response:

Noted. The Plan includes a range of policies and provisions in relation to the reuse of historic buildings such as places of worship. In this respect it has been prepared with regard to the provisions of PPW and other plans and strategies. The additional suggestions set out in this representation are beyond the remit of the Plan.

Object

Second Deposit LDP

Representation ID: 5916

Received: 12/04/2023

Respondent: Cllr. Ken Howell

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Observations:
• There is very little guidance on the functional re-use of chapels and churches in rural communities apart from their historic surroundings and facades.
• Many church and chapel buildings in rural areas are converted for holiday/second home use. This is not consistent with the interests of “local listing” to preserve the contextual integrity of the community asset.
CONSIDERATIONS:
1. To acknowledge that the LDP could include measures to assess, secure and re-use closed Places of Worship for the benefit of the community.
2. To encourage conversations between representatives of closing Places of Worship, planners and the community before disposal of the asset.
3. To consider placing covenants on Chapels and Churches being converted to dwellings to ensure they are permanent residential dwellings rather than second homes in order to protect the historic integrity of the building for the future.
4. To require that CADW exercises flexibility in its approach to the re-use of local historic assets so that they remain of value and interest to the community

Change suggested by respondent:

Amend Plan

Full text:

Whilst I fully agree with the proposals submitted by my colleague and fellow Councillor Carys Jones, I wish to submit that the allocation proposed for Drefach Felindre is limited and inadequate for the next ten years. In particular, the allocation of only three houses on the Waugilwen road should be doubled to six, which would accommodate future expansion of the village.

Submissions by Carys Jones - dealt with in another representation

Attachments:

email representation (431.88 KB)

Our response: