Include the site within the Plan.

We believe the proposed plan is incorrect and incomplete. In the 2006 - 2021 LDP a portion of the land, situated alongside Parc Mansant, Pontyates (T3/5/H2) was allocated for residential development. This is missing from the proposed plans and should be reinstated. In addition, we would like the remaining area of the field, highlighted in yellow and numbered 4618 & 5600, to be considered for residential development. When Parc Mansant was built in the early 1990’s planning permission took into consideration future development - therefore access, drainage and utilities were laid along the road at the entrance to the field in preparation for this.
The Site Assessment Methodology (Sept 2019) section 2a sets out the criteria that has to be met before moving to stage 2b. After reviewing the questions set out in this document, we believe that the proposed land does pass this stage such as:
• Accommodate more than 5 dwellings
• Accessible from 2 public highways
• Physically, functionally and visually linked to the settlement
• Close to Public Transport (Lime Grove Bus Stop)
• Water and sewerage connections are already in place
• Easy access with a road already in place
In addition the attached Sustainability Appraisal supports this application for residential development classification.

Suggests that the whole of the original Northern Residential Quarter Allocation (site T2/2/h1) should be included in the Revised LDP.

Dear Sir

I am writing about the 2nd Deposit Revised LDP with reference to the housing site adjacent to Parc Pencrug, Llandeilo.

Sole access via the restricted space of the existing Parc Pencrug estate and its steep hill is inadequate for the construction of the 27 houses shown in the LDP, also for the amount of traffic that would nowadays be subsequently generated by them . And this would be even more the case for the 86 homes currently being proposed for the site by Pobl

For the wellbeing of the residents of the existing Parc Pencrug estate and of the residents of the adjacent site a more suitable main access point is needed. And this suggests that the site of the whole of the original Northern Residential Quarter should be included in the LDP in order to allow for the provision of access for vehicles and pedestrians via Rhosmaen Street as proposed in 2009.

Yours faithfully

Robert Evans

Include the whole of site T2/2/h1 in the Plan

I refer to the above and in particular the proposals for Llandeilo with regard the area to the north of the town.
In particular I refer to housing allocation SeC16/H1 which is allocated for 27 units plus some affordable.

I am writing to object to the deletion of the strategic development area as was defined in the current adopted LDP as T2/2h1.
This is the most logical place to accommodate growth for the town and requires a strategic long term vision as was envisaged in the :

https://www.sirgar.llyw.cymru/media/1212896/briff-cynllunio-a-datblygu-llandeilo.pdf

The deletion of this strategic vision is a serious failing in the 2018-2033 LDP Revised Deposit.

The “incremental” and I suspect disconnected release of land in this northern area of the town as is apparent by the isolated allocation of SeC16/h1 in the Revised Deposit does not constitute the proper planning of the area and will result in a unsatisfactory form of development out of accord with the Council’s own SPG on Placemaking and Design.

Please acknowledge my submissions on the above and continue to advise me on the evolution of the 2018-2033 Revised Deposit as I would wish to make further representations depending on your responses .

Include site in the Plan

Previously, planning has been refused on the grounds ‘Inclusion of the site would result in an illogical extension to the settlement limits’ but due to the recent development of Parc Y Mynydd we believe it would serve as a continuation of housing for the local area.

The following comments aim to support our plea that insufficient planning allocation has been given to new builds in the area and the county as a whole.

1. We have statements from several local estate agents outlining a serious shortage of domestic property for sale. Please see the following John Francis statement.

"There is a huge shortage of properties on the market for sale and to rent. We have a list of buyers struggling to find a home and many of our sales fall through due to our vendors cannot find a property for themselves leading them to withdraw from the chain. As there is a shortage of properties and very little new developments within our area property prices are increasing as the properties on the market are attracting more than one interested party. There is a demand for all types of properties especially properties for first time buyers. There are schemes in place to help first time buyers get on the property ladder and mortgage lenders are offering good deals but unfortunately there is a shortage of stock. Our Land & New Homes area manager is constantly searching for land for new home developers to purchase and develop”.

2. The standalone company set up by Carmarthenshire County Council has bought and continues to purchase new first time buyer housing stock as soon as it reaches the market. This has impacted on the buying opportunity of the first time buyers in the area.

3. There is a lack of small scale development sites or self build plots. This means that small development companies and quality tradespeople, brickies and carpenters in particular, risk being closed out of the new build market. This could lead to a loss of quality tradespeople in the area in the long term.

4. The emphasis on large development sites, some with poor site management and poor design, makes for inferior housing stock in the area for the future. Smaller developers are known for better quality builds with higher quality features whereas the larger developments which are built at speed, often lacking in design features and build quality and exterior aesthetics visibly deteriorate rapidly over time.

5. The emphasis on social housing, where there is often not the demand from local people means that housing associations are parachuting those from far outside the area to occupy the properties. The impact on regional communities has been massive in some instances.

6. The eco houses recently built in the area are not a suitable or in-keeping with the surrounding housing environment and are not built to last. Replacing or adding several small development self-builds will yield high quality housing that will improve the aesthetics and longevity of the county housing market.

We have verbal accounts from a number of professionals and in due course will happily put together a portfolio of evidence to support our comments. We are also happy to speak in appeal. In the meantime, the County Building Regulations department are a wealth of knowledge of the issues involved in the building market in the county and the kind of properties that the county would benefit from. Organisations such as the LABC would also provide invaluable information regarding quality housing, who is building quality saleable properties and where. We believe that there is much scope for improvement of the current LDP to include sites such as ours, to build quality housing for our community.

We propose that the land put forward as part of this objection is included within the boundary line for up to 4 dwellings to allow future growth within Cwmgwili for the reasons stated within the covering letter.

We object to the omission of site SR/040/002 - Land at Blaengwili off Heol y Deri for residential development. The development provides a perfectly logical extension of the urban form within close proximity to all services and located within a sustainable location. The allocated site within the LDP SUv28/h1 has already been built out and therefore no new sites allocated going forward with tight development boundary limits.

Allocate site within Plan.

Previously, planning has been refused on the grounds ‘Inclusion of the site would result in an illogical extension to the settlement limits’ but due to recent and continuing planning consent on the old sawmill land (Cwrt Y Ffynnon), we believe it would serve as a continuation of housing for the local area, an additional application has also been submitted for SR/132/001.

The following comments aim to support our plea that insufficient planning allocation has been given to new builds in the area and the county as a whole.
1. We have statements from several local estate agents outlining a serious shortage of domestic property for sale. Please see the following John Francis statement.
"There is a huge shortage of properties on the market for sale and to rent. We have a list of buyers struggling to find a home and many of our sales fall through due to our vendors cannot find a property for themselves leading them to withdraw from the chain. As there is a shortage of properties and very little new developments within our area property prices are increasing as the properties on the market are attracting more than one interested party. There is a demand for all types of properties especially properties for first time buyers. There are schemes in place to help first time buyers get on the property ladder and mortgage lenders are offering good deals but unfortunately there is a shortage of stock. Our Land & New Homes area manager is constantly searching for land for new home developers to purchase and develop”.
2. The standalone company set up by Carmarthenshire County Council has bought and continues to purchase new first time buyer housing stock as soon as it reaches the market. This has impacted on the buying opportunity of the first time buyers in the area.
3. There is a lack of small scale development sites or self build plots. This means that small development companies and quality tradespeople, brickies and carpenters in particular, risk being closed out of the new build market. This could lead to a loss of quality tradespeople in the area in the long term.
4. The emphasis on large development sites, some with poor site management and poor design, makes for inferior housing stock in the area for the future. Smaller developers are known for better quality builds with higher quality features whereas the larger developments which are built at speed, often lacking in design features and build quality and exterior aesthetics visibly deteriorate rapidly over time.
5. The emphasis on social housing, where there is often not the demand from local people means that housing associations are parachuting those from far outside the area to occupy the properties. The impact on regional communities has been massive in some instances.
6. The eco houses recently built in the area are not a suitable or in-keeping with the surrounding housing environment and are not built to last. Replacing or adding several small development self-builds will yield high quality housing that will improve the aesthetics and longevity of the county housing market.
We have verbal accounts from a number of professionals and in due course will happily put together a portfolio of evidence to support our comments. We are also happy to speak in appeal. In the meantime, the County Building Regulations department are a wealth of knowledge of the issues involved in the building market in the county and the kind of properties that the county would benefit from. Organisations such as the LABC would also provide invaluable information regarding quality housing, who is building quality saleable properties and where. We believe that there is much scope for improvement of the current LDP to include sites such as ours, to build quality housing for our community.

Include site within the Plan

1. Introduction
We would like rear part of the dwelling called Myrtlebury Farm at Llannon Road, B4306 on the South edge of Pontyberem, to be considered as a candidate site to be
included in the new Local Development Plan.

2. Site Appraisal
This candidate site consists of the rear part the garden. It is of a rectangular shape and can be found just outside the settlement limits of Pontyberem Unitary
development plan.
The proposed site is a relatively flat grassed land with a gentle slope towards the road. It is bordered on three sides by mature hedgerows. No trees can be found on the land which could affect any development.
Myrtlebuury Farm now only consists of a single dwelling. The original farm house and outbuildings had been taken down a while ago.

3. Access
There is an existing access points farm on the Eastern side off Llannon Road which
will lead to the candidate site. There is no pedestrianized access and no public
footpath along the road.
At the point of entering the main road has a 50-mph controlled zone in place with a
good visibility standard in both directions up and down. No restrictions through tress,
bends or hedgerows. The road has got a good alignment

4. Flooding
The site lies well above the water level and in good distance from any water course.
No evidence can be found on the flood maps issued by the Environmental Agency –
Wales.

5. Pollution
This field is currently greenfield sites and use for grazing.
Evidence of a past development can be found on the land, which consisted of the
frame house, 2 cow sheds and a haybarn.
The radon level is under 1%.
No known contamination as happened to the land.
Not adjacent to a mineral buffer zone
The site does not lie in a sandstone recognised area.
No overhead power cable run through the field.
No activities have taken place which would have resulted in a contamination of the
soil or the sub soil.

6. Possible constrains
Overhead power cables run alongside the road and next to the candidate site. No
underground or phone lines would cause a problem for a possible development.

7. Main services
All services: mains water supply, foul sewer, electricity and high-speed electronic
communications networks, are on the site of Myrtle Farm right next to the candidate
site. The area is serviced by the local bin collection.

8. Historic Importance
The site is not in a conservation area.
None of surrounding buildings are listed.
No know or apparent feature of heritage of archaeological importance can be found
on the land.
No land infills took place.
The site has not been used for any industrial use or as a waste site.
No coal mining has been taken place on or in close proximity to the site.

9. Landscape and ecology
This site has been used for many years as part of the garden of the existing dwelling.
There is no knowledge of any protected species on or surrounding. However, a full
ecological survey would need to be necessary before any development could take
place.
This sloping site can be seen from the main road and up the valley. It is tucked
behind the existing farm house. New dwellings should be design with the
surrounding residential houses in mind.
Small trees and hedgerows are along parts of the northern, southern and eastern
boundaries. There is no defined boundary to the western side. It runs into the garden
of Myrtle Farm.
No large trees can be found on the site.

10. Settlement - Boundaries
This candidate site lies outside the settlement limits of Carmarthenshire as defined in
the local UDP -GR1. It is surrounded by residential development.
In the last LPDs (December 2014) a surrounding site in close proximity (just 2 fields
along) had been included; T3/6/h6.
Pontyberem is a small town which got all necessary amenities in close proximity.
 General hospital 9.5 miles
 Secondary school 5 miles
 Primary schools, less than ¼ mile
 Leisure centers, 9 miles
 Town center, ¼ mile
 Dentist & GP surgeries, ¼ mile

11. Transport links
The transport links to Carmarthen and Llanelli town are well established and
developed.
 train station is in Kidwelly, 8 miles away
 bus line is along Llannon Road with the next stop a few hundred meters down
the road.
 Carmarthen town 9 miles
 Llanelli town 8 miles
 A48 motorway link is 9 min away
 M4 is reached in 15 min

12. Conclusion
The site is very suitable for 2-3 dwellings. They would be tucked behind the exiting
resident development and can be serviced via the same access point. It should be
seen in a visual and functional connection between the dwelling at Myrtle Farm.
Given that this site is close to the existing dwelling as well as only some hundred
yards from a row of dwellings, along Llannon Road, we cannot see any obvious
adverse effect on the developments in close proximity.
Not enough house developments in Carmarthenshire, has been implemented since
the last LDP was approved, which has led to a shortfall of housing sites in
Carmarthenshire.
Especially in Pontyberem not a lot of sites had been included in the last LDP.
There would not be an increase in traffic given that there used to be a working farm
on this site which would have create a fair amount of movement onto the site.
The existing access can be used to serve the dwelling on the site as well as the new
development.
It is worth emphasising at the outset that the site:
 will help sustain the community by providing dwellings in a location that
reinforces the traditional settlement pattern;
 is of modest size and is situated adjacent to a proposed residential allocation;
 would not result in the loss of any important amenity feature or represent an
unacceptable intrusion into the landscape;
 would not give rise to any recognised highway or utility service provision
objections
 would fully comply with established planning policies that direct development
to sustainable locations in terms of proximity to urban facilities and a public
transport route.
 it is closely related to the main public transport corridors;
 the site is conveniently located in terms of schools and other services and
facilities;
 the site is not constrained by any significant environmental considerations,
including ecological designations;
 it will be contained within existing defendable boundaries and will not give rise
to any harmful precedent for further residential development.
 It is felt that there is scope for additional small sites to be identified to receive
residential development, in order to provide further choice.
 The inclusion would not create any amenity, highway or utility service provision
difficulty.

Include site in the Plan

1. Introduction
We would to include a field at the rear of Llannon Road, B4306 in the new Local
Development Plan. It can be found behind an area of land which has been included
the last LDP of a lane serving the Gwendreath Row development.

2. Site Appraisal
This candidate site consists of a gentle sloping field at the southern site of
Pontyberem. Mature hedgerows form the western and southern boundaries whilst
streams define the eastern and northern boundaries.
The parcel of land is sloping towards the North and an access lane. It is of a
rectangular shape and can be found just outside the settlement limits of Pontyberem
Unitary development plan.

3. Access
There is no direct existing access onto the main road. Access can be achieved either
though the adjoining field which was already include in the LDP or through another
adjoining field which the owner has put forward as a candidate site.

4. Flooding
The site lies well above the water level and in good distance from any water course.
No evidence can be found on the flood maps issued by the Environmental Agency –
Wales.

5. Pollution
This field is currently greenfield sites and use for grazing.
No evidence of a past development can be found.
The radon level is under 1%.
No known contamination as happened to the land.
Not adjacent to a mineral buffer zone
The site does not lie in a sandstone recognised area.
No overhead power cable run through the field.
No activities have taken place which would have resulted in a contamination of the
soil or the sub soil.

6. Main services
All services: mains water supply, foul sewer, electricity and high-speed electronic
communications networks, are in the next field along. The area is serviced by the
local bin collection.

7. Historic Importance
The site is not in a conservation area.
None of surrounding buildings are listed.
No know or apparent feature of heritage of archaeological importance can be found
on the land.
No land infills took place.
The site has not been used for any industrial use or as a waste site.
No coal mining has been taken place on or in close proximity to the site.

8. Landscape and ecology
There is no knowledge of any protected species on or surrounding. However, a full
ecological survey would need to be necessary before any development could take
place.
The predominate part of this field is used for grassing. The areas surrounding the
streams to the North and East are covered with an over ground coppice. It is nonaccessible completely overgrown with a mix of small trees, bushes and hedgerows.

9. Possible constrains
Overhead power cables run through the field and alongside the road at the candidate
site. Contact has been made to move those cables to a different position in another
field owned by the same person.
No underground or phone lines would cause a problem for a possible development.
A road access needs to be formed either onto Gwendraeth Row, which is only a
single lane but has potential to be widened. Most of the surrounding land is in the
same ownership and can be incorporated.
Another option would be to access this land either via a parcel of land which had
been include in the last LDP or via a field which the owner has put forward for a
candidate site as well.

10. Settlement - Boundaries
This candidate site lies outside the settlement limits of Carmarthenshire as defined in
the local UDP -GR1. It is surrounded by residential development.
In the last LPDs (December 2014) a surrounding site in close proximity (just 2 fields
along) had been included; T3/6/h6.
Pontyberem is a small town which got all necessary amenities in close proximity.
 General hospital 9.5 miles
 Secondary school 5 miles
 Primary schools, less than ¼ mile
 Leisure centers, 9 miles
 Town center, ¼ mile
 Dentist & GP surgeries, ¼ mile

11. Transport links
The transport links to Carmarthen and Llanelli town are well established and
developed.
 train station is in Kidwelly, 8 miles away
 bus line is along Llannon Road with the next stop a few hundred meters down
the road.
 Carmarthen town 9 miles
 Llanelli town 8 miles
 A48 motorway link is 9 min away
 M4 is reached in 15 min

12. Conclusion
From the Carmarthenshire housing policy statement, it would appear that there is a
need for around 15,000 houses in the LDP period. It also appears that there are
currently only around 5,000 committed allocations. Especially in Pontyberem not a
lot of sites had been included in the last LDP.
Further investigation should be taken into the vegetation and animal life of the
overgrown area along the streams. However, this can be left as a biotope which
would not affect any development.
Our proposed development can easily be joined to the fields included in the LDP last
time and seen as one. This would give more scope for a more “round” development
behind the dwellings along Llannon Row.
Various options are available for a new road access onto the roads. Either an
adjoining access for both sites direct onto Llannon Road, a new access over another
field we have put forward again directly onto Llanon Road or an access onto
Gwendraeth Row which could be widen and upgrade,
We cannot see any obvious adverse effect on the developments in close proximity.
There would an increase in traffic given amount of new dwelling which could be
erected in this field. However, the main road as well as the village can cope with
new developments and their traffic.

It is worth emphasising at the outset that the site:
 will help sustain the community by providing dwellings in a location that
reinforces the traditional settlement pattern;
 is of modest size and is situated adjacent to a proposed residential allocation;
 would not result in the loss of any important amenity feature or represent an
unacceptable intrusion into the landscape;
 would not give rise to any recognised highway or utility service provision
objections
 would fully comply with established planning policies that direct development
to sustainable locations in terms of proximity to urban facilities and a public
transport route.
 it is closely related to the main public transport corridors;
 the site is conveniently located in terms of schools and other services and
facilities;
 the site is not constrained by any significant environmental considerations,
including ecological designations;
 it will be contained within existing defendable boundaries and will not give rise
to any harmful precedent for further residential development.
 It is felt that there is scope for additional small sites to be identified to receive
residential development, in order to provide further choice.
 The inclusion would not create any amenity, highway or utility service provision
difficulty.

Include site in Plan

1. Introduction
We would to include a field along Llannon Road, B4306, next to the existing row of
street fronted dwellings to be considered as a candidate site to be included in the
new Local Development Plan.

2. Site Appraisal
This candidate site consists of a grassed sloping field at the southern site of
Pontyberem. Gently sloping towards the village. It is of a rectangular shape and can
be found just outside the settlement limits of Pontyberem Unitary development plan.
It is bordered on all four sides by mature hedgerows with a few trees, which will not affect
any development.

3. Access
There is an existing access points onto Llannon Road which is wide enough for a
new development site. There is no pedestrianized access and no public footpath
along the road.
At the point of entering the main road has a 50-mph controlled zone in place with a
good visibility standard in both directions up and down. No restrictions through tress,
bends or hedgerows. The road has got a good alignment.

4. Flooding
The site lies well above the water level and in good distance from any water course.
No evidence can be found on the flood maps issued by the Environmental Agency –
Wales.

5. Pollution
This field is currently greenfield sites and use for grazing.
No evidence of a past development can be found.
The radon level is under 1%.
No known contamination as happened to the land.
Not adjacent to a mineral buffer zone
The site does not lie in a sandstone recognised area.
No overhead power cable run through the field.
No activities have taken place which would have resulted in a contamination of the
soil or the sub soil.

6. Main services
All services: mains water supply, foul sewer, electricity and high-speed electronic
communications networks, are in the next field along. The area is serviced by the
local bin collection.

7. Historic Importance
The site is not in a conservation area.
None of surrounding buildings are listed.
No know or apparent feature of heritage of archaeological importance can be found
on the land.
No land infills took place.
The site has not been used for any industrial use or as a waste site.
No coal mining has been taken place on or in close proximity to the site.

8. Landscape and ecology
This site has been used for grassing.
There is no knowledge of any protected species on or surrounding. However, a full
ecological survey would need to be necessary before any development could take
place.
This sloping site can be seen from parts of the main road running through the village
and from across the valley. The field is next to row of houses as well as a field which
was included in the last LDP. New dwellings should be design with the surrounding
residential houses in mind.
A couple of trees can be found in the hedgerows which runs along all boundaries.

9. Possible constrains
Overhead power cables run through the field and alongside the road at the candidate
site. Contact has been made to move those cables to a different position in another
field owned by the same person.
No underground or phone lines would cause a problem for a possible development.

10. Settlement - Boundaries
This candidate site lies outside the settlement limits of Carmarthenshire as defined in
the local UDP -GR1. It is surrounded by residential development.
In the last LPDs (December 2014) a surrounding site in close proximity (just 2 fields
along) had been included; T3/6/h6.
Pontyberem is a small town which got all necessary amenities in close proximity.
 General hospital 9.5 miles
 Secondary school 5 miles
 Primary schools, less than ¼ mile
 Leisure centers, 9 miles
 Town center, ¼ mile
 Dentist & GP surgeries, ¼ mile

11. Transport links
The transport links to Carmarthen and Llanelli town are well established and
developed.
 train station is in Kidwelly, 8 miles away
 bus line is along Llannon Road with the next stop a few hundred meters down
the road.
 Carmarthen town 9 miles
 Llanelli town 8 miles
 A48 motorway link is 9 min away
 M4 is reached in 15 min

12. Conclusion
The site is next to a row of houses belonging to the Pontyberem. Right next this field
lies an area of tow fields which were included in the last LDP. Our proposed
development can easily be joined to the fields included last time and seen as one. In
this incidence the existing road access can be used for both sites.
We cannot see any obvious adverse effect on the developments in close proximity.
Not enough house developments in Carmarthenshire, has been implemented since
the last LDP was approved, which has led to a shortfall of housing sites in
Carmarthenshire.
Especially in Pontyberem not a lot of sites had been included in the last LDP.
There would an increase in traffic given amount of new dwelling which could be
erected in this field. However, the main road as well as the village can cope with
new developments and their traffic.

The existing access can be used and maybe widened to serve the new
development.
It is worth emphasising at the outset that the site:
 will help sustain the community by providing dwellings in a location that
reinforces the traditional settlement pattern;
 is of modest size and is situated adjacent to a proposed residential allocation;
 would not result in the loss of any important amenity feature or represent an
unacceptable intrusion into the landscape;
 would not give rise to any recognised highway or utility service provision
objections
 would fully comply with established planning policies that direct development
to sustainable locations in terms of proximity to urban facilities and a public
transport route.
 it is closely related to the main public transport corridors;
 the site is conveniently located in terms of schools and other services and
facilities;
 the site is not constrained by any significant environmental considerations,
including ecological designations;
 it will be contained within existing defendable boundaries and will not give rise
to any harmful precedent for further residential development.
 It is felt that there is scope for additional small sites to be identified to receive
residential development, in order to provide further choice.
 The inclusion would not create any amenity, highway or utility service provision
difficulty.

Include site in Plan

1. Introduction
We would like to include a field to the south of the center of Pontyberem in the new
Local Development Plan. This parcel of land north of Gwendraeth Row with direct
access.

2. Site Appraisal
This candidate site consists of a grassed parcel of land of an irregular shape just
South of the center of Pontyberem, which lies just outside the settlement limits of the
Unitary development plan.
A green corridor consisting of shrubs, trees, a couple of streams and public footpath
forms the eastern boundary.
A mature hedgerow forms the northern boundary. To the West are residential
developments all along Llannon Road, as well as to the South and South- East.
More fields under the same ownership are stretching towards the south, east and
north.
The field is sloping towards the East. A narrow tarmaced public footpath with low
level street lighting is running through the center of the field, linking Llannon Road to
the green corridor.

3. Access
An existing access can be off Gwendraeth Row which would ideally be widened
depending on the amount of new development. The same person owns more
surrounding fields which could have a positive affect to gain more land for a good
access onto the main Road, Llannon Road.

4. Flooding
The site lies well above the water level with a good distance from the streams
running along the small valley to the East. No evidence can be found on the flood
maps issued by the Environmental Agency – Wales.

5. Pollution
This field is currently greenfield sites and use for grazing.
No evidence can be found of any past development except for a notice on an
ordinance survey “quarry disused”. However, no evidence is apparent.
No evidence of a past development can be found.
The radon level is under 1%.
No known contamination as happened to the land.
Not adjacent to a mineral buffer zone
The site does not lie in a sandstone recognised area.
No overhead power cable run through the field.
No activities have taken place which would have resulted in a contamination of the
soil or the sub soil.

6. Main services
All services: mains water supply, foul sewer, electricity and high-speed electronic
communications networks, can be found in the surrounding developments. The area
is serviced by the local bin collection.

7. Historic Importance
The site is not in a conservation area.
None of surrounding buildings are listed.
No know or apparent feature of heritage of archaeological importance can be found
on the land.
No land infills took place.
The site has not been used for any industrial use or as a waste site.
No coal mining has been taken place on or in close proximity to the site.

8. Landscape and ecology
There is no knowledge of any protected species on or surrounding. However, a full
ecological survey would need to be necessary before any development could take
place.
The field is used only for agricultural use at present. The surrounding hedgerows to
the east and the green corridor should be maintained.

9. Possible constrains
An overhead power cable runs through the field along the public footpath. This path
can be incorporated easily into a new development. The overhead cable would need
to be moved to serve a new development.
No underground or phone lines would cause a problem for a possible development.

10. Settlement - Boundaries
This candidate site lies just outside the settlement limits of Carmarthenshire as
defined in the local UDP -GR1. However, the parcel of land is surrounded on two
side by residential and commercial development.
In the last LPDs (December 2014) a surrounding site in close proximity (just 2 fields
along) had been included; T3/6/h6.
Pontyberem is a small town which got all necessary amenities in close proximity.
 General hospital 9.5 miles
 Secondary school 5 miles
 Primary schools, about ½ mile
 Leisure centers, 9 miles
 Town center, ½ mile
 Dentist & GP surgeries, ½ mile

11. Transport links
The transport links to Carmarthen and Llanelli town are well established and
developed.
 train station is in Kidwelly, 8 miles away
 bus line is along Llannon Road as well as Coalbrock Road with the next stop
just hundred yards
 Carmarthen town 9 miles
 Llanelli town 8 miles
 A48 motorway link is 9 min away
 M4 is reached in 15 min

12. Conclusion
From the Carmarthenshire housing policy statement, it would appear that there is a
need for around 15,000 houses in the LDP period. It also appears that there are
currently only around 5,000 committed allocations. Especially in Pontyberem not a
lot of sites had been included in the last LDP.
Further investigation should be taken into the vegetation and animal life close to the
green corridor to the East. However, this wooded area would be maintained as a
greenbelt anyway with a public footpath running along the streams. The existing
public footpath can be incorporated into the new development instead of having a
negative effect.
We cannot see any obvious adverse effect on the developments in close proximity.
This field would lend itself to new residential development by linking Llannon Road to
the development at Gwendraeth Row.
There would be an increase in traffic given amount of new dwelling which could be
erected in this field. However, the main roads as well as the village can cope with
new developments plus their traffic. It would have a positive effect on the local
economy.

It is worth emphasising at the outset that the site:
 will help sustain the community by providing dwellings in a location that
reinforces the traditional settlement pattern;
 is of modest size and is situated adjacent to a proposed residential allocation;
 would not result in the loss of any important amenity feature or represent an
unacceptable intrusion into the landscape;
 would not give rise to any recognised highway or utility service provision
objections
 would fully comply with established planning policies that direct development
to sustainable locations in terms of proximity to urban facilities and a public
transport route.
 it is closely related to the main public transport corridors;
 the site is conveniently located in terms of schools and other services and
facilities;
 the site is not constrained by any significant environmental considerations,
including ecological designations;
 it will be contained within existing defendable boundaries and will not give rise
to any harmful precedent for further residential development.
 It is felt that there is scope for additional small sites to be identified to receive
residential development, in order to provide further choice.
 The inclusion would not create any amenity, highway or utility service provision
difficulty.

Include site within Plan

1. Introduction
We would like to include a field right in the center of Pontyberem in the new Local
Development Plan. It can be found east of Llannon Road and behind the line of
street development to the south of Coalbrock Road

2. Site Appraisal
This candidate site consists of a parcel of land of an irregular shape in the center of
Pontyberem just outside the settlement limits of the Unitary development plan, which
is used for grassing.
Llannon Road forms the western boundary of about 127m of this gently sloping field.
A narrow public run along the center. A mature hedgerow with a few medium trees
stretches along the eastern boundary leading into a now green corridor surround a
couple of streams. A single mature tree grows on its own at the northern part of the
land. The southern boundary forms another greenfield side, which the owner has put
forward as a candidate site for the new local development plan.

3. Access
There is an existing direct access of the main road, Llannnon Road. A new access
could be formed along the 127m main road frontage. There is good visibility at most
of the road frontage.
A second access can be found on the northern side onto an alley way leading to
Coalbrock Road. This alley runs parallel to the main road and serves as the access
lane for the main street development along Coalbrock Road.
A footpath can be found along the western and southern side of the land. The land
for the footpath to the south had been donated to the council of the land owner.

4. Flooding
The site lies well above the water level and in good distance from the 2 streams
running along the small valley. No evidence can be found on the flood maps issued
by the Environmental Agency – Wales.

5. Pollution
This field is currently greenfield sites and use for grazing.
No evidence of a past development can be found.
The radon level is under 1%.
No known contamination as happened to the land.
Not adjacent to a mineral buffer zone
The site does not lie in a sandstone recognised area.
No overhead power cable run through the field.
No activities have taken place which would have resulted in a contamination of the
soil or the sub soil.

6. Main services
All services: mains water supply, foul sewer, electricity and high-speed electronic
communications networks, are in the next field along. The area is serviced by the
local bin collection.

7. Historic Importance
The site is not in a conservation area.
None of surrounding buildings are listed.
No know or apparent feature of heritage of archaeological importance can be found
on the land.
No land infills took place.
The site has not been used for any industrial use or as a waste site.
No coal mining has been taken place on or in close proximity to the site.

8. Landscape and ecology
There is no knowledge of any protected species on or surrounding. See attached
survey..
The field is used only for agricultural use at present. The surrounding hedgerows can
be maintained as well as the exiting tree in the center of the field.

9. Possible constrains
An overhead power cables run through the field and alongside public foot path. The
path should be moved to suit a possible new development. With this the overhead
cable would be taken away.
No underground or phone lines would cause a problem for a possible development.

10. Settlement - Boundaries
This candidate site lies just outside the settlement limits of Carmarthenshire as
defined in the local UDP -GR1. However, the parcel of land is surrounded on two
side by residential and commercial development.
In the last LPDs (December 2014) a surrounding site in close proximity (just 2 fields
along) had been included; T3/6/h6.
Pontyberem is a small town which got all necessary amenities in close proximity.
 General hospital 9.5 miles
 Secondary school 5 miles
 Primary schools, less than ¼ mile
 Leisure centers, 9 miles
 Town center, 100 yards
 Dentist & GP surgeries, 100 yards

11. Transport links
The transport links to Carmarthen and Llanelli town are well established and
developed.
 train station is in Kidwelly, 8 miles away
 bus line is along Llannon Road as well as Coalbrock Road with the next stop
just hundred yards
 Carmarthen town 9 miles
 Llanelli town 8 miles
 A48 motorway link is 9 min away
 M4 is reached in 15 min

12. Conclusion
From the Carmarthenshire housing policy statement, it would appear that there is a
need for around 15,000 houses in the LDP period. It also appears that there are
currently only around 5,000 committed allocations. Especially in Pontyberem not a
lot of sites had been included in the last LDP.
The ecological survey of the site has been included. The wooded area surround by
the streams will be staying as a greenbelt anyway with a public footpath running
along the streams. The existing public footpath can be incorporated into the new
development instead of having a negative effect.
This field is right in the center of the village and would link part of the center with the
street development along Llannon Road, which can be found on both sides of the
road. The owner had previously donated a strip of this land to the council to build a
public footpath.
We cannot see any obvious adverse effect on the developments in close proximity.
There would be an increase in traffic given amount of new dwelling which could be
erected in this field. However, the main roads as well as the village can cope with
new developments plus their traffic. It would have a positive effect on the local
economy.

It is worth emphasising at the outset that the site:
 will help sustain the community by providing dwellings in a location that
reinforces the traditional settlement pattern;
 is of modest size and is situated adjacent to a proposed residential allocation;
 would not result in the loss of any important amenity feature or represent an
unacceptable intrusion into the landscape;
 would not give rise to any recognised highway or utility service provision objections
 would fully comply with established planning policies that direct development
to sustainable locations in terms of proximity to urban facilities and a public
transport route.
 it is closely related to the main public transport corridors;
 the site is conveniently located in terms of schools and other services and
facilities;
 the site is not constrained by any significant environmental considerations,
including ecological designations;
 it will be contained within existing defendable boundaries and will not give rise
to any harmful precedent for further residential development.
 It is felt that there is scope for additional small sites to be identified to receive
residential development, in order to provide further choice.
 The inclusion would not create any amenity, highway or utility service provision
difficulty.

Include site within the Plan

1. Introduction
We would like to include a field in the center of Pontyberem in the new Local
Development Plan. This parcel of land is linked to a field in the last LDP, marked as
T3/6/h5, which has been put in for outline planning.

2. Site Appraisal
This candidate site consists of a grassed parcel of land of an irregular shape just
South of the center of Pontyberem, which lies just outside the settlement limits of the
Unitary development plan.
A green corridor consisting of shrubs, trees, a couple of streams and public footpath
forms the western boundary.
A mature hedgerow with a few small to medium size trees forms the southern and
western boundary. To the north is the village center with commercial and residential
development. More fields under the same ownership are stretching towards the
south, east and north.
The field is very gently sloping. A grassed public footpath is running a long the side
linking Ashgrove to the green corridor.

3. Access
An existing access can be found past the commercial development of Coalbrock
Road, which can be utilized for a new development.
In addition, a new access onto Ashgrove can be formed via the field to the north,
T3/6/h5. This should be incorporated into this development with a joining new access
road.

4. Flooding
The site lies well above the water level and in good distance from the 2 streams
running along the small valley to the West. No evidence can be found on the flood
maps issued by the Environmental Agency – Wales.

5. Pollution
This field is currently greenfield sites and use for grazing.
No evidence of a past development can be found.
The radon level is under 1%.
No known contamination as happened to the land.
Not adjacent to a mineral buffer zone
The site does not lie in a sandstone recognised area.
No overhead power cable run through the field.
No activities have taken place which would have resulted in a contamination of the
soil or the sub soil.

6. Main services
All services: mains water supply, foul sewer, electricity and high-speed electronic
communications networks, are in Ashgrove. The area is serviced by the local bin
collection.

7. Historic Importance
The site is not in a conservation area.
None of surrounding buildings are listed.
No know or apparent feature of heritage of archaeological importance can be found
on the land.
No land infills took place.
The site has not been used for any industrial use or as a waste site.
No coal mining has been taken place on or in close proximity to the site.

8. Landscape and ecology
There is no knowledge of any protected species on or surrounding. However, a full
ecological survey would need to be necessary before any development could take
place.
The field is used only for agricultural use at present. The surrounding hedgerows to
the west should be maintained.

9. Possible constrains
An overhead power cable runs through the field and determinates at the end to serve
a commercial yard. A permission should be obtained to move the cable to a more
favorable position for a future development.
The existing footpath can easily be incorporated into the new development.
No underground or phone lines would cause a problem for a possible development.

10. Settlement - Boundaries
This candidate site lies just outside the settlement limits of Carmarthenshire as
defined in the local UDP -GR1. However, the parcel of land is surrounded on two
side by residential and commercial development.
In the last LPDs (December 2014) a surrounding site in close proximity (just 2 fields
along) had been included; T3/6/h6.
Pontyberem is a small town which got all necessary amenities in close proximity.
 General hospital 9.5 miles
 Secondary school 5 miles
 Primary schools, about ½ mile
 Leisure centers, 9 miles
 Town center, 200 yards
 Dentist & GP surgeries, 200 yards

11. Transport links
The transport links to Carmarthen and Llanelli town are well established and
developed.
 train station is in Kidwelly, 8 miles away
 bus line is along Llannon Road as well as Coalbrock Road with the next stop
just hundred yards
 Carmarthen town 9 miles
 Llanelli town 8 miles
 A48 motorway link is 9 min away
 M4 is reached in 15 min

12. Conclusion
From the Carmarthenshire housing policy statement, it would appear that there is a
need for around 15,000 houses in the LDP period. It also appears that there are
currently only around 5,000 committed allocations. Especially in Pontyberem not a
lot of sites had been included in the last LDP.
Further investigation should be taken into the vegetation and animal life close to the
green corridor to the West. However, this wooded area would be maintained as a
greenbelt anyway with a public footpath running along the streams. The existing
public footpath can be incorporated into the new development instead of having a
negative effect.
A tree survey should be done and the healthy medium size trees even the smaller
ones could be protected easily be incorporated into a new development and could
form a boundary to the southern fields.
This field would be continuous development to the T3/6/h5 and could be developed
as one.
We cannot see any obvious adverse effect on the developments in close proximity.
There would be an increase in traffic given amount of new dwelling which could be
erected in this field. However, the main roads as well as the village can cope with
new developments plus their traffic. It would have a positive effect on the local
economy.

An inclusion of this site at this location would realignment of the LDP’s development limits
to a more logical physical edge to the settlement.
In addition, the inclusion of this site will provide for an improved access to development
site GA3/h51, which is currently facing technical difficulties in bringing an access
alongside Bron-Yr-Ynn housing estate.
It is worth emphasising at the outset that the site:
 will help sustain the community by providing dwellings in a location that
reinforces the traditional settlement pattern;
 is of modest size and is situated adjacent to a proposed residential allocation;
 would not result in the loss of any important amenity feature or represent an
unacceptable intrusion into the landscape;
 would not give rise to any recognised highway or utility service provision
objections
 would fully comply with established planning policies that direct development
to sustainable locations in terms of proximity to urban facilities and a public
transport route.
 it is closely related to the main public transport corridors;
 the site is conveniently located in terms of schools and other services and
facilities;
 the site is not constrained by any significant environmental considerations,
including ecological designations;
 it will be contained within existing defendable boundaries and will not give rise
to any harmful precedent for further residential development.
 It is felt that there is scope for additional small sites to be identified to receive
residential development, in order to provide further choice.
 The inclusion would not create any amenity, highway or utility service provision
difficulty.

Include site within Plan

1. Introduction
We would like to put a field forward to be kept in the new LDP. The existing number
is T3/6/h5. The owner is in the process of getting outline planning granted on this
site.
It is located right in the center of Pontyberem. This parcel of land has been put in for
outline planning last year and application process is going forward.

2. Site Appraisal
This candidate site consists of a grassed parcel of land of a rectangular shape just
South of the center of Pontyberem, which lies inside the settlement limits of the
Unitary development plan.
The field has got a slopped pedestrianized access from the north leading off the
hammerhead of Ashgrove. It is a grassed public footpath which runs across the field
linking Ashgrove to the green corridor stretching towards the south west of the
village. This parcel of land is slightly slopping and raised to the road.
To the north lies the village center with commercial and residential development.
More fields under the same ownership are stretching towards the south, east and
north.
The owner is in the process of maintaining an outline planning permission for 3
double story dwellings on the site.
Application number, S/40104

3. Access
The public footpath can be moved along the western boundary. Propose drawings
have been agreed with the “public right of way” department.
In addition, a new access onto Ashgrove can be formed via the existing
pedestrianized access.

4. Flooding
The site lies well above the water level and in good distance from the 2 streams
running along the small valley to the West. No evidence can be found on the flood
maps issued by the Environmental Agency – Wales.

5. Main services
All services: mains water supply, foul sewer, electricity and high-speed electronic
communications networks, are in Ashgrove. The area is serviced by the local bin
collection.

6. Pollution
This field is currently included in the LDP and is used for grazing.
No evidence of a past development can be found.
The radon level is under 1%.
No known contamination as happened to the land.
Not adjacent to a mineral buffer zone
The site does not lie in a sandstone recognised area.
No overhead power cable run through the field.
No activities have taken place which would have resulted in a contamination of the
soil or the sub soil.

7. Historic Importance
The site is not in a conservation area.
None of surrounding buildings are listed.
No know or apparent feature of heritage of archaeological importance can be found
on the land.
No land infills took place.
The site has not been used for any industrial use or as a waste site.
No coal mining has been taken place on or in close proximity to the site.

8. Landscape and ecology
A full ecological survey has been done, with no negative constrains have been
found.
As well as full coal mining report.
The field is used only for agricultural use at present. The surrounding hedgerow to
the north should be maintained or replanted on the site.

9. Possible constrains
There is a slight height difference between the existing road and the field which can
overcome by reducing the height of the field to the road one.
The existing footpath with a right of way can easily be incorporated into the new
development. A proposal for the redirection of the path has been agreed with the
Countryside Access Assistant already.
No underground or phone lines would cause a problem for a possible development.

10. Settlement - Boundaries
This candidate site lies inside the settlement limits of Carmarthenshire as defined in
the local UDP -GR1. The parcel of land is surrounded on two side by residential and
commercial development.
Existing LPDs (December 2014) T3/6/h5.
Pontyberem is a small town which got all necessary amenities in close proximity.
 General hospital 9.5 miles
 Secondary school 5 miles
 Primary schools, about ½ mile
 Leisure centers, 9 miles
 Town center, 200 yards
 Dentist & GP surgeries, 200 yards

11. Transport links
The transport links to Carmarthen and Llanelli town are well established and
developed.
 train station is in Kidwelly, 8 miles away
 bus line is along Llannon Road as well as Coalbrock Road with the next stop
just hundred yards
 Carmarthen town 9 miles
 Llanelli town 8 miles
 A48 motorway link is 9 min away
 M4 is reached in 15 min

12. Conclusion
From the Carmarthenshire housing policy statement, it would appear that there is a
need for around 15,000 houses in the LDP period. It also appears that there are
currently only around 5,000 committed allocations. Especially in Pontyberem not a
lot of sites had been included in the last LDP.
The outline planning process has been running since a while and all necessary
information have been provided. Further investigation like the coal mining report and
the full ecological survey had been done with no negative findings. A new public
footpath has been agreed and incorporated into the new development without a
negative effect.
We cannot see any obvious adverse effect on the developments in close proximity.
There would be an increase in traffic given amount of new dwelling which could be
erected in this field. However, the main roads as well as the village can cope with
new developments plus their traffic. It would have a positive effect on the local
economy.

An inclusion of this site at this location would realignment of the LDP’s development limits
to a more logical physical edge to the settlement.
It is worth emphasising at the outset that the site:
 will help sustain the community by providing dwellings in a location that
reinforces the traditional settlement pattern;
 is of small size and is situated adjacent to a proposed residential allocation;
 would not result in the loss of any important amenity feature or represent an
unacceptable intrusion into the landscape;
 would not give rise to any recognised highway or utility service provision
objections
 would fully comply with established planning policies that direct development
to sustainable locations in terms of proximity to urban facilities and a public
transport route.
 it is closely related to the main public transport corridors;
 the site is conveniently located in terms of schools and other services and
facilities;
 the site is not constrained by any significant environmental considerations,
including ecological designations;
 it will be contained within existing defendable boundaries and will not give rise
to any harmful precedent for further residential development.
 It is felt that there is scope for additional small sites to be identified to receive
residential development, in order to provide further choice.
 The inclusion would not create any amenity, highway or utility service provision
difficulty.

Mae angen gwella darpariaeth o dai fforddiadwy i ddenu trigolion ifanc sy’n siarad Cymraeg nol i’r sir er mwyn diogelu’r iaith Gymraeg ar gyfer y dyfodol. Cynnwys y safle fel dyranniad preswyl.


There is a need to improve provision of affordable housing to attract young Welsh-speaking residents to the county to future-proof the Welsh language. Include the site as a housing allocation.

Dydw i ddim yn teimlo bod y sir wedi gwneud digon o ymdrech i ddiogelu’r iaith Cymraeg. Wrth edrych ar y data o’r proffil oedran trigolion sy'n siarad Cymraeg sy’n symud allan o’r sir a ddim yn dod 'nôl. Mae’r cynllun rwy’n rhoi o flaen y sir heddiw yn gwneud cyfraniad sylweddol i wella’r sefyllfa er mwyn diogelu’r iaith i’r genhedlaeth nesaf.

Include site within the Plan

Introduction

Persimmon Homes West Wales write to submit these representations in respect of the current Carmarthenshire Deposit Local Development Plan (2018 to 2033) (“Deposit Plan”) consultation. As the Council will be aware, Persimmon Homes West Wales are actively promoting two additional candidate sites for residential allocation in the Deposit Plan, both of which have Option Agreements in place:

Land off Church Road, Gorslas (SR/067/002)
This submitted site is 2.7 hectares of undeveloped land, located to the north of Gorslas.

Land at Fforest Road, Fforest (SR/069/003)
Two options have been submitted for the site. The first forms 15.24 hectares and the second 4.5 hectares of undeveloped land which is situated directly adjacent to the eastern boundary and settlement building line of Fforest. Part of the site is allocated for housing in the adopted Carmarthenshire Local Development Plan (Site T3/7/h8).

Promotional documents were submitted as part of the candidate site submission which provide a full overview of each site.

Persimmon Homes are currently within the planning application process and delivering units on a number of sites which are detailed in the Deposit Plan – of which are relevant commentary on these is provided below.

This letter focuses on the key concerns with the Deposit Plan and overall housing strategy, reflecting on each matter with regard to the ‘tests of soundness’, to ensure compliance with the requirements of the Planning and Compulsory Purchase Act 2004 and Planning Policy Wales 11 (PPW 11) (February 2021).

Soundness
The fundamental requirement for a Local Development Plan to be sound is prescribed in the Planning and Compulsory Purchase Act 2004. With regard to the ‘tests of soundness’, whilst there is no statutory definition of ‘soundness’ the Development Plans Manual (Edition 3) (March 2020) advises that the following criteria should be considered:

Test 1. Does the plan fit?
Test 2. Is the Plan appropriate?
Test 3. Will the Plan deliver?

Policies and comments

Persimmon Homes West Wales raise concern regarding the Plan Period, noting that if adopted in 2024 as targeted, the Plan will effectively only cover a relatively short Plan Period Post Adoption of 10 years. It is considered a more proactive approach would be to Plan for a 15 year period from the point of adoption to allow for greater certainty over the longer-term (particularly if a future LDP is likely to suffer from such delays and to align the Plan with Future Wales: the National Plan (2040). Such an approach would call for the allocation of additional sites to meet the housing need for the extended Plan Period.

The Deposit Plan as currently drafted fails Test 1 and 3 in terms of the current Plan Period, with regard to the effectiveness of the Plan Period and the need to fit with other plans and policies. We consider a 15 year plan period from the anticipated point of adoption should be implemented and additional residential site allocations which are available and deliverable should be allocated to meet housing need (Church Road, Gorslas and Land at Forest).

SP3: Sustainable Distribution – Settlement Framework
SP3 directs the provision of growth and development to sustainable locations. This takes a 4 tiered approach in terms of the settlement framework. These include the principal centres, the service centres, sustainable villages and rural villages. The principal centres remain as Carmarthen, Llanelli and Ammanford/Cross Hands, which includes Gorslas, where the majority of development will be directed. Fforest/Hendy is defined as a Service Centre in Cluster 2 where 15-20% of development will be directed. We support the provision of Housing Allocations in Principal Centres and Service Centres

As part of the review process, Persimmon Homes are promoting the inclusion of sites SR/069/003 (Option 1 and 2) in Fforest and SR/067/002 in Gorslas in the Deposit Plan.

It is considered that the future development of the residential sites at both Gorslas and Fforest (option 1 and 2) which have been submitted as Candidate Sites would be coherent and consistent with the Local Development Plan vision, objectives, preferred strategy and Deposit Plan Policies.

SP4: A Sustainable Approach to Providing New Homes
This Deposit Plan proposes to use the ten-year based projection from Turley’s Housing and Economic Growth Report and utilise the Council Tax vacancy rate of 3.8% to underpin the future growth requirements for this revised Deposit LDP. This results in the following for the plan period:
- Projected population change between 2018-2033: +14,468
- New homes requirement: + 588 per year
- New Homes requirement during the plan period: 8,822
- Jobs creation value per annum: +276

This will result in 13 units less over the plan period from the original Deposit Plan which was consulted upon.
This Deposit Plan’s strategic policy (SP1) outlines the LDP will provide for the future growth of a sustainable economy and housing requirement through the provision of:
- 9,704 new homes to meet the identified housing requirement of 8,822 with a 10% flexibility allowance.
- The focus on regeneration and growth reflects the Council’s core strategic ambitions with development distributed in a sustainable manner consistent with the spatial strategy and settlement framework.

This will result in 456 less new homes in the plan period from the original Deposit Plan which was consulted upon. A more ambitious housing requirement would facilitate the economic growth required in the county and will be more effective in achieving the Council’s vision and objectives. Persimmon Homes considers that the plan lacks ambition in regards to the housing numbers.

The removal of the 5 year housing land supply policy within PPW 11 and TAN 1 and the replacement with the housing trajectory approach to monitor the delivery of LDP housing requirements, places even greater importance on ensuring that the housing trajectory is credible and realistic and it is critical that the housing allocations proposed in emerging Local Development Plans are appropriately and robustly evidenced to ensure that they are realistically deliverable.

Planning Policy Wales Edition 11 sets out the land use planning policies of the Welsh Government with its primary objective being to ensure that the planning system contributes towards the delivery of sustainable development and improves the social, economic, environmental and cultural well-being of Wales.

PPW 11 states that the ‘planning system must:
- Identify a supply of land to support the delivery of the housing requirement to meet the differing needs of communities across all tenures;
- Enable provision of a range of well-designed, energy efficient, good quality market and affordable housing that will contribute to the creation of sustainable places; and
- Focus on the delivery of the identified housing requirement and the related land supply’.

‘The supply of land to meet the housing requirement proposed in a development plant must be deliverable. To achieve this, development plans must include a supply of land which delivers the identified housing requirement figure and makes a locally appropriate additional flexibility allowance for sites not coming forward during the plan period. The ability to deliver requirements must be demonstrated through a housing trajectory. The trajectory should be prepared as part of the development plan process and form part of the plan. The trajectory will illustrate the expected rate of housing delivery for both market and affordable housing for the plan period. To be ‘deliverable’, sites must be free, or readily freed, from planning, physical and ownership constraints and be economically viable at the point in the trajectory when they are due to come forward for development in order to support the creation of sustainable communities’.

‘As part of demonstrating the deliverability of housing sites, financial viability must be assessed prior to their inclusion as allocations in a development plan. At the ‘Candidate Site’ stage of development plan preparation land owners/developers must carry out an initial site viability assessment and provide evidence to demonstrate the financial deliverability of their sites. At the ‘Deposit’ stage, there must be a high level plan-wide viability appraisal undertaken to give certainty that the development plan and its policies can be delivered in principle, taking into account affordable housing targets, infrastructure and other policy requirements’.

Flexibility Allowance
The flexibility allowance in terms of housing numbers is to be included in a Plan to ensure it will remain effective in the event of changing circumstance such as non-delivery of key sites and / or other unforeseen issues. The Development Plan Manual indicates that a 10% flexibility allowance should be the starting point in terms of housing provision. Persimmon Homes West Wales are of the view that the appropriate rate should be set based on local circumstances. We consider that a greater level of flexibility should be allowed for in the Plan to increase the change of meeting the housing needs of the County. Such a flexibility allowance will assist in overcoming uncertainties regarding housing deliverability and viability and would also allow additional flexibility given the shorter time period on which the Plan is proposed (10 years from adoption). The provision of 15% flexibility would increase the housing supply to 10,145 and increase the allocated plots by 441 dwellings.

Site Allocations
Persimmon Homes supports the allocation of the Strategic Site at Carmarthen West and would like to provide confirmation that as one of the largest house builders in West Wales, we are currently going through the Planning Application and Design process for 343 dwellings on Carmarthen West and are also actively working to obtain an Option Agreement for an additional 300 units. The site is considered deliverable and viable and we therefore support the inclusion of the site in the Plan under reference PrC1/MU1.

Persimmon Homes supports the allocation of Dafen East Gateway for the delivery of housing under reference PrC2/h23. We are currently within the Planning Process for the development scheme and intend to begin construction on site as soon as we are able. We are confident that the development site will be delivered in line with the Housing Trajectory as set out in the Deposit Plan. In regards to this allocation, the site is currently 20% affordable housing with the planning application complying with this policy level, we therefore request that the affordable housing requirement is reduced from 30% (which does not fall in line with AHOM1 at 25%) to the current level of 20%.

AHOM1: Affordable Housing
Persimmon Homes West Wales Object to the nature of the Affordable Housing Provision Policy AHOM1. The changes to the Affordable Housing percentages at a blanket of 25% on sites which are over 101 plots does not consider the changes in viability and locality of a site across the County Council area.

If you require any further information on the above or would like to discuss any points, please do not hesitate to contact me.

Include site within the Plan

Introduction

Persimmon Homes West Wales write to submit these representations in respect of the current Carmarthenshire Deposit Local Development Plan (2018 to 2033) (“Deposit Plan”) consultation. As the Council will be aware, Persimmon Homes West Wales are actively promoting two additional candidate sites for residential allocation in the Deposit Plan, both of which have Option Agreements in place:

Land off Church Road, Gorslas (SR/067/002)
This submitted site is 2.7 hectares of undeveloped land, located to the north of Gorslas.

Land at Fforest Road, Fforest (SR/069/003)
Two options have been submitted for the site. The first forms 15.24 hectares and the second 4.5 hectares of undeveloped land which is situated directly adjacent to the eastern boundary and settlement building line of Fforest. Part of the site is allocated for housing in the adopted Carmarthenshire Local Development Plan (Site T3/7/h8).

Promotional documents were submitted as part of the candidate site submission which provide a full overview of each site.

Persimmon Homes are currently within the planning application process and delivering units on a number of sites which are detailed in the Deposit Plan – of which are relevant commentary on these is provided below.

This letter focuses on the key concerns with the Deposit Plan and overall housing strategy, reflecting on each matter with regard to the ‘tests of soundness’, to ensure compliance with the requirements of the Planning and Compulsory Purchase Act 2004 and Planning Policy Wales 11 (PPW 11) (February 2021).

Soundness
The fundamental requirement for a Local Development Plan to be sound is prescribed in the Planning and Compulsory Purchase Act 2004. With regard to the ‘tests of soundness’, whilst there is no statutory definition of ‘soundness’ the Development Plans Manual (Edition 3) (March 2020) advises that the following criteria should be considered:

Test 1. Does the plan fit?
Test 2. Is the Plan appropriate?
Test 3. Will the Plan deliver?

Policies and comments

Persimmon Homes West Wales raise concern regarding the Plan Period, noting that if adopted in 2024 as targeted, the Plan will effectively only cover a relatively short Plan Period Post Adoption of 10 years. It is considered a more proactive approach would be to Plan for a 15 year period from the point of adoption to allow for greater certainty over the longer-term (particularly if a future LDP is likely to suffer from such delays and to align the Plan with Future Wales: the National Plan (2040). Such an approach would call for the allocation of additional sites to meet the housing need for the extended Plan Period.

The Deposit Plan as currently drafted fails Test 1 and 3 in terms of the current Plan Period, with regard to the effectiveness of the Plan Period and the need to fit with other plans and policies. We consider a 15 year plan period from the anticipated point of adoption should be implemented and additional residential site allocations which are available and deliverable should be allocated to meet housing need (Church Road, Gorslas and Land at Forest).

SP3: Sustainable Distribution – Settlement Framework
SP3 directs the provision of growth and development to sustainable locations. This takes a 4 tiered approach in terms of the settlement framework. These include the principal centres, the service centres, sustainable villages and rural villages. The principal centres remain as Carmarthen, Llanelli and Ammanford/Cross Hands, which includes Gorslas, where the majority of development will be directed. Fforest/Hendy is defined as a Service Centre in Cluster 2 where 15-20% of development will be directed. We support the provision of Housing Allocations in Principal Centres and Service Centres

As part of the review process, Persimmon Homes are promoting the inclusion of sites SR/069/003 (Option 1 and 2) in Fforest and SR/067/002 in Gorslas in the Deposit Plan.

It is considered that the future development of the residential sites at both Gorslas and Fforest (option 1 and 2) which have been submitted as Candidate Sites would be coherent and consistent with the Local Development Plan vision, objectives, preferred strategy and Deposit Plan Policies.

SP4: A Sustainable Approach to Providing New Homes
This Deposit Plan proposes to use the ten-year based projection from Turley’s Housing and Economic Growth Report and utilise the Council Tax vacancy rate of 3.8% to underpin the future growth requirements for this revised Deposit LDP. This results in the following for the plan period:
- Projected population change between 2018-2033: +14,468
- New homes requirement: + 588 per year
- New Homes requirement during the plan period: 8,822
- Jobs creation value per annum: +276

This will result in 13 units less over the plan period from the original Deposit Plan which was consulted upon.
This Deposit Plan’s strategic policy (SP1) outlines the LDP will provide for the future growth of a sustainable economy and housing requirement through the provision of:
- 9,704 new homes to meet the identified housing requirement of 8,822 with a 10% flexibility allowance.
- The focus on regeneration and growth reflects the Council’s core strategic ambitions with development distributed in a sustainable manner consistent with the spatial strategy and settlement framework.

This will result in 456 less new homes in the plan period from the original Deposit Plan which was consulted upon. A more ambitious housing requirement would facilitate the economic growth required in the county and will be more effective in achieving the Council’s vision and objectives. Persimmon Homes considers that the plan lacks ambition in regards to the housing numbers.

The removal of the 5 year housing land supply policy within PPW 11 and TAN 1 and the replacement with the housing trajectory approach to monitor the delivery of LDP housing requirements, places even greater importance on ensuring that the housing trajectory is credible and realistic and it is critical that the housing allocations proposed in emerging Local Development Plans are appropriately and robustly evidenced to ensure that they are realistically deliverable.

Planning Policy Wales Edition 11 sets out the land use planning policies of the Welsh Government with its primary objective being to ensure that the planning system contributes towards the delivery of sustainable development and improves the social, economic, environmental and cultural well-being of Wales.

PPW 11 states that the ‘planning system must:
- Identify a supply of land to support the delivery of the housing requirement to meet the differing needs of communities across all tenures;
- Enable provision of a range of well-designed, energy efficient, good quality market and affordable housing that will contribute to the creation of sustainable places; and
- Focus on the delivery of the identified housing requirement and the related land supply’.

‘The supply of land to meet the housing requirement proposed in a development plant must be deliverable. To achieve this, development plans must include a supply of land which delivers the identified housing requirement figure and makes a locally appropriate additional flexibility allowance for sites not coming forward during the plan period. The ability to deliver requirements must be demonstrated through a housing trajectory. The trajectory should be prepared as part of the development plan process and form part of the plan. The trajectory will illustrate the expected rate of housing delivery for both market and affordable housing for the plan period. To be ‘deliverable’, sites must be free, or readily freed, from planning, physical and ownership constraints and be economically viable at the point in the trajectory when they are due to come forward for development in order to support the creation of sustainable communities’.

‘As part of demonstrating the deliverability of housing sites, financial viability must be assessed prior to their inclusion as allocations in a development plan. At the ‘Candidate Site’ stage of development plan preparation land owners/developers must carry out an initial site viability assessment and provide evidence to demonstrate the financial deliverability of their sites. At the ‘Deposit’ stage, there must be a high level plan-wide viability appraisal undertaken to give certainty that the development plan and its policies can be delivered in principle, taking into account affordable housing targets, infrastructure and other policy requirements’.

Flexibility Allowance
The flexibility allowance in terms of housing numbers is to be included in a Plan to ensure it will remain effective in the event of changing circumstance such as non-delivery of key sites and / or other unforeseen issues. The Development Plan Manual indicates that a 10% flexibility allowance should be the starting point in terms of housing provision. Persimmon Homes West Wales are of the view that the appropriate rate should be set based on local circumstances. We consider that a greater level of flexibility should be allowed for in the Plan to increase the change of meeting the housing needs of the County. Such a flexibility allowance will assist in overcoming uncertainties regarding housing deliverability and viability and would also allow additional flexibility given the shorter time period on which the Plan is proposed (10 years from adoption). The provision of 15% flexibility would increase the housing supply to 10,145 and increase the allocated plots by 441 dwellings.

Site Allocations
Persimmon Homes supports the allocation of the Strategic Site at Carmarthen West and would like to provide confirmation that as one of the largest house builders in West Wales, we are currently going through the Planning Application and Design process for 343 dwellings on Carmarthen West and are also actively working to obtain an Option Agreement for an additional 300 units. The site is considered deliverable and viable and we therefore support the inclusion of the site in the Plan under reference PrC1/MU1.

Persimmon Homes supports the allocation of Dafen East Gateway for the delivery of housing under reference PrC2/h23. We are currently within the Planning Process for the development scheme and intend to begin construction on site as soon as we are able. We are confident that the development site will be delivered in line with the Housing Trajectory as set out in the Deposit Plan. In regards to this allocation, the site is currently 20% affordable housing with the planning application complying with this policy level, we therefore request that the affordable housing requirement is reduced from 30% (which does not fall in line with AHOM1 at 25%) to the current level of 20%.

AHOM1: Affordable Housing
Persimmon Homes West Wales Object to the nature of the Affordable Housing Provision Policy AHOM1. The changes to the Affordable Housing percentages at a blanket of 25% on sites which are over 101 plots does not consider the changes in viability and locality of a site across the County Council area.

If you require any further information on the above or would like to discuss any points, please do not hesitate to contact me.

No change to the Plan. Site to remain unallocated for housing in the Revised LDP.

As this is the only form that I have been given, I am using it at this stage to place on record
my objection to the possibility of the land I have identified being included in a revised LDP
for the Cwmaman area. To reiterate, the land I am referring to is off Cwmaman Road,
Glanaman SA182AF. Grid Reference coordinates XY as follows, 266436: 213116.

Although I understand that the above potential development site is not currently in the
LDP, or the revised LDP, I wish to make you aware of my very strong objections to having
it included in any future LDP adoption. The recent scenario surrounding this potential
development has been very confusing and has alarmed many people in the locality.

You should be aware that the site is already being advertised by local estate agents who
have indicated that up to 80 dwellings my be built on the land referenced above . I am not
aware of any current planning application being submitted, yet preparatory work is
underway which will have already had some impact on biodiversity in the area and could
have the potential to create false picture of demand for the development.

As previous planning application decisions made by Carmarthenshire County Council
regarding the land have indicated, the site is unsuitable for housing for a number of
reasons. These reasons are many and have been discussed in detail in the previous
planning applications and the subsequent unsuccessful appeal I refer to. Although there
was a successful appeal made to the Welsh Assembly, the consent given at that time has
long expired and the conditions appended to the Assembly appeal report even then were
very specific and restrictive. Indeed, the requirements outlined in the consent given at that
time are even more pertinent now.

To briefly indicate where the main concerns of both Carmarthenshire CountyCouncil and
the Welsh Assembly were focused it is only necessary to consider the long history of coal
mining in the area and the recorded subsidence issues in the immediate vicinity. Common
sense, and relevant legislation combine to insist that substantial in depth surveys must be
undertaken and significant mitigation may be necessary before any development on this
site can even be considered.

In addition to the concerns around the mining history of the area, the site has a high
ecological value, and any harm to its biodiversity must be addressed through additional
surveys and mitigation.

The surrounding road network is also a concern. The highway is already at high capacity
and there is an extensive history of minor traffic collisions in the area. The additional traffic
from the number of dwellings proposed would not be safely accommodated.

Given the constraints of the 2nd deposit editable form that I am responding to I have only
briefly touched on some of the reasons why I object to even the possibility of this (already
being promoted) proposed development being accepted into a revised LDP, I would, of
course, be prepared to expand on my concerns in any future forum or hearing if that was
required.

Amend Plan to include the site.

This proposed allocation was rejected as a candidate site for the reason described:-
Development of the site would have a detrimental impact on the character and setting of the settlement. Furthermore, there is sufficient and more suitable land available for development within the settlement to accommodate its housing need.

In reflection to this assessment:-

This proposed site is similar in environs context to housing allocations SuV33/h1 & SuV35/h1 as a green field site opposite existing dwellings with the exception of being closer to amenities.

Within Tier 3 - Sustainable Villages - Cluster 4 of the Second Deposit Revised LDP there are 11 new units within this plan area to date and this amount of housing allocation is unlikely to satisfy the need for housing for the local community.

Evidence within this assessment demonstrates this candidate site is within an existing sustainable settlement area, it meets all sustainable requirements as set out within the Planning Policy Wales framework for homes to be constructed within an existing sustainable built environment and community.

Development of the site would not have a detrimental impact on the character and setting of the settlement.

Include site within the Plan

1. Introduction
We would like to include a field for residential in the village of Glandy Cross in the
new Local Development Plan. The site is back directly onto the existing settlement
boundaries next to a small estate of about 15 dwellings. This parcel of land has not
got any planning history. It is located 100 m of the road between Narberth and
Cardigan.
Grid references: 214528, 226560

2. Site Appraisal
This candidate site consists of an area of field which can only be used in the summer
season to take off one crop. The winter months are too wet for grazing. It is adjoining
to the estate of Bro Deirian and the existing LDP.
The proposed site as well as the surrounding area and settlement are fairly level.
The field is surrounded by a mature hedge which can be maintained in any
development. At northern edge is a small stream which can be used for any
sustainable drainage solution.
We believe that this site is ideal for a residential development for the village to grow
into. The close proximity to the shop and village center as well as the main road will
be in favor. As well as the existing speed limit and a good visibility from the existing
access. The village would expand in a circular way and not along the road. An estate
of the main road would provide a safe environment for children to grow up in. A site
like this would fulfil the need for housing in the community.

3. Access
The field has got an existing access on the C-road which has got a good visibility in
both directions. Additionally, this access benefits from a 30 m/h speed restriction at
this part of the road. The main road, A478, has got a speed restriction of 40 m/h.

4. Flooding
The site lies well above the water level with no river close by. No evidence of
flooding can be found on the flood maps issued by the Environmental Agency –
Wales. The Eastern and the Northern part of the site has got some evidence of
surface water in the winter months which can be overcome with a sustainable
drainage solution and excess surface water can be taken into the stream that runs
along the northern edge.

5. Pollution
The land is currently a greenfield site and used for agricultural.
No evidence can be found of any past development.

6. Use
The field is too wet for any winter use. Over the summer months one crop will be
taken off the land.

7. Main services
All services: mains water supply, electricity and high-speed electronic
communications networks, are running along the boundary of the site and the main
road. These can easily be accessed. The area is serviced by the local bin collection.

8. Proposal
The proposal is for a site of residential dwellings, ideally a mix of bungalows and
double story dwellings in a similar size as the surrounding development. A should
have a good size amenity space in this rural settlement.
As this community is not connected to the mains sewer network and to overcome the
phosphate levels in our local rivers, either a sewage Treatment Plant could be
installed for the whole site or individual septic tank for each plot.
A Treatment Plant has minimal negative impact on the environment. It produces
clean non-polluting effluent 95% clean which will have no real impact on the
environment.
The clean discharge can go easily straight into a stream or a ditch,
There will be no need for an application for a Consent of Discharge as our proposal
will fit into the rules for not requiring one.

9. Historic Importance
There is not historic importance to the site

10. Planning history
There is no planning history to this site

11. Landscape and ecology
There is no knowledge of any protected species on or surrounding the site. However,
a full ecological survey would need to be necessary before any development could
take place.

11. Possible constrains
No overhead power cables are running through the field.
As far as we are aware no underground or phone lines would cause a problem for a
possible development.

12. Settlement - Boundaries
This candidate site backs onto the established settlement limits of Glandy Cross. A
small village established at a cross road around a petrol station, a shop and a pub.
Unfortunately, the pub closed a few years ago. However, the shop has been growing
steadily. The site backs directly onto a small estate, build in the 80th consisting of
about 15 dwellings.
The community of Gandy Cross – Efailwen, has got a few local amenities like a
shop, Café, petrol station and a primary school. However, all necessities are in close
proximity.
 General hospitals, there are at the moment 2 in close distance: Carmarthen &
Haverfordwest
 Secondary school - Ysgol Y Preseli about 5 miles, Crymych
 Primary schools – Ysgol Beca, about 1 mile, Efailwen & Ysgol Y Frenni about
5 miles, Crymych
 Leisure centers, 5 miles Crymych
 GP surgery, 5 miles, Crymych
 Just 100 meters away is the next shop as well as a petrol station
 Café about 1 mile away
 Next pharmacies are in 5miles distance, Clynderwen & Crymych
 All other amenities like restaurants, take aways, pubs, various shops, a
library, a small industrial estate can be found in Crymych

13. Transport links
The site is in very close proximity to one of the main Welsh A roads. Transport links
to Carmarthen, Haverfordwest and Cardigan are all well established and developed.
 train station is in Clynderwen, 5 miles
 there are bus lines running to Cardigan and Narberth
 Carmarthen town - 24 miles
 Cardigan 13 - miles
 Haverfordwest – 22 miles
 Narberth – 7.7 miles
 A478 Cardigan – Tenby 0.1 mile
 A40 – Haverfordwest – Carmarthen – Llandovery 6.5 miles
 A487 Fishguard – Aberystwyth

14. Conclusion
From the Carmarthenshire housing policy statement, it would appear that there is a
need for around 15,000 houses in the LDP period. It also appears that there are
currently only around 5,000 committed allocations.
Speaking to the local community, lots of complains were raised that there is
significant shortage of available properties as well as building plots in this area. The
younger generation who want to stay in this close-knit community close to friends
and family, getting push out and need to look for housing a lot further away. There
have not been any new housing sites released in the close proximity to the
community of Glandy Cross – Efailwen since a long time.
Residence of this possible development would help to grow and maintain the local
amities as well as the primary school in the community.
We cannot see any obvious adverse effect on the developments in close proximity.
The increase in traffic is minimal as the main road as well as the village can cope
with new developments. It would have a positive effect on the local economy.

Allocate the alternative site for housing within the settlement of Llandybie.

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Mr A Pritchard to prepare and
submit an Alternative Allocation Report for the allocation of land adjoining Parc
Gelliwastad, Llandybie for the purposes of residential development in the forthcoming
replacement Carmarthenshire Local Development Plan (LDP). Submissions for the
Site were made at the Candidate Site Stage (LPA ref. No. SR/082/005), but the
Council determined to exclude the Site for the following reasons:
“There is sufficient and more suitable land available for development within the village
to accommodate its housing need which is considered to be better located in terms of
its relationship and proximity to the existing urban form and the services and facilities
within the settlement.”
1.2 This report has therefore been prepared in response to the above and provides
further information, highlighting the suitability of the Site for allocation for housing
development. It also relates to a slightly larger parcel of land to that promoted at the
Candidate Site stage, as contrary to the Council’s view above, it has been identified
that the Cluster the settlement of Llandybie forms part of is facing an under provision
of new housing during the Plan period, due to a number of undeliverable sites being
promoted by the Council.
1.3 This report has therefore been prepared in line with the Authority’s published site
assessment and selection documents. The contents of this report therefore address
each point raised within these documents as well as ensuring that it complies with
regards to the guidance and requirements of Planning Policy Wales (Edition 11)
when it comes to the preparation of development plans and the allocation of land for
residential purposes as part of them.
1.4 The contents of this report therefore provide a comprehensive case for the allocation
of the land for residential development purposes, and it should also be read in
Alternative Allocation Report April 2023
Land off Parc Gelliwastad, Llandybie
4
conjunction with the accompanying information, as well as a sustainability
assessment undertaken in-line with the Council’s requirements.
Alternative Allocation Report April 2023
Land off Parc Gelliwastad, Llandybie
5
2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Alternative Site relates to land measuring approximately 4.6 acres in area in
total, edged red on the plan and the photograph below.
Plan A
Photograph 1
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Land off Parc Gelliwastad, Llandybie
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2.1.2 As can be seen from the aerial photograph above and the accompanying information,
the Alternative Site consists of a single parcel of semi-improved grassland, with its
boundaries being strongly defined by a mix of mature hedge lines and stock proof
fencing. In terms of topography, the Site is generally level to a slight downwards
gradient in an east to west direction.
2.1.3 Access to the site is currently gained via an existing estate road positioned along part
of its eastern boundary (Photograph 2).
Photograph 2
2.1.4 As can be seen, the road has been constructed to adoptable standards and in turn
then leads onto the public highway to the south east (Kings Road).
2.1.5 Under the provisions of the current Carmarthenshire LDP, the Site presently lies at
the western edge of the defined Development Limits of the settlement of Llandybie.
However, as the extract of the Proposals Map below illustrates, the Site (outlined in
red) adjoins and is well related to the current built form of the urban area directly to
the east.
Alternative Allocation Report April 2023
Land off Parc Gelliwastad, Llandybie
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Plan B
2.1.6 As can be seen, the Alternative Site is therefore well related to the existing defined
Development Limits for Llandybie and the settlement’s built form as a whole when
existing residential development directly to its south and east is taken into
consideration. Its position and proposed use therefore represent a natural and logical
location for the settlement’s expansion, as well as an example of natural rounding-off
of the existing built form.
2.2 THE ADJOINING SETTLEMENT
2.2.1 As detailed above, the Candidate Site adjoins the existing settlement and form of
Llandybie. As a result, the Site is within walking distance of a number of its
community facilities and local services, including the following:
 Primary School
 Village Hall
 Several Retail Units (A1 and A3)
 Several Public Houses (A3)
 Several Places of Worship
Alternative Allocation Report April 2023
Land off Parc Gelliwastad, Llandybie
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2.2.2 From an accessibility perspective, Llandybie has a station on the Heart of Wales line,
is located on a main transport artery in the form of the A483, as well as having very
well served bus stops. The bus services serving the settlement are numbers 103,
276, 284 and x13, which provide regular access to the following larger settlements,
as well as the intervening villages:
 Ammanford
 Llandeilo
 Swansea
2.2.3 The strong sustainable position of Llandybie should therefore be given full
consideration when considering potential future growth options.
2.2.4 Llandybie forms part of the wider Principal Centre of Cluster 3 as defined by the 2nd
Deposit LDP, where the Council expects much of the planned growth in the County to
take place. However, two of the proposed housing allocations (PRC3/h19 and
PrC3/h37) have already been constructed or will be near completion by the time the
Replacement LDP will be adopted. This is worrying considering the sustainable
credentials of Llandybie as a settlement and so further deliverable allocations for the
settlement should be considered.
2.2.5 The above is particularly important as having undertaken a comprehensive review of
the proposed allocations put forward by the 2nd Deposit LDP for the Principal Centre
in question, it has been identified that a number have significant questions over their
ability to be delivered within the Plan period, including the following:
Alternative Allocation Report April 2023
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Ref. No. Site Name Units
PrC3/h4 Tirychen Farm 150
PrC3/h36 Betws Colliery 60
PrC3/h14 Nantydderwen, Tumble 33
PrC3/h22 Adj. to Pant y Blodau, Penygroes 79
PrC3/h2 Heol Gelynen, Brynamman 8
Table 1
2.2.6 As a result of the above, separate objections have been made in relation to the above
allocations and it is therefore important that alternative more deliverable sites should
be identified, to ensure the Plan can be regarded as being ‘sound’.
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Land off Parc Gelliwastad, Llandybie
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3.0 THE PROPOSAL
3.0.1 As part of the requirements for the promotion of sites for residential development, an
indicative layout drawing was prepared as part of the original Candidate Site Stage
submissions. It should be emphasised that the accompanying layout is for illustrative
purposes and that other design solutions for the site could also be reached.
Notwithstanding this, the accompanying layout drawing has taken account of all the
potential assets and constraints of the Site, as well as current Authority design
guidance, and demonstrates that it is capable of delivering 21 units in a deliverable
and sustainable manner. The following information therefore expands on this
principle.
3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Candidate Site be allocated in the forthcoming replacement
LDP for the purposes of 21 residential units. As detailed above, the accompanying
illustrative layout (reproduced below) demonstrates that the site is capable of
accommodating this number in a deliverable and sustainable manner.
Plan C
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3.1.2 As illustrated above, the site is potentially capable of accommodating a mix of unit
sizes and types, with the associated density – 21 units – having therefore taken into
consideration this potential mix. The form of development for the Alternative Site is
also capable of respecting and retaining its current means of enclosure and natural
boundary features both at the edge and within the Site.
3.1.3 With regards then to access, it is proposed that the Alternative Site would be served
by the existing estate road running along part of its eastern boundary. This would
then extend into the Site, off which several private shared driveways would branch.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Any development of the Alternative Site for residential units would be served by
mains water, public sewer and electricity, connections to which we understand lie
within or in close proximity to the Site.
3.2.2 With regards then to surface water, it is considered that as a result of on-site
features, there would be a number of options available to any development of the site
in terms of its disposal, ensuring its development adheres to current regulatory
requirements.
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Land off Parc Gelliwastad, Llandybie
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4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 The Site does not contain any protected flora or fauna, or signs of their presence.
Notwithstanding this, any potential biodiversity assets the Site may include have been
given full consideration with regards to exploring its potential for residential
development. This has included the proposed retention and management of existing
site boundary features.
4.1.2 The Alternative Site has been assessed against data held on the “Magic Map”
website which details statutory and non-statutory National and Local sites of
ecological importance. Plan D below provides an extract of those records applied to
the Llandybie locality, with the red star denoting the position of the Alternative Site.
Plan D
4.1.3 As can be seen from the above, the Alternative Site does not form part of and neither
is it near any national or local designations. Although a number are within 2-4km of
the site, due to the intervening distance and topography, the development of the
Alternative Site will not have any detrimental impact on these features.
Alternative Allocation Report April 2023
Land off Parc Gelliwastad, Llandybie
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4.2 HISTORICAL ASSETS
4.2.1 Below is an extract from the ‘Archwilio’ website that represents a resource for the
Historic Environment Records of Wales, with the Alternative Site indicated by a red
star.
Plan E
4.2.2 Whilst the Llandybie’s core includes a number of Listed Buildings, as can be seen,
neither the Alternative Site nor immediately adjoining element of the settlement
includes any Scheduled Ancient Monuments, Listed Buildings or Conservation
Area’s. As a result, the development of the Site would not have any detrimental
impact on the setting or interest of any nearby historical asset.
4.3 ENVIRONMENTAL CONSTRAINTS
4.3.1 The Candidate Site is not categorised as being at risk of flooding in terms of the
Development Advice Maps or those produced by Natural Resources Wales, as
illustrated by the plans below (Alternative Site indicated by the red star).
Alternative Allocation Report April 2023
Land off Parc Gelliwastad, Llandybie
14
Plan F
(Development Advice Maps)
Plan G
(Flood Maps for Planning)
4.3.2 In terms of ground conditions, due to its greenfield nature, the Candidate Site has no
ground contamination related constraints.
Alternative Allocation Report April 2023
Land off Parc Gelliwastad, Llandybie
15
5.0 VIABILITY
5.0.1 As part of the preparation of any development plan, it is vital to ensure that
allocations within it are both viable and deliverable. To not make efforts to explore
both these aspects is to then risk that the Plan may be unsound and so in turn fail to
meet its own targets or objectives.
5.0.2 Although detailed viability appraisals are difficult to prepare at this stage of the Plan’s
preparation due to the absence of, for example, such things as full engineering
details, it is possible to undertake such appraisals at a strategic or in-principle level.
The following therefore represents such a process and is fit-for-purpose in providing
confidence with regards to both the viability and deliverability of the Alternative Site at
this stage, but it should be noted, that more detailed analysis at a planning
application stage may result in some variance.
5.1 VIABILITY APPRAISAL
5.1.1 The following provides an indication of the viability of delivering the proposed 21 units
on the Alternative Site in question, based on a typical house type mix. It is based very
much on its greenfield status and uses figures and costings previously accepted by
the local authority through its determination of planning applications and other works.
The following appraisal is therefore based on the assumptions set out below in order
to provide a residual value for the scheme, prior to ascertaining an indicative land
value.
Costs
 Dwelling construction costs are based on £1,150 per metre
 Adoptable road construction cost based on £1200 per metre
 Connections for all utilities include water, foul water and electric
 Developer’s Profit based on RICS guidelines (18%)
 Professional Fees include planning application fee, associated professional
fees, estate agency fees (1%) and LABC Warranty fee.
Alternative Allocation Report April 2023
Land off Parc Gelliwastad, Llandybie
16
Sales
 Sale Prices based on LPAs Affordable Housing SPG, market research and
ACG figures where relevant.
5.1.2 Using the above, the following represents a strategic viability appraisal for the
proposed 21 units, with 3 units being made available on an affordable basis (based
on 3 three bed units).
Costs
Cost Per
Unit/Metre
No.
Units/Metres Total
4 Bed (150 sqm) 172500 5 862500
3 Bed (110 sq m) 126500 16 2024000
Utility Connections 5000 21 105000
Road and Access 1200 80 96000
Professional Fees - 112951
Sprinklers 3500 21 73500
Parks and Education Cont. 5000 21 100000
Total 3373951
Sales
3 Bed (110 sqm) (Aff.) 76380 3 229140
4 Bed (150 sqm) 310000 5 1550000
3 Bed (110 sq m) 270000 13 3510000
5289140
Total 5289140
Developers Profit Total 952045.2
Residual Land Value 963143.8
Table 2
5.1.3 Although the above figures have not been able to take into account any future
changes to construction costs as a result of other external factors (e.g. changes to
Building Regulations), it is considered that in-principle, the development of the site
would be financially viable.
Alternative Allocation Report April 2023
Land off Parc Gelliwastad, Llandybie
17
5.2 DELIVERABILITY
5.2.1 In terms of deliverability, it should be firstly noted, as illustrated above, that the site is
financially and physically viable, with no environmental, geo-physical or technical
constraints prohibiting immediate development. Furthermore, there are no ownership
or third-party interests preventing the site’s delivery.
5.2.2 In terms of a delivery timescale, it is envisaged that the site could be capable of being
completed within 2 years from the adoption of the Replacement Local Development
Plan.
Alternative Allocation Report April 2023
Land off Parc Gelliwastad, Llandybie
18
6.0 NATIONAL PLANNING POLICY CONSIDERATIONS
6.0.1 In the preparation of any development plan, consideration must be given to national
policy and guidance. At present, this takes the form of Planning Policy Wales (PPW)
(Edition 11) and a series of Technical Advice Notes (TAN) that deal with a range of
topic areas.
6.1 HOUSING SUPPLY
6.1.1 With regards to the provision of housing, Paragraph 4.2.2 of PPW gives the following
requirements the planning system must fulfil:
 Identify a supply of land to support the delivery of the housing requirement to
meet the differing needs of communities across all tenures;
 Enable the provision of a range of well designed, energy efficient, good quality
market and affordable housing that will contribute to the creations of sustainable
places; and
 Focus on the delivery of the identified housing requirement and the related land
supply
6.1.2 In addition to the above, Paragraph 4.2.10 of PPW states “the supply of land to meet
the housing requirement proposed in a development plan must be deliverable”. As
detailed previously, it is considered that the LPA has to date failed to accomplish this
requirement under the provisions of the current LDP and will continue to do so under
the provisions of the proposed allocations of the 2nd Deposit LDP.
6.1.3 In order therefore to re-dress this deficiency in provision, and provide a more robust
approach to housing provision through a mixed site-scale approach, there is an
urgent need to identify alternative deliverable housing allocations in the replacement
Plan. Based on the accompanying information, it is clear that the Alternative Site
represents one such example.
Alternative Allocation Report April 2023
Land off Parc Gelliwastad, Llandybie
19
7.0 CONCLUSION
7.1 Although currently undeveloped, the Alternative Site forms a logical extension to an
existing settlement, being well related to it and being positioned at a location within
the wider landscape to not form a prominent or logical part of the surrounding open
countryside.
7.2 In addition to the above, the site lies within close proximity and walking distance of
the existing community services and local facilities of the adjoining settlement. From
a wider sense, the Site will also benefit from well served excellent public transport
links to the adjoining larger conurbation of Ammanford and indeed Cross Hands and
Carmarthen, together with other locations within and adjoining the County, further
increasing the facilities and services available to future residents of the Site via
sustainable transport means.
7.3 In tandem to the above, the development of the Site will in turn ensure a viable and
so deliverable source of future housing for the area it forms part of, which has seen a
dangerous level of under supply prior to and since the adoption of the current LDP.
The development of the Site will help to redress this imbalance and it is strongly
suggested that the Authority closely scrutinises those sites currently allocated in the
LDP in terms of their suitability and deliverability if it is to continue to allocate them.
National planning policy however would suggest that in view of the uncertainty in
relation to their delivery, such sites should not form part of the replacement LDP.
7.4 With the Alternative Site having no access, ground condition, flood risk, hydrological,
ecological, archaeological or land ownership related constraints, its delivery if
allocated is assured. Combined therefore with its locational characteristics, the Site in
question represents a sustainable candidate for future housing development.
Alternative Allocation Report April 2023
Land off Parc Gelliwastad, Llandybie
20
7.5 In view of the above and information provided in this Statement, it is respectfully
requested that the Alternative Site in question be designated for residential
development.

Include the alternative site as a housing allocation in the Revised LDP.

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Mr M Jay to prepare and submit
an Alternative Allocation Report for the allocation of land adjoining Plasnewydd,
Foelgastell for the purposes of residential development in the forthcoming
replacement Carmarthenshire Local Development Plan (LDP).
1.2 This report has been prepared in line with the Authority’s published site assessment
and selection documents. The contents of this report therefore address each point
raised within these documents as well as ensuring that it complies with regards to the
guidance and requirements of Planning Policy Wales (Edition 11) when it comes to
the preparation of development plans and the allocation of land for residential
purposes as part of them.
1.3 The contents of this report therefore provide a comprehensive case for the allocation
of the land for residential development purposes, and it should also be read in
conjunction with the accompanying information and indicative drawing package, as
well as a sustainability assessment undertaken in-line with the Authority’s
requirements.
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell

2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Alternative Site relates to a parcel of land measuring approximately 1.8 acres in
area in total, edged red on the plan and the photograph below.
Plan A
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
Photograph 1
2.1.2 Following recent land management, the site currently has a clear appearance, as
illustrated by the photographs below:
Photograph 2 Photograph 3
2.1.3 As can be seen from the above photographs, the site is generally level. In addition, all
it’s boundaries are clearly and well defined, the majority of which are mature tree
lines or hedgerows. The exception is the north-western boundary (Photograph 2),
which is more domestic in appearance, being shared with existing residential
development beyond.
2.1.4 Access to the site is currently gained via an existing field entrance in the site’s south
western boundary, leading directly onto the adjoining public highway (Heol y Foel).
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
The frontage of the site shared with the adjoining highway is particularly straight,
providing excellent visibility in both directions, as illustrated below.
Photograph 4 Photograph 5
2.1.5 Under the provisions of the current Carmarthenshire LDP, the Site presently lies at
the southern edge of the defined Development Limits of the settlement of Foelgastell.
However, as the extract of the Proposals Map below illustrates, the Site (outlined in
red) adjoins the current built form of the urban area directly to the north west, with its
remaining boundaries presenting a very strong and defensible boundary to the much
more open landscape to the east and north east of the site.
Plan B
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
2.1.6 As can be seen, the Alternative Site is therefore well related to the existing defined
Development Limits for Foelgastell and the settlement’s built form as a whole when
existing residential development directly to its north west and indeed that to its south
east, is taken into consideration. Its position and proposed use therefore represent a
natural and logical location for the settlement’s expansion.
2.2 THE ADJOINING SETTLEMENT
2.2.1 As detailed above, the Alternative Site adjoins the existing built form of the settlement
of Foelgastell. Foelgastell is a linear style development in form, with the bulk of it
being located along Heol y Foel. In more recent times, development has then
occurred ‘in-depth’ off Heol y Foel, with examples being found at Parc y Gelli and
Parc Newydd.
2.2.2 In terms of community facilities and local services, the settlement of Foelgastell
includes a public house, play area, place of worship, as well as a regularly served bus
stop. However, the site (indicated by the red star on Plan C) is in close proximity to
the larger wider conurbation of Cross Hands and its outlying settlements to the south
east (see Plan C below).
Plan C
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
2.2.3 The strong sustainable position of the Alternative Site should therefore be given full
consideration when considering potential future growth options.
2.2.4 In terms of planned growth for Foelgastell, the 2nd Deposit LDP currently contains no
proposed housing allocations for the Plan period. This in itself is surprising,
considering the sustainable qualities of the settlement.
2.2.5 Notwithstanding the above, the proposed Alternative Site lies in close proximity and is
well related to one of the 3 identified Principal Centres within the 2nd Deposit LDP
Within these areas, the majority of the County’s growth (particularly with regards to
housing) is expected to be accommodated within the Plan period. However, having
undertaken a comprehensive review of the proposed allocations put forward by the
2nd Deposit LDP for the Principal Centre in question, it has been identified that a
number have significant questions over their ability to be delivered within the Plan
period, including the following:
Ref. No. Site Name Units
PrC3/h4 Tirychen Farm 150
PrC3/h36 Betws Colliery 60
PrC3/h14 Nantydderwen, Tumble 33
PrC3/h22 Adj. to Pant y Blodau, Penygroes 79
PrC3/h2 Heol Gelynen, Brynamman 8
Table 1
2.2.6 As a result of the above, separate objections have been made in relation to the above
allocations and it is therefore important that alternative more deliverable sites should
be identified, to ensure the Plan can be regarded as being ‘sound’.
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell

3.0 THE PROPOSAL
3.0.1 As part of the requirements for the promotion of sites for residential development, this
Statement is accompanied by an indicative layout for a potential residential scheme
that could be developed on the site. It should be emphasised that the accompanying
layout is for illustrative purposes and that other design solutions for the site could also
be reached. Notwithstanding this, the accompanying layout drawing has taken
account of all the potential assets and constraints of the site, as well as current
Authority design guidance, and demonstrates that it is capable of delivering 6 units in
a deliverable and sustainable manner. The following information therefore expands
on this principle.
3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Candidate Site be allocated in the forthcoming replacement
LDP for the purposes of 6 residential units. As detailed above, the accompanying
illustrative layout (reproduced below) demonstrates that the site is capable of
accommodating this number in a deliverable and sustainable manner.
Plan D
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
3.1.2 As illustrated above, the site is potentially capable of accommodating a mix of unit
sizes and types, with the associated density – 6 units – having therefore taken into
consideration this potential mix. The form of development for the Alternative Site is
also capable of following the current development form of existing properties
positioned along Heol y Foel.
3.1.3 With regards then to access, it is proposed that the Alternative Site would be served
either by a single point of access serving a shared access drive, or via individual
private drives as illustrated in Plan D. In both situations, as can be seen in the
Photographs at Section 2, the required level of visibility is achievable in both
directions.
3.1.4 The Alternative Site proposal can retain and enhance existing boundary treatments
as recommended in the accompanying Ecological Appraisal, as well as
accommodating further biodiversity enhancements within a detailed scheme for the
site.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Any development of the Alternative Site for residential units would be served by
mains water, public sewer and electricity, connections to which we understand lie
within or in close proximity to the Site.
3.2.2 With regards then to surface water, it is considered that as a result of on-site
features, there would be a number of options available to any development of the site
in terms of its disposal, ensuring its development adheres to current regulatory
requirements.
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell

4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 Accompanying this submission is an Ecological Appraisal for the site. As indicated,
the Site does not contain any protected flora or fauna, or signs of their presence.
However, and in line with the Appraisal’s recommendations, any potential biodiversity
assets the Site may include have been given full consideration with regards to
exploring its potential for residential development. This has included the proposed
retention and management of existing site boundary features.
4.1.2 The Alternative Site has been assessed against data held on the “Magic Map”
website which details statutory and non-statutory National and Local sites of
ecological importance. Plan E below provides an extract of those records applied to
the Foelgastell locality, with the red star denoting the position of the Alternative Site.
Plan E
4.1.3 As can be seen from the above, the Alternative Site does not form part of and neither
is it near any national or local designations. Although a number are within 2-4km of
the site, due to the intervening distance and topography, the development of the
Alternative Site will not have any detrimental impact on these features.
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
4.2 HISTORICAL ASSETS
4.2.1 Below is an extract from the ‘Archwilio’ website that represents a resource for the
Historic Environment Records of Wales, with the Alternative Site indicated by a red
star.
Plan F
4.2.2 As can be seen, neither the Alternative Site nor immediately adjoining element of the
settlement includes any Scheduled Ancient Monuments, Listed Buildings or
Conservation Area’s. As a result, the development of the Site would not have any
detrimental impact on the setting or interest of any nearby historical asset.
4.3 ENVIRONMENTAL CONSTRAINTS
4.3.1 The Candidate Site is not categorised as being at risk of flooding in terms of the
Development Advice Maps or those produced by Natural Resources Wales, as
illustrated by the plans below (Alternative Site indicated by the red star).
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
Plan G
(Development Advice Maps)
Plan H
(Flood Maps for Planning)
4.3.2 Due to its greenfield nature, the Candidate Site has no ground contamination related
constraints.
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
5.0 VIABILITY
5.0.1 As part of the preparation of any development plan, it is vital to ensure that
allocations within it are both viable and deliverable. To not make efforts to explore
both these aspects is to then risk that the Plan may be unsound and so in turn fail to
meet its own targets or objectives.
5.0.2 Although detailed viability appraisals are difficult to prepare at this stage of the Plan’s
preparation due to the absence of, for example, such things as full engineering
details, it is possible to undertake such appraisals at a strategic or in-principle level.
The following therefore represents such a process and is fit-for-purpose in providing
confidence with regards to both the viability and deliverability of the Alternative Site at
this stage, but it should be noted, that more detailed analysis at a planning
application stage may result in some variance.
5.1 VIABILITY APPRAISAL
5.1.1 The following provides an indication of the viability of delivering the proposed 6 units
on the Alternative Site in question. It is based very much on its greenfield status and
uses figures and costings previously accepted by the local authority through its
determination of planning applications and other works. The following appraisal is
therefore based on the assumptions set out below in order to provide a residual value
for the scheme, prior to ascertaining an indicative land value.
Costs
 Dwelling construction costs are based on £1,300 per metre given that
bespoke four bed detached houses (169 sq.m.), with a medium grade of
internal finishing.
 Adoptable road construction cost based on £1200 per metre
 Connections for all utilities include water, foul water and electric
 Developer’s Profit based on RICS guidelines (18%)
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
 Professional Fees include planning application fee, associated professional
fees, estate agency fees (1%) and LABC Warranty fee.
Sales
 Sale Prices based on LPAs Affordable Housing SPG, market research and
ACG figures where relevant.
5.1.2 Using the above, the following represents a strategic viability appraisal for the
proposed 6 units, based on an affordable housing level being a financial contribution
of £40.42 per square metre of internal floorspace.
Costs
Cost Per
Unit/Metre
No.
Units/Metres Total
4 Bed semi(169 sqm) 219700 6 1318200
Utility Connections 5000 6 30000
Professional Fees - 42600
Sprinklers 3500 6 21000
Affordable Hsng. Cont. 42000
Parks and Education Cont. 5000 6 100000
Total 1553800
Sales
4 Bed semi(169 sqm) 425000 6 2550000
Total 2550000
Developers Profit Total 459000
Residual Land Value 537200
Table 2
5.1.3 Although the above figures have not been able to take into account any future
changes to construction costs as a result of other external factors (e.g. changes to
Building Regulations), it is considered that in-principle, the development of the site
would be financially viable.
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
5.2 DELIVERABILITY
5.2.1 In terms of deliverability, it should be firstly noted, as illustrated above, that the site is
financially and physically viable, with no environmental, geo-physical or technical
constraints prohibiting immediate development. Furthermore, there are no ownership
or third-party interests preventing the site’s delivery.
5.2.2 In terms of a delivery timescale, it is envisaged that the site could be capable of being
completed within 2 years from the adoption of the Replacement Local Development
Plan.
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
6.0 NATIONAL PLANNING POLICY CONSIDERATIONS
6.0.1 In the preparation of any development plan, consideration must be given to national
policy and guidance. At present, this takes the form of Planning Policy Wales (PPW)
(Edition 11) and a series of Technical Advice Notes (TAN) that deal with a range of
topic areas.
6.1 HOUSING SUPPLY
6.1.1 With regards to the provision of housing, Paragraph 4.2.2 of PPW gives the following
requirements the planning system must fulfil:
 Identify a supply of land to support the delivery of the housing requirement to
meet the differing needs of communities across all tenures;
 Enable the provision of a range of well designed, energy efficient, good quality
market and affordable housing that will contribute to the creations of sustainable
places; and
 Focus on the delivery of the identified housing requirement and the related land
supply
6.1.2 In addition to the above, Paragraph 4.2.10 of PPW states “the supply of land to meet
the housing requirement proposed in a development plan must be deliverable”. As
detailed previously, it is considered that the LPA has to date failed to accomplish this
requirement under the provisions of the current LDP and will continue to do so under
the provisions of the proposed allocations of the 2nd Deposit LDP.
6.1.3 In order therefore to re-dress this deficiency in provision, and provide a more robust
approach to housing provision through a mixed site-scale approach, there is an
urgent need to identify alternative deliverable housing allocations in the replacement
Plan. Based on the accompanying information, it is clear that the Alternative Site
represents one such example.
Alternative Allocation Report March 2023
7.0 CONCLUSION
7.1 Although currently undeveloped, the Alternative Site forms a logical extension to an
existing settlement, being well related to it and being positioned at a location within
the wider landscape to not form a prominent or logical part of the surrounding open
countryside.
7.2 In addition to the above, the site lies within close proximity and walking distance of
the existing community services and local facilities of the adjoining settlement, as well
as an element of the larger conurbation of Cross Hands to the south east. This will
then ensure it makes a positive contribution to both national and local sustainable
development objectives.
7.3 From a wider sense, the Site will also benefit from well served excellent public
transport links to the adjoining larger conurbation of Cross Hands and indeed
Carmarthen, together with other locations within and adjoining the County, further
increasing the facilities and services available to future residents of the Site via
sustainable transport means.
7.4 In tandem to the above, the development of the Site will in turn ensure a viable and
so deliverable source of future housing for the are it forms part of, which has seen a
dangerous level of under supply prior to and since the adoption of the current LDP.
The development of the Site will help to redress this imbalance and it is strongly
suggested that the Authority closely scrutinises those sites currently allocated in the
LDP in terms of their suitability and deliverability if it is to continue to allocate them.
National planning policy however would suggest that in view of the uncertainty in
relation to their delivery, such sites should not form part of the replacement LDP.
7.5 With the Alternative Site having no access, ground condition, flood risk, hydrological,
ecological, archaeological or land ownership related constraints, its delivery if
Alternative Allocation Report March 2023
Land adjoining Plasnewydd, Foelgastell
allocated is assured. Combined therefore with its locational characteristics, the Site in
question represents a sustainable candidate for future housing development.
7.6 In view of the above and information provided in this Statement, it is respectfully
requested that the Alternative Site in question be designated for residential
development.

Include Candidate Site reference SR/004/022 in the Plan

Further to the publication of the above document, we have been asked by our Client to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the
proposed provisions of Policy HOM1 are of particular interest to our Client. As a result, we
offer the following for the Authority’s consideration, and Inspector’s in due course.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/004/022, seeking the allocation of their land for future residential development within the
defined settlement limits of Ammanford/Betws as part of the Replacement Local
Development Plan. The Candidate Site (edged red below) comprised of a single existing
enclosure and an associated residential property with all boundaries clearly and well defined.

Plan A

As a result of this, existing residential development and their associated curtilages are
positioned directly to the north east, north west and south east. The site is also within close
proximity to the range of community facilities and local services the settlement and greater
urban area of Ammanford has to offer.
Following its due consideration, the Council then excluded the Site from the proposed
development limits for Ammanford/Betws in its 1st Deposit LDP, published in January 2020
(Plan B).

Plan B

In explaining its decision to exclude the site and not allocate it for residential purposes, the
Council advised in its ‘Site Assessment Table’ (January 2020) as follows:
“There is sufficient and more suitable land available for residential development within the
town to accommodate its housing need.”.

At the time of publication of the 1st Deposit LDP therefore, the only reason presented by the
Council for the exclusion of the site from the development limits and its non-allocation for
residential development, was on the basis that the Council considered there to be sufficient
alternative sites within the town to accommodate the housing need.

As part of the current consultation process into the 2nd Deposit LDP, the Council have again
published a “Site Assessment Table” (2023), which provides details of the Council’s analysis
of each received Candidate Site submission. We note that our Client’s land was considered
as part of this process and as a result the Council concluded as follows:

“There is sufficient and more suitable land available for residential development within the
town to accommodate its housing need. Access to the site would likely necessitate the
demolition of property likely to cause some disturbance to neighbouring properties. It is
unclear whether suitable visibility splays can be achieved.”

As can be seen, the initial rationale presented by the Council mirrors that at the 1st Deposit
LDP stage (housing land supply), but now the Council have questioned the means of access
to the site. Both reasons presented are puzzling, particularly the latter as the Candidate Site
submissions include a full Transport Statement that included new access provisions to serve
the site, in-line with the highway authority’s requirements. The proposed arrangement is
reproduced in Plan C below.

Plan C

It should of course be further noted that as a result of changes being brought in by the Welsh
Government later this year, the required level of visibility for new access will be reduced
even further. Unfortunately, it appears that in their assessment of the Candidate Site, the
Council have failed to take this and the submitted information into consideration. As a result
of this and the reasons above, we consider the sites exclusion to be an illogical and
erroneous decision by the Council and consider therefore that the LDP as it stands is
“unsound” and fails to meet the required Tests of Soundness.

Specifically, we consider that alternative allocations within the settlement and wider Principal
Centre are neither appropriate nor deliverable. We consider therefore that the land edged
red in Plan A, should be allocated for residential development under the provision of Policy
HOM1 of the Carmarthenshire Local Development Plan.
This formal representation letter supplements the following documents which comprise a
complete submission to the 2nd Deposit LDP Consultation stage:

- Completed Deposit LDP Representation Form
- Completed Integrated Sustainability Appraisal form
- Copy of Candidate Site Submission Report (August 2018)
- Ecological Appraisal
- Transport Statement

Response to Council’s Reasons for Non-Allocation of Site
Sufficient Residential Land Allocated Within Settlement
Part of the Council’s rationale for the non-allocation of the site for residential development is
on the basis that it considers that alternative allocations within Ammanford/Betws and the
wider Principal Centre it forms part of will deliver sufficient housing for the town during the
Plan period.

Under the current provision of the Deposit LDP, the Principal Centre has a range of
proposed residential allocations. Having undertaken a comprehensive review of the
proposed allocations put forward by the 2nd Deposit LDP for the Principal Centre in question,
it has been identified that a number have significant questions over their ability to be
delivered within the Plan period, including the following:

Ref. No. Site Name Units
PrC3/h4 Tirychen Farm 150
PrC3/h36 Betws Colliery 60
PrC3/h14 Nantydderwen, Tumble 33
PrC3/h22 Adj. to Pant y Blodau, Penygroes 79
PrC3/h2 Heol Gelynen, Brynamman 8

Table 1

As a result of the above – all of which have been allocated in previous development plans -
separate objections to their inclusion with the LDP have been made. This is due to the fact
that to continue to allocate such sites for residential development results in the Plan being
unsound. Alternative sites, such as that put forward by our Client, must therefore be
considered and brought forward in order to address this deficiency and ensure that the Plan
is sound in all respects.

In conclusion, this Representation to the 2nd Deposit Draft of the Revised LDP has sought to
examine the Council’s reasons for non-allocation of a Candidate Site. It has successfully
addressed the reasons put forward by the Authority for its exclusion and has highlighted that
currently proposed allocations are undeliverable.

We therefore respectfully request that this Representation be given careful examination, and
consequently the land in question be allocated for residential development as part of the
Carmarthenshire Local Development Plan to ensure that the document passes all the
relevant tests of soundness.

Include site within the Plan.

Site Ref: 026-017

Address:
Parc Yr Onnen (land part of Penybont Farm, Johnstown)
Traveller’s Rest,
Johnstown

Hectares: 2.51 (extending to 6 hectares in total with adjoining neighbouring land)

Proposed use of site: Mixed use/Employment area

The proposed development area (identified above) was included in the adopted Local Development Plan (LDP) 2006-2021 and also in the first deposit of the 2018 - 2033 LDP due to its potential to greatly enhance and promote the sustainable development of the West Carmarthen LDP. We feel strongly that this is still the case and should continue to be included in the second deposit either as an employment or mixed use area. The following demonstrates some of the benefits of why it should continue to be included.

Firstly, I would like to record my displeasure at the lack of communication regarding the revised 2nd deposit LDP with landowners. It was only by chance that this had come to my attention, one week before the closing date for public consultation and comments to be submitted.

This is a self contained area which would not require community infrastructure and occupies a key position that would assist in its marketing and have minimum impact on residential areas.

The West Carmarthen LDP proposes 1300 residential houses, many of which are being or have been built and with such large housing development must come opportunities for employment within easy reach in order to meet sustainability and climate change carbon reduction requirements.

The site in total spans 6 hectares and lends itself to meet the requirement of sustainability and climate change and has many positive aspects to promote this end. This area is within easy walking distance of the 1300 new houses and has opportunity of reducing carbon input due to its immediate proximity to residential areas while at the same time remaining separate to not create any negative impact. It has public transport serving the local community and Carmarthen town, passing along its boundaries.

In terms of access, it already possesses a highways standard road on the western side of the site, projecting into the site for approximately 70 meters. This access road is within a matter of a few 100 meters of the A40 dual carriageway which in turn brings you to the M4 motorway on the outskirts of Carmarthen.

Services are available at the eastern end of the site with electricity pylons already on site which could provide the required energy provisions.

As a mixed use area this could not only provide employment to current Welsh speaking population but could also provide some facilities to promote the Welsh language.

The land consists of brown earth, only used as grazing land. It is not highly productive but was suitable for growing grass for limited grazing purposes.

The small stream that passes through the area has been identified as not falling within flood zones 2 and 3 as per environment agency modelling and we have written confirmation from NRW. The land on both the western and eastern side of the stream rises quite rapidly at 20 meters either side, therefore any flood risk would be limited to small areas either side of the stream and would not be included in the main area to be developed. This can be accommodated within any detailed plan for the site.

The site is not located within or immediately adjacent to any sites designated for importance to Nature Conservation or Sites of Special Scientific Interest.

In conclusion, the site is highly compatible with the growth presented in the deposit LDP. In particular, it would provide employment opportunities within easy reach of the proposed west Carmarthen development scheme and thereby conform with the requirements of sustainability and climate change.

Any minimal flood risk and the high pressure gas pipe running through the site can be accommodated in any detailed plan for the area. Such an allocation would reinforce the employment provision and ensure a sustainable mixed use development is achieved. There could be no possible harm in its inclusion.

Allocate site for housing within the Revised LDP.

Further to the publication of the above document, we have been asked by our Client to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the
proposed provisions of Policy HOM1 and Policy SG1 are of particular interest to our Client.
As a result, we offer the following for the Authority’s consideration, and Inspector’s in due
course.

Our clients made a formal Strategic Candidate Site Submission in August 2018, which was
referenced SR/082/012, seeking the allocation of their land (edged red on Plan A) for a mix
of residential development, areas of formal and informal amenity space, together with an
area preserved for ecological interests, as part of the Replacement Local Development Plan.

Plan A

The site would serve the settlement of Llandybie and the surrounding area of the associated
Principal Centre (Cluster 3). The Strategic Candidate Site comprised of a series of existing
enclosures, with vehicular access gained directly off Blaneau Road, which runs along its
northern boundary. From a locational perspective, the site is also within close proximity to
the range of community facilities and local services the adjoining settlement and surrounding
area has to offer, as well as being in close proximity to a number of well served bus stops
that provide access to those services and facilities found in the wider region.

Following its due consideration, the Council then excluded the Site from the proposed
development limits for Llandybie in its 1st Deposit LDP, published in January 2020 (Plan B).

Plan B

In explaining its decision to exclude the site and not allocate it for residential purposes, the
Council advised in its ‘Site Assessment Table’ (January 2020) as follows:

“The site has been identified as being at high risk of flooding in the Revised Carmarthenshire
LDP SFCA. There are other more suitable sites available which can meet the housing needs
of the village.”

The above decision was somewhat puzzling and in our view erroneous, as (a) the SFCA
was wrong to exclude the whole of the site from consideration (the area of the Site within the
flood zone was minimal) and that (b) alternative allocations within the settlement and wider
growth area were clearly neither appropriate nor deliverable.

As part of the current consultation process into the 2nd Deposit LDP, the Council have again
published a “Site Assessment Table” (2023), which provides details of the Council’s analysis
of each received Candidate Site submission. We note that our Client’s land was considered
as part of this process and as a result the Council concluded as follows:

“The site has been identified as being at high risk of flooding in the Revised Carmarthenshire
LDP SFCA (2019). There are other more suitable sites available which can met the housing
needs of the village.”

As can be seen, the rationale presented by the Council replicates that at the 1st Deposit LDP
stage (flood risk and housing land supply), although when examined fully, they appear both
illogical and erroneous.
Plan C and Plan D below provide an indication under the provisions of Technical Note 15:
Development and Flood Risk of the considered current and emerging risk of flooding in
relation to the Site.

Plan C Plan D

(Development Advice Maps) Flood Maps for Planning)
As can be seen, less than 5% of the total area of the Site is considered to be at risk of
flooding. Furthermore, as illustrated on the submitted Indicative Layout Plan, none of this
area is required to deliver the mix of development put forward for the Site and so the Council
have undertaken an incomplete and clearly erroneous assessment of the Alternative
Strategic Site. As a result of this and the reasons below, we consider the sites exclusion to
be an illogical and erroneous decision by the Council and consider therefore that the LDP as
it stands is “unsound” and fails to meet the required Tests of Soundness.

Specifically, we consider that alternative allocations within the settlement and wider Principal
Centre are neither appropriate nor deliverable (see below). We consider therefore that the
land edged red in Plan A, should be allocated for residential development under the
provision of Policy HOM1 and Policy SG1 of the Carmarthenshire Local Development Plan.
This formal representation letter supplements the following documents which comprise a
complete submission to the 2nd Deposit LDP Consultation stage:

- Completed Deposit LDP Representation Form
- Completed Integrated Sustainability Appraisal form
- Copy of Candidate Site Submission Report (August 2018)
- Ecological Appraisal
- Transport Statement
- Indicative Master Plan

Response to Council’s Reasons for Non-Allocation of Site
Sufficient Residential Land Allocated Within Settlement
Part of the Council’s rationale for the non-allocation of the site for residential development is
on the basis that it considers that alternative allocations within Llandybie and the wider
Principal Centre it forms part of will deliver sufficient housing for the town during the Plan
period.

Under the current provision of the Deposit LDP, the Principal Centre has a range of
proposed residential allocations. Having undertaken a comprehensive review of the
proposed allocations put forward by the 2nd Deposit LDP for the Principal Centre in question,
it has been identified that a number have significant questions over their ability to be
delivered within the Plan period, including the following:

Ref. No. Site Name Units
PrC3/h4 Tirychen Farm 150
PrC3/h36 Betws Colliery 60
PrC3/h14 Nantydderwen, Tumble 33
PrC3/h22 Adj. to Pant y Blodau, Penygroes 79
PrC3/h2 Heol Gelynen, Brynamman 8

Table 1

As a result of the above – all of which have been allocated in previous development plans -
separate objections to their inclusion with the LDP have been made. This is due to the fact
that to continue to allocate such sites for residential development results in the Plan being
unsound. Alternative sites, such as that put forward by our Client, must therefore be
considered and brought forward in order to address this deficiency and ensure that the Plan
is sound in all respects.

In conclusion, this Representation to the 2nd Deposit Draft of the Revised LDP has sought to
examine the Council’s reasons for non-allocation of a Candidate Site. It has successfully
addressed the reasons put forward by the Authority for its exclusion and has highlighted that
currently proposed allocations are undeliverable and that the Council’s assessment of the
Alternative Strategic Site was flawed.

We therefore respectfully request that this Representation be given careful examination, and
consequently the land in question be allocated for mixed use development as part of the
Carmarthenshire Local Development Plan to ensure that the document passes all the
relevant tests of soundness.

Include site within the Plan

Further to the publication of the above document, we have been asked by our Clients to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the
proposed provisions of Policy HOM1 are of particular interest to our Clients. As a result, we
offer the following for the Authority’s consideration, and Inspector’s in due course.

Our Clients made a formal Candidate Site Submission in August 2018, which was
referenced SR/132/008, seeking the allocation of their land for future residential
development within the defined settlement limits of Penygroes as part of the Replacement
Local Development Plan. The Candidate Site (edged red below) comprised in effect of two
existing enclosures, split by a stock proof fence and public footpath.

Plan A

It should be noted that the adjoining development was constructed by our Clients and so
they have a recent proven development track record of delivering residential development in
the area. The site is then within close proximity to the range of community facilities and local
services the settlement has to offer.
Following its due consideration, the Council then excluded the Site from the proposed
development limits for Penygroes in its 1st Deposit LDP, published in January 2020 (Plan B).

Plan B

In explaining its decision to exclude the site and not allocate it for residential purposes, the
Council advised in its ‘Site Assessment Table’ (January 2020) as follows:

““Inclusion of the site would contribute towards the coalescence of two villages contrary to
general planning principles.”

At the time of publication of the 1st Deposit LDP therefore, the only reason presented by the
Council for the exclusion of the site from the development limits and its non-allocation for
residential development, was on the basis that the Council considered the development of
the site would lead to the coalescence of two villages. However, as can be seen from Plan A
and Plan B above, this is clearly not the case.

As part of the current consultation process into the 2nd Deposit LDP, the Council have again
published a “Site Assessment Table” (2023), which provides details of the Council’s analysis
of each received Candidate Site submission. We note that our Clients land was considered
as part of this process and as a result the Council concluded as follows:
“Inclusion of the site would contribute towards the coalescence of two villages contrary to
general planning principles. .”

As can be seen, the initial rationale presented by the Council replicates that at the 1st
Deposit LDP stage, but it is still considered that the reasoning given is illogical. Using the
relevant extract of the 2nd Deposit Proposals Map and highlighting in red the Alternative Site,
it can be seen that even with its development, a gap would remain between the southern
most limits of Penygroes and the northernmost limits of Capel Hendre.

Plan C

It is quite clear therefore, that the development of the Alternative Site would not lead to the
coalescence of two villages and as a result of this, we consider the sites exclusion to be an
illogical and erroneous decision by the Council and consider therefore that the LDP as it
stands is “unsound” and fails to meet the required Tests of Soundness. This is particularly
worrying, in view of the lack of deliverable allocations within the Principal Tier of which the
Alternative Site forms part of (please see below).
We consider therefore that the land edged red in Plan A, should be allocated for residential
development under the provision of Policy HOM1 of the Carmarthenshire Local
Development Plan.

This formal representation letter supplements the following documents which comprise a
complete submission to the 2nd Deposit LDP Consultation stage:

- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
- Copy of Candidate Site Submission Report (August 2018)
- Copy of Ecological Appraisal Report

Response to Council’s Reasons for Non-Allocation of Site
Sufficient Residential Land Allocated Within Settlement
We understand from discussions with Officers that part of the Council’s rationale for the nonallocation
of the site for residential development is on the basis that it considers that
alternative allocations within Penygroes and the wider Principal Centre it forms part of will
deliver sufficient housing for the area during the Plan period.

Under the current provision of the Deposit LDP, the Principal Centre has a range of
proposed residential allocations. Having undertaken a comprehensive review of the
proposed allocations put forward by the 2nd Deposit LDP for the Principal Centre in question,
it has been identified that a number have significant questions over their ability to be
delivered within the Plan period, including the following:

Ref. No. Site Name Units
PrC3/h4 Tirychen Farm 150
PrC3/h36 Betws Colliery 60
PrC3/h14 Nantydderwen, Tumble 33
PrC3/h22 Adj. to Pant y Blodau, Penygroes 79
PrC3/h2 Heol Gelynen, Brynamman 8

Table 1

As a result of the above – all of which have been allocated in previous development plans -
separate objections to their inclusion with the LDP have been made. This is due to the fact
that to continue to allocate such sites for residential development results in the Plan being
unsound. Alternative sites, such as that put forward by our Clients, must therefore be
considered and brought forward in order to address this deficiency and ensure that the Plan
is sound in all respects.

In conclusion, this Representation to the 2nd Deposit Draft of the Revised LDP has sought to
examine the Council’s reasons for non-allocation of a Candidate Site. It has successfully
addressed the reasons put forward by the Authority for its exclusion and has highlighted that
the reasons given are illogical and erroneous. In addition, it has been highlighted in
conjunction with our submissions made by this Practice, that the currently proposed
allocations put forward by the 2nd Deposit LDP are undeliverable.

We therefore respectfully request that this Representation be given careful examination, and
consequently the land in question be allocated for residential development as part of the
Carmarthenshire Local Development Plan to ensure that the document passes all the
relevant tests of soundness.

Amend Plan to include the site

We would like the Authority and the Planning Inspector to re-think its reason for not including this land and urge them to re-read our submitted evidence with our first submission
Land adjacent to Ty Coch, Llandyfaelog

Allocate the above site for housing within the Revised LDP.

Land off Lotwen Road, Capel Hendre
Further to the publication of the above document, we have been asked by our Client to review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the proposed provisions of Policy HOM1 are of particular interest to our Client. As a result, we
offer the following for the Authority’s consideration, and Inspector’s in due course.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced SR/018/002, seeking the allocation of their land for future residential development within the defined settlement limits of Capel Hendre as part of the Replacement Local Development Plan. The Candidate Site is edged red below in Plan A.

Please see accompanying Alternative Site Report attached.

Allocate the whole site for housing in the Revised LDP.

Further to the publication of the above document, we have been asked by our Client to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the
proposed provisions of Policy HOM1 are of particular interest to our Client. As a result, we
offer the following for the Authority’s consideration, and Inspector’s in due course.

Our Client made a formal Candidate Site Submission in August 2018, which was referenced
SR/159/006, seeking the allocation of their land for residential development within the
defined settlement limits of Tycroes as part of the Replacement Local Development Plan.
The Candidate Site (edged red below) comprised in effect of two elements – a now complete
residential development for 37 units in its western half and an undeveloped parcel of poor
agricultural land in its eastern half.

Plan A

It should be noted that the adjoining development retained provision to provide access to the
eastern half of the site, whilst access was also possible via the demolition of two properties
to its north, as illustrated below.
Plan B
The site is then within close proximity to the range of community facilities and local services
the settlement has to offer.

Following its due consideration, the Council then allocated the Candidate Site for residential
development in its 1st Deposit LDP, published in January 2020 (Plan C).

Plan B

Allocated under reference PrC3/h32, the allocation in its totality was expected to deliver a
total of 62 units within the first 10 years of the Plan’s lifetime.

Notwithstanding the above decision, and for reasons well known, the Council then revisited
its 1st Deposit LDP in preparation of a second version. As part of the preparation process for
the 2nd Deposit LDP, the Council have published a “Site Assessment Table” (2023), which
provides details of the Council’s analysis of each received Candidate Site submission,
including that subject of this objection. We note that our Clients land was considered as part
of this process and as a result the Council concluded as follows:

“The site is to be partly allocated for residential development. Site reference is PrC3/h32.”

According then to the 2nd Deposit LDP Proposals Maps, now only the western half of the
original Candidate Site is allocated for residential development (37 units) as illustrated in
Plan D, despite construction on this element of the Site having been completed in 2022.

Plan D

Other than the text quoted above, the Council have provided no explanation for the removal
of the eastern half of the Site from the allocation, or its reduction from 62 units to 37 units.
They have raised no highway, ecological, utility or viability reason for its exclusion. This is
not only illogical, but also appears to be a dangerous and erroneous decision to make,
particularly in light of the level of under provision of deliverable housing sites within the Plan.

As a result of this decision we therefore consider that the LDP as it stands is “unsound” and
fails to meet the required Tests of Soundness. As detailed, this is particularly worrying, in
view of the lack of deliverable allocations within the Principal Tier of which the Alternative
Site forms part of (please see below).
We consider therefore that all the land edged red in Plan A, should be allocated for
residential development under the provision of Policy HOM1 of the Carmarthenshire Local
Development Plan.

This formal representation letter supplements the following documents which comprise a
complete submission to the 2nd Deposit LDP Consultation stage:

- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
- Copy of Candidate Site Submission Report (August 2018)
- Copy of Ecological Appraisal Report

Response to Council’s Reasons for Non-Allocation of Site
Sufficient Residential Land Allocated Within Settlement
As detailed above, we are deeply concerned with the Council’s decision to reduce the
proposed housing allocation in question, and understand that this may be because the
Council holds the view that alternative allocations within Tycroes and the wider Principal
Centre it forms part of will deliver sufficient housing for the area during the Plan period. This
is in our view wholly incorrect.

Under the current provision of the Deposit LDP, the Principal Centre has a range of
proposed residential allocations. Having undertaken a comprehensive review of the
proposed allocations put forward by the 2nd Deposit LDP for the Principal Centre in question,
it has been identified that a number have significant questions over their ability to be
delivered within the Plan period, including the following:

Ref. No. Site Name Units
PrC3/h4 Tirychen Farm 150
PrC3/h36 Betws Colliery 60
PrC3/h14 Nantydderwen, Tumble 33
PrC3/h22 Adj. to Pant y Blodau, Penygroes 79
PrC3/h2 Heol Gelynen, Brynamman 8

Table 1

As a result of the above – all of which have been allocated in previous development plans -
separate objections to their inclusion with the LDP have been made. This is due to the fact
that to continue to allocate such sites for residential development results in the Plan being
unsound. Alternative sites, such as that put forward by our Client, must therefore be
considered and brought forward in order to address this deficiency and ensure that the Plan
is sound in all respects.

In conclusion, this Representation to the 2nd Deposit Draft of the Revised LDP has sought to
examine the Council’s reasons for non-allocation of the whole of the Candidate Site. It has
successfully addressed the reasons put forward by the Authority for its exclusion and has
highlighted that the reason given are illogical and erroneous. In addition, it has been
highlighted in conjunction with our submissions made by this Practice, that the currently
proposed allocations put forward by the 2nd Deposit LDP are undeliverable.

We therefore respectfully request that this Representation be given careful examination, and
consequently the land in question be allocated for residential development in its entirety as
part of the Carmarthenshire Local Development Plan to ensure that the document passes all
the relevant tests of soundness.

Allocate the site for housing within the Revised LDP.

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd has been instructed by Mrs K Fakes, Mr D James, Mr E
Roberts and Mr G Jones (the Land Owners) to prepare and submit an Alternative Site
Report for the allocation of land off Waterloo Road, Penygroes for the purposes of
residential development in the forthcoming replacement Carmarthenshire Local
Development Plan.
1.2 This report has been prepared in line with the Authority’s published site assessment
and selection documents. The contents of this report therefore address each point
raised within these documents as well as ensuring that it complies with regards to the
guidance and requirements of Planning Policy Wales (Edition 11) when it comes to
the preparation of development plans and the allocation of land for residential
purposes as part of them.
1.3 The contents of this report therefore provide a comprehensive case for the allocation
of the land for residential development purposes, and it should also be read in
conjunction with the accompanying information and indicative drawing package, as
well as a sustainability assessment undertaken in-line with the Authority’s
requirements.
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes

2.0 SITE CONTEXT
2.1 THE SITE
2.1.1 The Alternative Site relates to a parcel of land measuring just over 1.7ha, edged in
red on the plan and photograph below.
Plan A
Photograph 1
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes
2.1.2 The Site consists of three undeveloped enclosures that are in part laid to rough grass,
as illustrated in the photographs below.
Photograph 2 Photograph 3
2.1.3 As can be seen, the Site is gently sloping in nature and undeveloped. All of its
boundary features are well defined, consisting of a mix of hedgerows, stock proof
fencing and residential boundary treatments. The Site contains no water features
within it and ground composition we understand has good drainage qualities.
2.1.4 In terms of access, the Site can be accessed via two points. The first is directly off
Waterloo Road at the south western corner of the Site, which is also where a Public
Footpath dissects part of the proposed Site. The second then is directly off Spien
Road, which runs along the Site’s northern edge.
2.1.5 Under the provisions of the current Carmarthenshire Local Development Plan, the
site adjoins the Development Limits for the settlement of Penygroes, as illustrated in
the plan below.
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes
Plan B
2.1.6 As can be seen, a small part of the Site lies within the existing defined Development
Limits, with the remainder in essence being almost completely encapsulated by them.
Its position and proposed use therefore represents a natural and logical location for
the settlement’s expansion.
2.2 THE ADJOINING SETTLEMENT
2.2.1 As detailed above, the Alternative Site adjoins the existing settlement and form of
Penygroes. The existing built form and pattern of the settlement follows key access
routes, with then further development leading off these in depth, such as the
development of Spein Road to the north of the Site and that of Brynglas to the south.
The larger town of Ammanford is then located a short distance to Penygroes’ south
east and Cross Hands to the north west.
2.2.2 The Site is also located a short distance from the settlement’s core and within walking
distance of all of its community facilities and local services, as well as those offered
by the nearby settlement of Capel Hendre, all of which are marked by the blue circles
on the map below.
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes
Plan C
2.2.3 Access to further facilities in the larger towns of Ammanford, Llanelli and Cross
Hands can then be gained by regular bus services (including numbers 128 and 129),
a number of stops for which are within a short walk of the Alternative Site (marked by
the red circles on Plan C). The strong sustainable position of Penygroes should
therefore be given full consideration when considering potential future growth options.
2.2.4 In terms of planned growth put forward by 2nd Deposit LDP currently under
consultation, the settlement of Penygroes forms part one of the 3 identified Principal
Centres within the 2nd Deposit LDP. Within these areas, the majority of the County’s
growth (particularly with regards to housing) is expected to be accommodated within
the Plan period. However, having undertaken a comprehensive review of the
proposed allocations put forward by the 2nd Deposit LDP for the Principal Centre in
question, it has been identified that a number have significant questions over their
ability to be delivered within the Plan period, including the following:
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes
Ref. No. Site Name Units
PrC3/h4 Tirychen Farm 150
PrC3/h36 Betws Colliery 60
PrC3/h14 Nantydderwen, Tumble 33
PrC3/h22 Adj. to Pant y Blodau, Penygroes 79
PrC3/h2 Heol Gelynen, Brynamman 8
Table 1
2.2.5 As a result of the above, separate objections have been made in relation to the above
allocations and it is therefore important that alternative more deliverable sites should
be identified, to ensure the Plan can be regarded as being ‘sound’.
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes

3.0 THE PROPOSAL
3.0.1 As part of the requirements for the promotion of sites for residential development, this
Report is accompanied by an indicative layout for a potential residential scheme that
could be developed on the site. It should be emphasised that the accompanying
layout is for illustrative purposes and that other design solutions for the site could also
be reached. Notwithstanding this, the accompanying layout drawing has taken
account of all the potential assets and constraints of the site and demonstrates that it
is capable of delivering 33 units in a deliverable and sustainable manner. The
following information therefore expands on this principle.
3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Alternative Site be allocated in the forthcoming replacement
LDP for the purposes of 33 residential units. As detailed above, the accompanying
illustrative layout (reproduced below) demonstrates that the site is capable of
accommodating this number in a deliverable and sustainable manner.
Plan D
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes
3.1.2 As illustrated above, the site is also capable of accommodating a mix of unit sizes
and types, with the associated density – 33 units – having therefore taken into
consideration this potential mix, as well as striking a balance of being reflective of the
existing form and density of residential development in the immediate locality.
3.1.3 With regards then to access, it is proposed that the Alternative Site would be served
by two points of access off the existing local highway network – one off Waterloo
Road and one of Spien Road. The proposals would make provision for the existing
Public Footpath without the need for a diversion, as well as accommodating a speed
table (or similar) as illustrated to act as a form of natural traffic calming.
3.1.4 It is also envisaged that a small area of the site (as shown) could be used to extend
the existing equipped area of play located at the north eastern corner of the site. It is
also recognised and supported that an element of the proposed units would be
affordable in nature, which under the provisions of the current LDP would be in the
region of 12%.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Any development of the Alternative Site for residential units would be served by
mains water, public sewer and electricity, connections to which either lie within the
site or in the adjoining stretch of aforementioned newly constructed estate road
serving the adjoining residential development.
3.2.2 With regards then to surface water, it is considered that as a result of on-site
features, there would be a number of options available to any development of the site
in terms of its disposal.
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes

4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 Any potential biodiversity assets the Site may include have been given full
consideration with regards to exploring its potential for residential development. This
has included the proposed retention and management of existing hedgerow features
forming part of the Land Owners wider ownership.
4.1.2 The site does not form part of any local or national nature conservation designation.
In the wider content, there are then 8 further SSSI designations and 1 SAC
designation within 3km of the Alternative Site (red star on Plan E), who’s locations
are illustrated on the plan below.
Plan E
4.1.3 In view of the above, it is considered that due to the separation distance from these
designations and the Alternative Site, together with intervening topography (including
existing residential development) that these factors will ensure that its development
would have no detrimental impact on any local or national designation.
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes
4.2 HISTORICAL ASSETS
4.2.1 Below is an extract from the ‘Archwilio’ website that represents a resource for the
Historic Environment Records of Wales, with the Alternative Site indicated by a red
star.
Plan F
4.2.1 As can be seen, neither the Alternative Site nor immediately adjoining element of the
settlement includes any Scheduled Ancient Monuments, Listed Buildings or
Conservation Area’s. As a result, the development of the Site would not have any
detrimental impact on the setting or interest of any nearby historical asset.
4.3 ENVIRONMENTAL CONSTRAINTS
4.3.1 The Candidate Site is not categorised as being at risk of flooding in terms of the
Development Advice Maps or those produced by Natural Resources Wales, as
illustrated by the plans below (Alternative Site indicated by the red star).
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes
Plan G
(Development Advice Maps)
Plan H
(Flood Maps for Planning)
4.3.2 Due to its greenfield nature and agricultural use, the Alternative Site has no ground
contamination related constraints.
4.3.3 Whilst many areas in the locality have been the subject of mining in the past, Plan F
below (obtained from the Coal Authority) shows that the Alternative Site (marked with
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes
a red star) has no known surface or underground workings, or mine entries or
associated ventilation shafts within it.
Plan I
4.3.4 As a result, the Site has no ground stability related constraints to its proposed
development
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes

5.0 VIABILITY
5.0.1 As part of the preparation of any development plan, it is vital to ensure that
allocations within it are both viable and deliverable. To not make efforts to explore
both these aspects is to then risk that the Plan may be unsound and so in turn fail to
meet its own targets or objectives.
5.0.2 Although detailed viability appraisals are difficult to prepare at this stage of the Plan’s
preparation due to the absence of, for example, such things as full engineering
details, it is possible to undertake such appraisals at a strategic or in-principle level.
The following therefore represents such a process and is fit-for-purpose in providing
confidence with regards to both the viability and deliverability of the Alternative Site at
this stage, but it should be noted, that more detailed analysis at a planning
application stage may result in some variance.
5.1 VIABILITY APPRAISAL
5.1.1 The following provides an indication of the viability of delivering the proposed 6 units
on the Alternative Site in question. It is based very much on its greenfield status and
uses figures and costings previously accepted by the local authority through its
determination of planning applications and other works. The following appraisal is
therefore based on the assumptions set out below in order to provide a residual value
for the scheme, prior to ascertaining an indicative land value.
Costs
 Dwelling construction costs are based on £1,150 per metre
 Adoptable road construction cost based on £1200 per metre
 Connections for all utilities include water, foul water and electric
 Developer’s Profit based on RICS guidelines (18%)
 Professional Fees include planning application fee, associated professional
fees, estate agency fees (1%) and LABC Warranty fee.
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes

Sales
 Sale Prices based on LPAs Affordable Housing SPG, market research and
ACG figures where relevant.
5.1.2 Using the above, the following represents a strategic viability appraisal for the
proposed 33 units, with 4 units being made available on an affordable basis (based
on 4 three bed units).
Costs Cost Per Unit/Metre No. Units/Metres Total
Four Bed Dwelling 239200 8 1913600
Three Bed Dwellings 161805 17 2750685
Three Bed Bungalow 131963 8 1055704
Shared Drive Construction 400 134 53600
Road Construction 1200 300 360000
Utility Connections 5000 33 165000
Professional Fees - - 184355
Sprinklers 3500 33 115500
Parks and Education Cont. 5000 33 165000
Total 6598444
Sales
Four Bed Dwelling (Open
Market) 320000 8 2560000
Three Bed Dwellings (Open
Market) 280000 13 3640000
Three Bed Bungalow (Open
Market) 300000 8 2400000
Three Bed Dwelling
(Affordable) 79,380 4 317520
Total 8917520
Developers Profit Total 1337628
Residual Land Value 981448
Table 2
5.1.1 Based on the above figures, it is considered that in-principle, the development of the
site would be financially viable.
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes

5.2 DELIVERABILITY
5.2.1 In terms of deliverability, it should be firstly noted, as illustrated above, that the site is
viable. Furthermore, there are no ownership or physical constraints preventing the
Site’s delivery.
5.2.2 In terms of a delivery timescale, with a developer secured, it is envisaged that the site
could be capable of being completed within 3-4 years from the adoption of the
replacement LDP, as well as in a phased manner within this time period.
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes

6.0 NATIONAL PLANNING POLICY CONSIDERATIONS
6.0.1 In the preparation of any development plan, consideration must be given to national
policy and guidance. At present, this takes the form of Planning Policy Wales (PPW)
(Edition 11) and a series of Technical Advice Notes (TAN) that deal with a range of
topic areas.
6.1 HOUSING SUPPLY
6.1.1 With regards to the provision of housing, Paragraph 4.2.2 of PPW gives the following
requirements the planning system must fulfil:
 Identify a supply of land to support the delivery of the housing requirement to
meet the differing needs of communities across all tenures;
 Enable the provision of a range of well designed, energy efficient, good quality
market and affordable housing that will contribute to the creations of sustainable
places; and
 Focus on the delivery of the identified housing requirement and the related land
supply
6.1.2 In addition to the above, Paragraph 4.2.10 of PPW states “the supply of land to meet
the housing requirement proposed in a development plan must be deliverable”. As
detailed previously, it is considered that the LPA has to date failed to accomplish this
requirement under the provisions of the current LDP and will continue to do so under
the provisions of the proposed allocations of the 2nd Deposit LDP.
6.1.3 In order therefore to re-dress this deficiency in provision, and provide a more robust
approach to housing provision through a mixed site-scale approach, there is an
urgent need to identify alternative deliverable housing allocations in the replacement
Plan. Based on the accompanying information, it is clear that the Alternative Site
represents one such example.
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes

7.0 CONCLUSION
7.1.1 Although currently undeveloped, the Alternative Site forms a logical extension to the
existing settlement, being well related to and encapsulated by it, as well as being
positioned at a location within the wider landscape to not form a prominent or logical
part of the surrounding open countryside.
7.1.2 In addition to the above, the Site lies within close proximity and walking distance of
the existing community services and local facilities of the adjoining settlement, which
will ensure it makes a positive contribution to both national and local sustainable
development objectives.
7.1.3 From a wider sense, the Site also benefits from well served excellent public transport
links to the nearby settlements, the larger towns of Ammanford and Cross Hands,
together with other locations within and adjoining the County, further increasing the
facilities and services available to future residents of the Site via sustainable transport
means. In tandem to this, the development of the Site will in turn ensure a deliverable
source of future housing for the settlement and Principal Centre in which it lies, which
has seen a dangerous level of under supply prior to and since the adoption of the
current LDP. The development of the Site will help to redress this imbalance and it is
strongly suggested that the Authority closely scrutinises those sites currently
allocated in the LDP in terms of their suitability and deliverability if it is to continue to
allocate them. National planning policy however would suggest that in view of the
uncertainty in relation to their delivery, such sites should not form part of the
replacement LDP.
7.1.4 With the Alternative Site having no access, ground condition, flood risk, hydrological,
ecological, archaeological or land ownership related constraints, its delivery if
allocated is assured. Combined therefore with its locational characteristics, the Site in
question represents a sustainable candidate for future housing development.
Alternative Site Supporting Statement March 2023
Land off Waterloor Road, Penygroes
7.1.5 In view of the above it is considered that in its current form, the 2nd Deposit LDP fails
to adheres to the Tests of Soundness as a number of the currently proposed
residential allocations will fail to be delivered. In contrast, the Alternative Site
presented herein does satisfy all Tests, and so it is respectfully requested that the
Alternative Site in question be allocated for residential development.

Allocate the above site for housing within the RLDP.

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Omnicorp Ltd to prepare and
submit an Alternative Allocation Report for the allocation of land off Parc y Delyn,
Carmarthen for the purposes of residential development in the forthcoming
replacement Carmarthenshire Local Development Plan (LDP).
1.2 This statement has been prepared in line with the Authority’s published site
assessment and selection documents. The contents of this Statement therefore
address each point raised within these documents as well as ensuring that it
complies with regards to the guidance and requirements of Planning Policy Wales
(Edition 11) when it comes to the preparation of development plans and the allocation
of land for residential purposes as part of them.
1.3 The contents of this Statement therefore provide a comprehensive case for the
allocation of the land for residential development purposes, and it should also be
read in conjunction with the accompanying information and indicative drawing
package, as well as a sustainability assessment undertaken in-line with the
Authority’s requirements.
Alternative Allocation Report April 2023
Land off Parc y Dleyn, Carmarthen

2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Alternative Allocation relates to the parcel of land edged red on the plan and
image below.
Plan A
Photograph 1
Alternative Allocation Report April 2023
Land off Parc y Dleyn, Carmarthen
2.1.2 The majority of the Site is made up of a single field enclosure that is dominated by
semi-improved grassland (see photograph below) with large areas of scrub and
slopes downwards in a north to south direction:
Photograph 1
2.1.3 The boundaries of the Site are well defined by a mix of hedgerows, trees and stock
proof fencing. Further trees of varying states of health can be found throughout a
number of areas of the application site, as detailed in the accompanying Tree Survey
Report.
2.1.4 The remaining elements of the Site then relate to small strips of land (all in the control
of the Applicant or forming part of the public highway) along the eastern edge of
Penlan Road, which will be utilised as part of the proposed development to widen the
exiting carriageway and improve pedestrian linkages. Pedestrian access to the
application site is at present via Parc y Delyn through informal vegetation. The access
is identified by the red arrow on the aerial image below:
Alternative Allocation Report April 2023
Land off Parc y Dleyn, Carmarthen
Photograph 2
2.1.5 Although this is the existing access to the site, a new vehicular and pedestrian access
is proposed as part of this development along Penlan Road.
2.1.6 Under the provisions of the current Carmarthenshire LDP, the core of the Site is
currently allocated for residential development, as illustrated by Plan B below.
Plan B
Alternative Allocation Report April 2023
Land off Parc y Dleyn, Carmarthen
2.1.7 In response to the above allocation, a planning application for 20 units is currently
being finalised to be submitted to the LPA for its consideration and determination in
due course. However, as will be noted, the total area of the proposed Alternative
Allocation is greater than the above allocation to allow for highway improvements and
biodiversity mitigation and gain measures.
2.2 THE ADJOINING SETTLEMENT
2.2.1 In the immediate sense, the land to the north of the site currently forms part of a wider
enclosure that includes the application site. The land to the south and west is then
dominated by existing residential development, forming part of the greater urban area
of Carmarthen.
2.2.2 As detailed above, the Alternative Allocation forms part of the greater urban area of
Carmarthen with its associated community facilities and local services. The
application site is within walking distance from the town centre. The strong
sustainable position of the Alternative Allocation should therefore be given full
consideration when considering potential future growth options.
2.2.3 In terms of planned growth, the proposed Alternative Site forms part of one of the 3
identified Principal Centres within the 2nd Deposit LDP Within these areas, the
majority of the County’s growth (particularly with regards to housing) is expected to
be accommodated within the Plan period. However, having undertaken a
comprehensive review of the proposed allocations put forward by the 2nd Deposit LDP
for the Principal Centre in question, it has been identified that a number have
significant questions over their ability to be delivered within the Plan period, including
the following:
Alternative Allocation Report April 2023
Land off Parc y Dleyn, Carmarthen
Ref. No. Site Name Units
PrC1/h4 Land off Parc y Delyn 17
PrC1/MU1 West Carmarthen 700
PrC1/MU2 Pibwrlwyd 247
SeC1/h4 Cae Canfas, Heol Llanelli, Pontyates 8
SuV4/h1 Adjacent Fron Heulog, Cynwyl Elfed 6
SuV12/h1 Adj. Gwyn Villa, Llanpumpsaint 20
Table 1
2.2.4 As a result of the above, separate objections have been made in relation to the above
allocations and it is therefore important that alternative more deliverable sites should
be identified, to ensure the Plan can be regarded as being ‘sound’.
Alternative Allocation Report April 2023
Land off Parc y Dleyn, Carmarthen

3.0 THE PROPOSAL
3.0.1 As part of the requirements for the promotion of sites for residential development, this
Statement is accompanied by a layout for the residential scheme that will be part of
the soon to be submitted planning application. The scheme has been full yworked up
and takes account of all the Site’s assets and constraints, as well as current Authority
design guidance. As a result, it demonstrates that the Site is capable of delivering 20
units in a deliverable and sustainable manner. The following information therefore
expands on this principle.
3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Alternative Allocation be allocated in the forthcoming
replacement LDP for the purposes of 20 residential units. As detailed above, the
accompanying layout (reproduced below) demonstrates that the site is capable of
accommodating this number in a deliverable and sustainable manner.
Plan C
3.1.2 As illustrated above, the site is capable of accommodating a mix of unit sizes and
types, with the associated density – 20 units – having therefore taken into
consideration this potential mix, as well as striking a balance of being reflective of the
Alternative Allocation Report April 2023
Land off Parc y Dleyn, Carmarthen
existing form and density of residential development in the immediate locality. The
positioning of the proposed units has also taken into account the topography of the
site.
3.1.3 With regards then to access, the Alternative Site will be served by a new point of
access via its western boundary, via Penlan Road where a new estate road is
proposed. All new units will then be positioned around a principle new adoptable
estate road with each dwelling gaining access either directly off this or via short
private shared drives. Each unit will then be served by generous private rear gardens,
with smaller grass forecourts to their front. New rear boundaries serving each unit will
then be defined by fencing or hedgerows.
3.1.4 In addition to the above, off-site improvements to the existing adjoining public
highway (Penlan Road), as set out in the accompanying Transport Statement, would
also be delivered as part of the development of the Alternative Allocation. This will
include localised road widening and new footways to improve access and pedestrian
linkage to the application site.
3.1.5 Any development would also give full regard to current biodiversity levels on the site
and so land has been included within the Alternative Allocation to satisfy the
recommendations of the accompanying ecological survey reports.
3.1.6 It is recognised and supported that an element of the proposed units would be
affordable in nature, with the level of provision forming part of the review of the
current LDP.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Any development of the Alternative Allocation for residential units would be served by
mains water, public sewer and electricity, connections to which we understand lie
within or in close proximity to the Site.
Alternative Allocation Report April 2023
Land off Parc y Dleyn, Carmarthen
3.2.2 With regards then to surface water, it is considered that as a result of on-site
features, there would be a number of options available to any development of the site
in terms of its disposal, ensuring its development adheres to current regulatory
requirements.
Alternative Allocation Report April 2023
Land off Parc y Dleyn, Carmarthen

4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 As detailed above, a series of ecological surveys of the Site have been undertaken
and have heavily influenced the form of the proposed development. Therefore, any
biodiversity assets the Site may include have been given full consideration with
regards to exploring its potential for residential development. This has included the
proposed retention and management of existing site boundary features, the creation
of new boundary features and areas for enhancement.
4.1.2 The Alternative Site has been assessed against data held on the “Magic” website
which details statutory and non-statutory National and Local sites of ecological
importance. Plan D below provides an extract of those records applied to the
Carmarthen locality. The red star denotes the position of the Alternative Site.
Plan D
4.1.3 As can be seen from the above, the Alternative Site does not form part of and neither
is it near any national or local designations. The nearest designation is the River Tywi
SSSI/SAC, but due to the intervening distance and topography, the development of
the Alternative Site will not have any detrimental impact on this feature.
Alternative Allocation Report April 2023
Land off Parc y Dleyn, Carmarthen
4.2 HISTORICAL ASSETS
4.2.1 Below is an extract from the ‘Archwilio’ website that represents a resource for the
Historic Environment Records of Wales, with the Alternative Site indicated by a red
star.
Plan E
4.2.2 As can be seen, neither the Alternative Allocation nor immediately adjoining element
of the settlement includes any Scheduled Ancient Monuments, Listed Buildings or
Conservation Area’s. As a result, the development of the Site would not have any
detrimental impact on the setting or interest of any nearby historical asset.
4.3 ENVIRONMENTAL CONSTRAINTS
4.3.1 The Candidate Site is not categorised as being at risk of flooding in terms of the
Development Advice Maps or those produced by Natural Resources Wales, as
illustrated by the plans below (Alternative Site indicated by the red star).
Alternative Allocation Report April 2023
Land off Parc y Dleyn, Carmarthen
Plan F
(Development Advice Maps)
Plan G
(Flood Maps for Planning)
4.3.2 Due to its greenfield nature, the Candidate Site has no ground contamination related
constraints.
Alternative Allocation Report April 2023
Land off Parc y Dleyn, Carmarthen

5.0 VIABILITY
5.0.1 As part of the preparation of any development plan, it is vital to ensure that
allocations within it are both viable and deliverable. To not make efforts to explore
both these aspects is to then risk that the Plan may be unsound and so in turn fail to
meet its own targets or objectives.
5.0.2 Although detailed viability appraisals are difficult to prepare at this stage of the Plan’s
preparation due to the absence of, for example, such things as full engineering
details, it is possible to undertake such appraisals at a strategic or in-principle level.
The following therefore represents such a process and is fit-for-purpose in providing
confidence with regards to both the viability and deliverability of the Candidate Site at
this stage, but it should be noted, that more detailed analysis at a planning
application stage may result in some variance.
5.1 VIABILITY APPRAISAL
5.1.1 The following provides an indication of the viability of delivering the proposed 20 units
on the Alternative Site in question. It is based very much on its greenfield status and
uses figures and costings previously accepted by the local authority through its
determination of planning applications and other works. The following appraisal is
therefore based on the assumptions set out below in order to provide a residual value
for the scheme, prior to ascertaining an indicative land value.
Costs
 Dwelling construction costs are based on £1,250 per metre (to allow for
ground levels).
 Adoptable road construction cost based on £1200 per metre
 Connections for all utilities include water, foul water and electric
 Developer’s Profit based on RICS guidelines (18%)
 Professional Fees include planning application fee, associated professional
fees, estate agency fees (1%) and LABC Warranty fee.
Alternative Allocation Report April 2023
Land off Parc y Dleyn, Carmarthen
Sales
 Sale Prices based on LPAs Affordable Housing SPG, market research and
ACG figures where relevant.
5.1.2 Using the above, the following represents a strategic viability appraisal for the
proposed 20 units, with 3 units being made available on an affordable basis (based
on 3 three bed units).
Costs Cost Per Unit/Metre No. Units/Metres Total
4 Bed Det. (145 sq m) 181259 13 2356367
3 Ded Det. (120sq m) 150000 7 1050000
Road Construction +
Off Site 100000
Utility Connections 5000 20 100000
Professional Fees - 113698
Sprinklers 3500 20 70000
Parks and Education
Cont. 5000 20 100000
Total 3890065
Sales
3 Bed Det. (120 sqm)
(Aff.) 78286 3 234858
3 Ded Det. (120sq m) 265000 3 795000
4 Bed Det. (145 sq m) 330000 14 4620000
Total 5649858
Developers Profit Total 1016974.44
Residual Land Value 742818.56
Table 2
5.1.3 Although the above figures have not been able to take into account any future
changes to construction costs as a result of other external factors (e.g. changes to
Building Regulations), it is considered that in-principle, the development of the site
would be financially viable.
Alternative Allocation Report April 2023
Land off Parc y Dleyn, Carmarthen

5.2 DELIVERABILITY
5.2.1 In terms of deliverability, it should be firstly noted, as illustrated above, that the site is
financially and physically viable, with no environmental, geo-physical or technical
constraints prohibiting immediate development. Furthermore, there are no ownership
or third-party interests preventing the Ssite’s delivery.
5.2.2 In terms of a delivery timescale, it is envisaged that the site could be capable of being
completed within 2 years from the adoption of the Replacement Local Development
Plan. Parc y Delyn and its immediate environs remains an attractive part of
Carmarthen given its panoramic views over the surrounding landscape and good
access to nearby schools, shops, services and community facilities.
Alternative Allocation Report April 2023
Land off Parc y Dleyn, Carmarthen

6.0 NATIONAL PLANNING POLICY CONSIDERATIONS
6.0.1 In the preparation of any development plan, consideration must be given to national
policy and guidance. At present, this takes the form of Planning Policy Wales (PPW)
(Edition 11) and a series of Technical Advice Notes (TAN) that deal with a range of
topic areas.
6.1 HOUSING SUPPLY
6.1.1 With regards to the provision of housing, Paragraph 4.2.2 of PPW gives the following
requirements the planning system must fulfil:
 Identify a supply of land to support the delivery of the housing requirement to
meet the differing needs of communities across all tenures;
 Enable the provision of a range of well designed, energy efficient, good quality
market and affordable housing that will contribute to the creations of sustainable
places; and
 Focus on the delivery of the identified housing requirement and the related land
supply
6.1.2 In addition to the above, Paragraph 4.2.10 of PPW states “the supply of land to meet
the housing requirement proposed in a development plan must be deliverable”. As
detailed previously, it is considered that the LPA has to date failed to accomplish this
requirement under the provisions of the current LDP and will continue to do so under
the provisions of the proposed allocations of the 2nd Deposit LDP.
6.1.3 In order therefore to re-dress this deficiency in provision, and provide a more robust
approach to housing provision through a mixed site-scale approach, there is an
urgent need to identify alternative deliverable housing allocations in the replacement
Plan. Based on the accompanying information, it is clear that the Alternative Site
represents one such example.
Alternative Allocation Report April 2023
Land off Parc y Dleyn, Carmarthen

7.0 CONCLUSION
7.1 Although currently undeveloped, the Alternative Site forms a logical extension to an
existing settlement, being well related to it and being positioned at a location within
the wider landscape to not form a prominent or logical part of the surrounding open
countryside.
7.2 In addition to the above, the site lies within close proximity and walking distance of
the existing community services and local facilities of the adjoining settlement, which
will ensure it makes a positive contribution to both national and local sustainable
development objectives.
7.3 From a wider sense, the Site will also benefit from well served excellent public
transport links to the adjoining larger town of Carmarthen, together with other
locations within and adjoining the County, further increasing the facilities and services
available to future residents of the Site via sustainable transport means.
7.4 In tandem to the above, the development of the Site will in turn ensure a viable and
so deliverable source of future housing for the Principal Centre is forms part of, which
has seen a dangerous level of under supply prior to and since the adoption of the
current LDP. The development of the Site will help to redress this imbalance and it is
strongly suggested that the Authority closely scrutinises those sites currently
allocated in the LDP in terms of their suitability and deliverability if it is to continue to
allocate them. National planning policy however would suggest that in view of the
uncertainty in relation to their delivery, such sites should not form part of the
replacement LDP.
7.5 With the Alternative Site having no access, ground condition, flood risk, hydrological,
ecological, archaeological or land ownership related constraints, its delivery if
allocated is assured. Combined therefore with its locational characteristics, the Site in
question represents a sustainable candidate for future housing development.
Alternative Allocation Report April 2023
Land off Parc y Dleyn, Carmarthen
7.6 In view of the above and information provided in this Statement, it is respectfully
requested that the Alternative Site in question be designated for residential
development.