Include site within the Plan

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Mr K Davies to prepare and
submit an Alternative Allocation Report for the allocation of land at Pludds Meadow,
Laugharne, 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 and Transport Statement, as well as a sustainability assessment undertaken
in-line with the Authority’s requirements.
Alternative Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne

2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Candidate Site relates to a parcel of land measuring approximately 2.8 acres in
area, edged red on the plan and image below.
Plan A
Photograph 1
Alternative Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne
2.1.2 The site currently consists of a level field that is currently laid to grass, as illustrated
by the photographs below.
Photograph 2 Photograph 3
2.1.3 All boundaries of the Site are currently well defined by existing features,
predominantly mature hedgerows. The exception to this is a post and wire fence
along its northern boundary, which it shares with an adjoining development
compound.
2.1.4 Access to the Site is currently obtained via the aforementioned compound and
adjoining enclosures to the south, also in our Client’s ownership. However, any new
access to serve the proposed development would be at the Site’s south western
corner in the manner indicated on the accompanying plans.
2.1.5 Under the provisions of the current Carmarthenshire LDP, the Site presently lies at
the south western edge of the defined Development Limits of the settlement of
Laugharne. 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
and is in effect positioned between two existing housing allocations in the settlement.
Alternative Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne
Plan B
2.1.6 As can be seen, the Alternative Site is therefore well related to the existing defined
Development Limits for Laugharne and the settlement’s built form as a whole when
existing residential development directly to its east, west and north 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 Laugharne. The existing built form and pattern of the settlement follows key access
routes, with then further development leading off those along roads such as the
adjoining development of Pludds Meadow.
2.2.2 Due to this position and close association with the existing built form, the Alternative
Site has excellent access to the range of community facilities and local services the
settlement of Laugharne has to to offer, with such facilities and services being within
walking distance of the site, as well as being accessible via regular bus services.
Such facilities and services include the following:
Alternative Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne
 Nursery
 Primary School
 Several Retail Units (A1 and A3)
 Several Public Houses (A3)
 Sports Clubs
 Several Places of Worship
 Community Hall
2.2.3 In addition to the above, the Alternative Site is also within a short distance and bus
journey from the nearby larger settlement and centre of Carmarthen, which includes a
wider range of community facilities and local services. 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, the proposed Alternative Site forms part of one of Service
Centre’s, as defined by the 2nd Deposit LDP, where second only to Principal Centres,
the Council expects a large portion of the planned growth in the County to take place
due to their sustainable attributes. In turn, the Service Centre then forms part of a
group of settlements defined as Cluster 6 in the Settlement Framework and having
undertaken a comprehensive review of the proposed allocations put forward by the
2nd Deposit LDP for the Cluster 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
SeC18/h1 Adjacent to Brittani Terrace, St Clears 60
SeC18/h3 Land adjacent to Cefn Maes, St Clears 100
SuV60/h1 Land at College Bach, Llangynog 6
SuV61/h1 Land at Nieuport Farm, Pendine 10
SuV63/h1 Land at Woodend, Llanmilow 28
Table 1
Alternative Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne
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 Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne

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 17 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 17 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
Alternative Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne
3.1.2 As illustrated above, the site is capable of accommodating a mix of unit sizes and
types, with the associated density – 17 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. The
positioning of the proposed units has also taken into account the topography of the
site.
3.1.3 With regards then to access, as detailed previously, the Alternative Allocation will be
served by a new access road leading from the existing public highway running
alongside its western boundary. This will then lead into the Site and be to full
adoptable standards.
3.1.4 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. For the purposes of the accompanying viability assessment however, it
is proposed that 2 of these units would be affordable in nature.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Any development of the Candidate 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 April 2023
Land adjacent to Pludds Meadow, Laugharne

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 site boundary
features.
4.1.2 The Alternative Allocation 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 Laugharne 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 adjacent to any national or local designations. The nearest designation is the
River Taf Estuary 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 adjacent to Pludds Meadow, Laugharne
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 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 adjacent to Pludds Meadow, Laugharne
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 adjacent to Pludds Meadow, Laugharne

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 17 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 Allocation Report April 2023
Land adjacent to Pludds Meadow, Laugharne
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 17 units, with 2 units being made available on an affordable basis (based
on 3 two bed units).
Costs
Cost Per
Unit/Metre
No.
Units/Metres Total
3 Bed semi(90 sqm) 103500 8 828000
3 bed bungalow (110sq m) 126500 4 506000
4 bed det. (160sq m) 184000 5 920000
Road Construction 1200 150 180000
Utility Connections 5000 17 85000
Professional Fees - 95718
Sprinklers 3500 17 59500
Parks and Education Cont. 5000 17 100000
Total 2774218
Sales
3 Bed semi(90 sqm) (Aff.) 78286 3 234858
3 Bed semi(90 sqm) 285000 5 1425000
3 bed bungalow (110sq m) 325000 4 1300000
4 bed det. (160sq m) 350000 5 1750000
Total 4709858
Developers Profit Total 847774.44
Residual Land Value 1087865.56
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 adjacent to Pludds Meadow, Laugharne
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 2-3 years from the adoption of the Replacement Local Development
Plan, as Laugharne 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 adjacent to Pludds Meadow, Laugharne

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 adjacent to Pludds Meadow, Laugharne

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 Cluster 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 adjacent to Pludds Meadow, Laugharne
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.

Amend the plan to include the site

1 Introduction

1.1 This Candidate Site submission document for the Second Deposit Revised Local Development Plan for Carmarthenshire has been prepared in order to accompany the candidate site form completed in respect of land at Station Road, St Clears, Carmarthenshire. It is submitted on behalf of Mr Wynne Walters and Mr John Walters.
1.2 The wider site was previously submitted for the First Deposit Revised LDP in 2018 (Ref: SR/150/023) but only the road frontage portion was included as a residential allocation (LPA Ref: Sec18/h5 – Land adjacent to Gwynfa, Station Road for a total of 8 units within the plan period). This allocation is carried forward in the Second Deposit Revised Local Development Plan. Notwithstanding this, it is considered that the wider area the subject of the initial submission is also suitable for residential development and, therefore this document concerns the resubmission of the wider site on the land at Station Road, St Clears for future residential development.
1.3 The site is situated in the community of St Clears and is bordered by the communities of Meidrim, Newchurch and Merthyr, Llangynog, Laugharne Township, Llanddowror, Eglwyscummin, Llanboidy, and Llangynin which all lie within Carmarthenshire.
1.4 This submission will demonstrate that if the site proposed were given permission to be developed, provisions would be incorporated which would seek to ensure a high quality of design and layout, including retention and enhancement of peripheral vegetation in order to create a high quality form of development.
1.5 The Carmarthenshire Local Development Plan Review Report identifies the status of site allocations within current LDP. Within the adopted LDP 2006 - 2021 there are 8 housing allocations within St Clears, of some have been started or completed, including the Maes yr Hufenfa development for Wales & West Housing Association on Station Road. The total allocation for these sites equates to 98 dwellings. In the event that these allocations are not developed, it is considered the candidate site will offer a solution for short-term housing development. In comparison to several speculative land bank application provided within the plan, the applicant wishes to sell the site to a potential developer in the summer in order for the site to provide new dwellings to serve the area in the short term.
1.6 In terms of the content of the submission Section 2 of this report provides a brief description of the site; Section 3 discusses the overall planning policy context; Section 4 assesses the site in the context of criteria identified in Planning Policy Wales. Section 5 provides a summary and conclusions.

2 Site Description

2.1 This section discusses the site’s general location and provides a brief description of the application site and its immediate surroundings.
2.2 St Clears is a community and small town situated in the unitary authority of Carmarthenshire. It is located approximately 13km to the west of the county town of Carmarthen and approximately 28km to the north-west of Llanelli. The B4299 (Station Road) runs in a north-south alignment along the eastern boundary of the site, providing access to Meidrim to the north and St Clears to the south. Within the current LDP St Clears is categorised as a service centre, which are “well located on sustainable transport corridors and demonstrate a broad range of facilities and services which provide for the needs of the settlement and a wider local catchment. Their respective status within the County and their regional contribution is reflected within the WSP.”
2.3 The irregular shaped piece of land is roughly 3.5 acres in area and is currently used for agricultural purposes and is subject to an annual grazing agreement. Having considered the site and its characteristics, it is considered the site would be suitable for the allocation of approximately 42 residential dwellings. There is an existing electricity pylon located within the site, adjacent to the southern boundary. Consideration will be given to this constraint as part of any development that were to take place on-site.
2.4 The site is bounded to the north by greenfield land and existing residential dwellings fronting onto Station Road, to the east by Station Road, to the south by residential dwellings within the Rhyd-Y-Gors Estate, and to the west by greenfield land. In addition, the site is bounded on all sides with hedgerow (more defined on some boundaries of the site than others) and a very small element of tree coverage within the north-western area of the site.
2.5 In terms of local facilities, the site is located approximately a 600m walking distance from St Clears Town Centre (as defined within Policies RT4, RT5, and RT6 of the adopted Local Development Plan) to the south on Pentre Road. There are several amenities within the town centre boundary, including takeaways, cafes, convenience stores, and public houses. Moreover, Ysgol Griffith Jones and St Clears Leisure Centre are located approximately 250m to the south-east and 360m to the south of the site respectively. There is also a Co-op Food store located approximately 320m to the north.
2.6 The closest bus stops to the site is placed along Station Road, approximately 170m to the south of the site, providing services in both northbound and southbound directions. Service 224 runs from these stops, once every two hours, linking with settlements including Whitland, Pwll-Trap and Tavernspite. Other bus stops are located on Pentre Road to the south where a greater range of services are provided, connecting St Clears with destinations across Carmarthenshire and Pembroekshire including Carmarthen, Tanerdy, Haverfordwest and Pendine.
2.7 Another benefit in terms of public transport which has arisen since the first submission of the site is the proposed reopening of St Clears train station. The station last operated in 1964, however recent attempts have been made to re-open the station which has gained traction since 2021 when the station was selected as one of four station re-opening bids to go through to the final stage. The station will be located along the West Wales line, situated between Carmarthen and Whitland stations and is proposed to open in 2024. This will be of great benefit to the settlement of St Clears, and lies only 300 metres from
the candidate site. It will further encourage residents to travel in a sustainable manner and reduce car dependence in the area.

3 Planning Policy Framework

Overview
3.1 The policy basis for this submission derives from the content and scope of national planning guidance. It is submitted that the residential land use proposed would be in accordance with national advice and guidance, its associated Technical Advice Notes (TANs), together with the Development Plan for the local area.
3.2 The Well-Being of Future Generations (Wales) Act 2015
The Well-Being of Future Generations Act requires public bodies in Wales to think about the long-term impact of their decisions, to work better with people, communities and each other, and to prevent persistent problems such as poverty, health inequalities and climate change. To make sure we are all working towards the same purpose, the Act puts in place seven well-being goals. The Act makes it clear the listed public bodies must work to achieve all of the goals, not just one or two.
The seven well-being goals include:
1. A prosperous Wales
2. A resilient Wales
3. A healthier Wales
4. A more equal Wales
5. A Wales of cohesive communities
6. A Wales of vibrant culture and Welsh Language
7. A globally responsible Wales
Future Wales – The National Plan 2040
3.3 Published on the 28th February 2021, Future Wales comprises the first development plan of its kind within Wales. It is a development plan with a strategy for addressing key national priorities through the planning system, including sustaining and developing a vibrant economy, achieving decarbonisation and climate- resilience, developing strong ecosystems and improving the health and well-being of our communities. The National Plan notes that the planning system must respond to these changes and contribute to a sustainable recovery, shaping places around a vision for healthy and resilient places. The strategy blends the existing settlement patterns and the distribution of jobs and homes with a vision of managing change and future trends for the benefit of everyone in Wales. Planning Policy Wales is the primary source of detail on how the planning system will support reconstruction efforts.
3.4 Future Wales is the highest tier of development plan and is focused on solutions to issues and challenges at a national scale. Due to its strategic nature, it does not allocate development to all parts of Wales, nor does it include policies on all land uses. It is a framework which will be built on by Strategic Development Plans at regional level and Local Development Plans at local authority level. As set out on Page 52 of Future Wales, the 11 Outcomes are collectively a statement of where the Welsh Government aspire Wales to be in 20 years` time as follows:
A Wales where people live:
1. …and work in connected, inclusive and healthy places
2. …in vibrant rural places with access to homes, jobs and services
3. …in distinctive regions that tackle health and socio-economic inequality through sustainable growth
4. …in places with a thriving Welsh Language
5. …and work in towns and cities which are a focus and springboard for sustainable growth
6. …in places where prosperity, innovation and culture are promoted
7. …in places where travel is sustainable
8. …in places with world-class digital infrastructure
9….in places that sustainably manage their natural resources and reduce pollution
10. …in places with biodiverse, resilient and connected ecosystems
11. …in places which are decarbonised and climate-resilient
3.5 Page 60 notes that “In all parts of Wales the strategy supports sustainable growth. Any place without jobs, homes, community spaces and wildlife has no prospect of having a thriving and cohesive community, Welsh language or economy. There is such a thing as too much development or the wrong type of development, whereas sustainable development should foster a stable or growing population to ensure a healthy natural environment and economic and social stability”.
Planning Policy Wales
3.6 National planning policy is contained within the eleventh edition of Planning Policy Wales (PPW), published by the Welsh Government in February 2021. It is the principal document for planning considerations in Wales. PPW provides land use planning policy and should be taken into account when preparing planning applications. It is supplemented by a series of Technical Advice Notes (TANs), Welsh Government Circulars, and policy clarification letters, which together with PPW provide the national planning policy framework for Wales. The planning system is central to achieving sustainable development in Wales. It provides the legislative and policy framework to manage the use and development of land in the public interest which is consistent with key sustainability principles.
3.7 Sustainable Development is defined at Page 7 of PPW as follows: “the process of improving the economic, social, environmental and cultural well-being of Wales by taking action, in accordance with the sustainable development principle, aimed at achieving the well-being goals”. Paragraph 1.18 sets out that “legislation secures a presumption in favour of sustainable development in accordance with the development plan unless material considerations indicate otherwise to ensure that social, economic, cultural and environmental issues are balanced and integrated”. Paragraph 1.18 of PPW relates to sustainability which emphasises that the planning system should provide for a presumption in favour of sustainable development to ensure that social, economic and environmental issues are balanced and integrated (Para 4.2.2). In Paragraph 2.3 it goes on to state that “The planning system should create sustainable places which are attractive, sociable, accessible, active, secure, welcoming, healthy and friendly. Development proposals should create the conditions to bring people together, making them want to live, work and play in areas with a sense of place and well-being, creating prosperity for all.”
3.8 The Well-being of Future Generations (Wales) Act 2015 is brought up in PPW, which places a duty on public bodies (including Welsh Ministers) to carry out sustainable development. In carrying out this duty, actions which public bodies must take include:
 setting and publishing objectives (“well-being objectives”) that are designed to maximise its contribution to achieving each of the well-being goals; and
 taking all reasonable steps (in exercising its functions) to meet those objectives.
3.9 The Act puts in place seven well-being goals to help ensure that public bodies are all working towards the same vision of a sustainable Wales. These include the need for cohesive communities which are attractive, viable, safe and well-connected.
3.10 In addition, sustainable development should be achieved through the design which is described in Paragraph 3.3: “Good design is fundamental to creating sustainable places where people want to live, work and socialise. Design is not just about the architecture of a building but the relationship between all elements of the natural and built environment and between people and places. To achieve sustainable development, design must go beyond aesthetics and include the social, economic, environmental, cultural aspects of the development, including how space is used, how buildings and the public realm support this use, as well as its construction, operation, management, and its relationship with the surrounding area.”
3.11 In terms of housing, Paragraph 4.2.1 notes the following: “Planning authorities must understand
all aspects of the housing market in their areas, which will include the requirement, supply and delivery
of housing. This will allow planning authorities to develop evidence-based market and affordable housing policies in their development plans and make informed development management decisions that focus on the creation and enhancement of Sustainable Places. New housing development in both urban and rural areas should incorporate a mix of market and affordable house types, tenures and sizes to cater for the range of identified housing needs and contribute to the development of sustainable and cohesive communities”. In relation to housing, PPW states that the planning system ought to:
“recognise a supply of land to assist the delivery of the housing needs to meet the varying requirements of communities across all tenures; offer provision of a spread of well-designed, energy efficient, high quality market and affordable dwellings that contribute towards the formation of sustainable settings; and concentrate on delivery of the recognised housing requirement and associated land supply”.
Carmarthenshire Local Development Plan
3.12 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires that planning application decisions should be made in accordance with the development plan unless material considerations indicate otherwise. The statutory development plan for this site is provided by Carmarthenshire Local Development Plan (LDP) 2006 – 2021 which was adopted by the County Council in December 2014.
3.13 The site is not allocated for development in the Adopted Plan, lying just beyond the settlement limits of St Clears, but should be considered through the review process as it lies within close proximity of facilities in the Sustainable Settlement of St Clears and is well related to the existing settlement pattern (as infill development).
3.14 The Carmarthenshire Local Development Plan Review will be required to make provision for future housing needs with an extended Plan Period to 2033, including those of individual settlements in accommodating necessary levels of growth to maintain communities and facilities. Within the current Second Deposit Revised Local Development Plan, the road frontage portion of the site is included as a residential allocation (LPA Ref: Sec18/h5 – Land adjacent to Gwynfa, Station Road for a total of 8 units within the plan period).
3.15 The following section will seek to establish that national planning guidance is broadly supportive of residential development taking place on the site. In these circumstances, therefore, it is submitted that these aspects should be taken into account when assessing the site through the LDP review site selection process.

4 Appraisal

4.1 This section examines how the submission site accords with prevailing planning policy in terms of identifying housing land allocations within development plans.
Availability of Previously Developed Land
4.2 The site is not brownfield land but is well-connected to the current settlement pattern of St Clears and its development for residential purposes represents a logical area for development and inclusion within the settlement boundary, at this location. As previously noted, Ysgol Griffith Jones and St Clears Leisure Centre lie circa 250m to the south-east and 360m to the south of the site respectively. In addition to this, a Co-op Food store lies roughly 320m to the north. These facilities being within walking distance underline the sustainable credentials of the site.
4.3 In order to achieve a sufficient range and choice of housing land opportunities, there will be a need to consider sites which represent viable urban extensions, especially those which could contribute to the Council’s housing land supply over a long period extending to 2033. This site can offer up to 42 residential units, and should therefore be seen as making an important contribution to land supply.
Accessibility
4.4 There is an existing gated access found along the eastern boundary of the site (roughly in a central position along the eastern boundary), fronting onto Station Road. The location of the existing gate would be considered to be the most appropriate point of access for any future development.
4.5 Station Road, within the vicinity of the candidate site, has a speed limit of 30mph which would require visibility splays of 43m in both directions from the site access. This would be achievable, however, an element of the hedgerow may need to be cut back to allow the visibility to be maintained. A drawing based on Ordnance Survey/Topographical based survey data will be able to definitively confirm that visibility is achievable at this access location.
4.6 As already discussed, there a number of facilities within close proximity of the site, including a number of amenities within the defined boundary of St Clears Town Centre. There is also a school and food store located within close proximity of the site on Station Road. The site also benefits from good access to public transport routes with bus stops located on Station Road and Pentre Road providing good connections with nearby towns/settlements, including Carmarthen. In addition to this, the proposed St Clears train station is within walking distance of the site and would enable users to travel to a host of destinations across South Wales including Milford Haven, Carmarthen, Swansea and Cardiff.
4.7 In terms of pedestrian infrastructure, there are already existing footways located along Station Road (on both sides of the carriageway) along the eastern side of the site. This will benefit any future residents that may occupy the site if built for the purposes of residential development.
Land Ownership
4.8 The land to which this Candidate Site Representation refers is within the joint-ownership of the Site Promoter – Mr Wynne Walters and Mr John Walters. Both landowners are fully committed to bringing forward the development of the site. As previously mentioned, both individuals are keen to sell site to a developer in the coming months and have had keen interest from regional developers who are interested in progressing the site towards development to meet the housing need of St Clears. This will help make
up for the fact that some of the housing allocation within the current plan for St Clears have not started or been completed.
Capacity of Infrastructure
Utilities
4.9 All utilities are readily available within the proximity of the site and discussions are underway with relevant utility providers to extend utility infrastructure as required. In addition, as the detailed design of the proposed development progresses, the provision of electric-charging on a plot-by-plot basis will be considered further.
Drainage
4.10 The site is not affected by a flood risk area (which would prevent vulnerable forms of development such as housing), and it is considered that foul surface water will connect with the existing mains sewer.
Access
4.11 Achieving sufficient widths and visibility at the site’s proposed access point would be achievable if an extent of the existing hedgerow were to be cut back. A detailed drawing on Ordnance Survey/Topographical survey data will provide clarity. The development will provide the necessary pedestrian and cyclist infrastructure within the site to encourage residents to walk and cycle, with 2m wide footways included on one or both sides of the carriageway for its entire length and, where appropriate, shared use private drives also included, prioritising the needs of pedestrians and cyclists over that of vehicles.
Impact on the Community/Welsh Language
4.12 A scheme at this location will provide a range and choice of house types and tenures, including affordable elements. It is not considered that the development of the site for housing will have any significant adverse impact upon the Welsh language or any local communities. Ysgol Griffith Jones is a bilingual primary school that has both Welsh and English streams, therefore the development of the site for residential purposes could lead to increased numbers of Welsh students at the school.
Physical and Environmental Constraints
Ecology
4.13 With the retention and enhancement of existing vegetation, there are considered to be no likely significant ecological issues conflicting with planning policy at any level and there are minimal legislative considerations as a result of potential impacts to legally protected species.
Visual Impact
4.14 Overall it is considered that the proposal would not have any significant adverse impact upon the visual amenities of the area. Separation distances, to prevent any adverse or overbearing impacts, between proposed dwellings and existing dwellings can easily be provided.
Coalescence of settlements
4.15 Development on the site would not result in the coalescence of settlements. Development of the site would result in a marginal extension of St Clears development limits, which makes sense as there is already existing development to the north, east and south. It would form a natural inclusion within the development limits of St Clears.
Flood Risk
4.16 The site is not identified in the TAN 15 Development Advice Maps as being at risk from flooding.
Site Contamination
4.17 In terms of ground conditions there are no known constraints that prevent the development of the site for residential uses.
Compatibility with Neighbouring Uses
4.18 It is anticipated that all of the proposed dwellings would respond well to the established character of the surrounding area. It is anticipated that a range of dwelling types and sizes would be incorporated ranging from 2 beds up to 5 beds which forms the basis for interesting street scenes and helps establish a balanced community. Overall it is considered that the proposal would not have any significant adverse impact upon the residential amenities of existing or future occupiers.
The Potential to reduce carbon emissions through co-location with other uses
4.19 The site is proposed for residential uses. However, an increase in population generated will allow help sustain local facilities and potentially increase demand for additional services to benefit the local community.
Relationship with Historic Environment
4.20 The site is not located within or adjacent to the boundary of a Conservation Area. In addition, there are no historic assets within or adjacent to the site (including Scheduled Ancient Monuments; Listed Buildings; and Registered Historic Park or Garden).
Delivery of Key Placemaking Objectives
4.21 Placemaking is at the heart of both ‘Future Wales’ and Planning Policy Wales (Edition 11, February 2021). As set out at Section 3 of ‘Future Wales’: “Future Wales’ Outcomes are overarching ambitions based on the national planning principles and national sustainable placemaking outcomes set out in Planning Policy Wales”. Preliminary investigations have identified that the candidate site can provide homes in the right place and create a sustainable, well-designed, and high-quality housing scheme, where people will want to live, in accordance with national placemaking objectives.

Conclusion

5.1 This Candidate Site representation is made by Asbri Planning Limited on behalf of Mr Wynne Walters and Mr John Walters and requests that land at Station Road, St Clears is brought forward as a housing land use allocation through the Carmarthenshire County Council Second Deposit Revised Local Development Plan 2018 - 2033.

5.2 Within the First Revised Deposit LDP, the site frontage (referred to as ‘Land adjacent to Gwynfa, Station Road) was allocated for residential use under Sec18.h5 for a total of 8 units within the Plan period.

5.3 Within the Second Revised Deposit LDP, the site continues to be identified as a housing allocation under Sec18.h5.

5.4 As per the representation submitted to the First Revised Deposit LDP, the wider site’s partial inclusion as a housing allocation in the Second Revised Deposit LDP is supported, and in particular the acceptance of the residential component of the allocation.

5.5 In summary, of Mr Wynne Walters and Mr John Walters continue to support the Second Deposit Revised Plan on the basis that the Council have accepted the principle of residential uses at the scale proposed, but would respectfully suggest that the wider site is also acceptable as an appropriate residential allocation to ensure the comprehensive redevelopment of the wider site.

5.6 The allocation of the wider site would be required to assist in ensuring the adequate delivery of housing in the sustainable community of St Clears, which may not be achieved by the current housing land allocations which are slow to come forward. The scale and nature of this site would be attractive to house builders, which would facilitate delivery in the short to medium term. The site promoters are keen to sell the land in the near future in order for work to commence on the site as soon as possible.

5.7 The site could potentially deliver a possible further 42 dwellings of various types and sizes which could be phased as appropriate and which would complement the existing form of the settlement. It will not give rise to any significant adverse impacts upon the character of the area, local amenities, residential amenity and highway safety whilst providing a significant contribution to the area’s housing land supply requirements as well as affordable housing. Furthermore, it is positioned in a sustainable location where several amenities lie nearby, and there are adequate public transport connections on offer.

5.9 This submission has assessed the site against prevailing planning policy in Wales. It is clear that the proposals are compatible with the relevant criteria. It is acknowledged that proposals will need to be refined on the basis of further comprehensive study information.
5.9 In light of the above, it is, therefore considered that Carmarthenshire County Council should, in its review of the Local Development Plan, identify the wider land at Station Road, St Clears as a larger housing land use allocation.

Include site within the Plan

1. Introduction
We would like to include a field next to the boundary of St Clears in the new Local
Development Plan. The field is positioned on the main road between St Clears to
Pwll-Trap on a bit of an incline. The site lies opposite the development of Cefn Maes.
And next to a large dwelling “Hillston”. This parcel of land has got a long planning
history.
Grid references: SN 27554 16561

2. Site Appraisal
This candidate site consists of an unused field. If has last been used for grassing
and crop in 1995.
It lies on the western side St Clears and to north of the A40. It is fairly of the road
and of the ground. It is about 47m deep and about 112 m long. About 5 arc side.

3. Access
There is an existing access can be found on the eastern side of the land (closer to
the town center) to the site from the main road between St Clears to Pwll-Trap.
The access profits from good visibility in both direction as well as 30 miles speed
limit. Additionally, the road has got street lighting all along the site.
The existing bus stop in front of the site will not have any negative effect on the
access.

4. Flooding
The site lies well above the water level and outside the flood area of St Clears, which
covers a big area of town of St Clears. Quite a lot of new development have been
constructed along Ostrey Hill above the flood plain of the town.

5. Pollution
The land is currently a greenfield site which nobody has used since the 1995 when it
had been rented out to a friend.
No evidence can be found of any past development.

6. Main services
All services: mains water supply, mains sewer connection, 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.

7.Proposal
A residential development for about 5 dwellings to allow for a good size garden. This
could be achieved by a single access lane or individual drives of the main road like
on the opposite side of the road.

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

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

10. 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 lies just outside the settlement limits of St Clears. The existing
boundary lines of the LDP are stopping short of this field.
To the East of the site is a big single dwelling. A sizable new housing estate can be
found on the other side of the road which runs along the hole length of this field.
 General hospital, in Carmarthen
 Privat hospital, Bancyfelin about 3 miles
 Secondary school would be in Whitland and Carmarthen, either 5 miles to
Whitland and 9/10 miles to the two secondary schools in Carmarthen. A
school bus goes into both directions from St Clears.
 Primary school can be found in the town itself
 Leisure centers, 2 miles in the town
 GP surgery is about a mile away
 Various pubs and restaurants are in town in close distance
 Various shops, petrol stations, pharmacy and all necessary amenities can be
found in very close proximity.

13. Transport links
The transport links to Carmarthen, Haverfordwest and Cardigan are well established
and developed.
 There is no train station in the town at the moment but there has been
ongoing discussion for reinstating one. At the moment the nearest one can be
found in Carmarthen, 9.4 miles
 there are various bus lines running from St Clears and a bus stop just in front
of the site
 Carmarthen town 9 miles
 Whitland about 4 miles
 About half a mile to the dual carriage way A40
 M4 is reached in about 24 miles

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.

A new development would infill an area which is party developed. Additionally, it
would make advantage of an area above the flood area of the town.
The site is fairly large but it should not be overdeveloped and restricted to protect
and enhance existing vegetation into a new layout.
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.
Not to forget the future need for new residential development when the new hospital
will get the go ahead further to the West, Whitland or Narbeth. Both are smaller
towns and one can see the need for new housing in a bigger town which is close by.
We believe that this is an ideal please for a new development.

Include Candidate Site SR/080/002 within the Revised Local Development 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/080/002, seeking the allocation of their and adjoining land for future residential
development within the defined settlement limits of Llandeilo as part of the Replacement
Local Development Plan. The Candidate Site is edged red below in Plan A.

Plan A

The Candidate Site comprised of a single enclosure, with its south western boundary
fronting onto the adjoining public highway, from which access to it was gained. Its remaining
boundaries were as equally well defined through a combination of existing woodland belts
and residential properties.

Following its due consideration, the Council then excluded the Site from the proposed
development limits for Ffairfach 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:

““Development would lead to an illogical extension of the urban form. The Site will remain
outside of limits. There is sufficient residential land allocated in the settlement. The position
with DCWW WWTW at Ffairfach is a consideration.”

At the time of publication of the 1st Deposit LDP therefore, the Council presented three
separate reasons for justifying its exclusion, although no further detail or explanation than
the above statement was provided.

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:

“Development would lead to an illogical extension of the urban form. The Site will remain
outside of limits. There is sufficient residential land allocated in the settlement. The position
with DCWW WWTW at Ffairfach is a consideration.”

As can be seen, the rationale of the Council for the exclusion of the Site as an allocation in
the LDP has remained the same. This is somewhat puzzling and illogical and for the reasons
set out below, puts the soundness of the Plan into question.

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 therefore 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)

Response to Council’s Reasons for Non-Allocation of Site
Sufficient Residential Land Allocated Within Settlement
Under the provisions of the 2nd Deposit LDP, Llandeilo in conjunction with Ffairfach and
Rhosmaen is defined as a Service Centre, representing the largest and most sustainable
settlement in Cluster 5 of the Settlement Framework. Despite this, and the fact that the
Council’s objective through the Plan is to channel most development to these settlements,
the current 2nd Deposit LDP has only allocated land for the provision of 27 new homes during
the Plan period for the Service Centre. To therefore suggest that there is ‘sufficient
residential land’ within the settlement to meet its community’s needs and satisfy the strategic
policies of the Plan is incredulous and for the Council’s proposals to remain unchanged
would result in the Plan being ‘unsound’.

In turn, the Service Centre then forms part of a group of settlements defined as Cluster 5 in
the Settlement Framework, with the table below providing an indication of the proposed
allocations in the 2nd Deposit LDP for the cluster.

Ref. No. Site Name Units
SeC15/h1 Land to north of Dan y Crug, Llandovery 61
SeC15/h2 Land adjacent to Bryndeilog, Tywi Avenue, Llandovery 8
SeC16/h1 Llandeilo Northern Quarter, Llandeilo 27
SeC17/h1 Land opp. Llangadog C.P School, Llangadog 16
SeC17/h3 Ger yr Ysgol, Llangadog 21
SuV49/h1 Ael y Mynyd, Llanfynydd 13
SuV51/h1 Opp. Village Hall, Cwmifor

Table 1

The above provides a worrying picture with regard to housing supply in the Cluster in
question. Despite being the largest and most sustainable Service Centre of Cluster 5,
Llandeilo/Rhosmaen/Ffairfach has a far lower level than the smaller settlement of Llandovery
and less than half the number allocated for Llangadog, despite the settlement being half the
size of Llandeilo.

The above is even more worrying when the deliverability, or the ability to deliver the
assigned number of units of some of the above allocations are in serious question
(SeC17/h1 and SuV51/h1), as well as some sites despite being allocated for over 30 years,
still having not delivered as single unit (SeC15/h1)

As a result of the above, separate objections have been made in relation to a number of the
aforementioned allocations and it is therefore important that alternative more deliverable
sites should be identified, to ensure the Plan can be regarded as being ‘sound’ in targeting
new housing development at the most sustainable location.
Development would lead to an unacceptable extension of the Urban Form.

The second reason given by the Authority for not allocating the Candidate Site was on the
basis that in its view it would “… lead to an illogical extension fo the urban form.”.

As the accompanying Candidate Site Supporting Statement highlights, the Candidate Site is
in fact well related to the existing settlement of Llandeilo. This is best apprecaited from an
aerial photograph (see below), which illustrates the close proximity of the site (edged red) to
existing residential and commercial development.

Photograph 1

It is in fact almost surrounded by existing non-agricultural land uses and so forms a logical
extension and addition to the wider urban form. From an accessibility perspective, the site is
within short walking distance of a number of the Town’s community facilities and local
services, as well as well served bus stops. The allocation of the Candidate Site would not
only represent a logical addition to the existing urban form, but would also represent a
sustainable form of development.
The position with DCWWWWTW at Ffairfach is a consideration.”

The final reasoning given by the Council then relates to the waste treatment plant at
Ffairfach, although it has not included this statement in any of its other response to its
assessment of Candidate Sites in the Service Centre. No explanation to date has been given
as to why.

Notwithstanding the above, we understand that provided all foul water leaving a
development from Llandeilo meets the phosphate regulations of Natural Resource Wales,
the WWTW in question will be able to accommodate such additional flows. The Site subject
of this submission is capable of providing such on-site infrastructure and the proposed 5
units, due to its size. This ratio has been based on other worked up examples and so the
third reason cited by the Council for excluding the Site is both illogical and erroneous

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 Candidate Site reference SR/080/013 within the Revised Local Development 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 Client made a formal Candidate Site Submission in August 2018, which was referenced
SR/080/013, seeking the allocation of their land for residential development within the
defined settlement limits of Llandeilo as part of the Replacement Local Development Plan.
The Candidate Site (edged red below) comprised of several parcels of land, with the eastern
half of the Site in the ownership of Carmarthenshire County Council and the western half in
the ownership of our Clients.

Plan A

As illustrated above, the Candidate Site comprised of three enclosures, each of lowmoderate
value in terms agriculture, and with all being well defined by a mix of hedgerows
and stock proof fencing. The westernmost enclosure (owned by the Council) is steeply
sloping, with the remaining two enclosures being more level in nature. The site as a whole is
then bounded by the existing urban form of Llandeilo to its south and west, with further
enclosures to its east and the Llandeilo Northern Bypass located a short distance to the
north. Due to the site’s location, it is within a short walk from a wide range of community
facilities and local services found within the Town.
It should be noted, that consultation has already begun on a comprehensive scheme for the
development of the majority of the Site by Pobl Housing Group, based on the site layout
drawing reproduced below, delivering 88 new units.

Plan B

The proposed development includes provision for addressing the phosphate regulations
published by Natural Resources Wales with regards to the disposal of foul water, ensuring
that the scheme is fully deliverable.
Notwithstanding the above, following its due consideration of submissions made at the
Candidate Site Stage, the Council then allocated part of the Candidate Site for residential
development in its 1st Deposit LDP, published in January 2020 (Plan C).

Plan C

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

“There are concerns over the deliverability of the site. The site has been allocated for
housing for a number of years and has not been developed. Allocation to be reduced in size
to the area covered by candidate site SR/080/005 with reference SeC16/h1; the remainder
to be excluded from development limits.”

At the time of publication of the 1st Deposit LDP therefore, the Council’s concerns related to
concerns over the deliverability of the much larger allocation the Candidate Site formed part
of, and so reduced it to the area of land owned by the Council.

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:

“There are concerns over the deliverability of the site. The site has been allocated for
housing for a number of years and has not been developed. Allocation to be reduced in size
to the area covered by candidate site SR/080/005 with reference SeC16/h1; the remainder
to be excluded from development limits.”

As can be seen, the rationale of the Council for the exclusion of our Clients land from the
allocation in the LDP has remained the same. However, it is somewhat illogical and puzzling
for the Council to be citing ‘deliverability’ as the justification for its decision. In fact, and in
contrast, the Council have failed to sell or develop its own element of the Candidate Site for
a considerable time now, due to unreasonable land value aspirations and construction-cost
challenges due to its topography. However – as can be seen from the current scheme in
preparation for the wider site – when the land is looked at in combination, a scheme for the
larger area then becomes deliverable. As a result, without our Clients land, the proposed
allocation will be undeliverable and fail to provide the number of new housing units it is
expected to do so, resulting in turn in the Plan being ‘unsound’.

The Council’s decision is therefore 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 Cluster and
wider Plan area.
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 Integrated Sustainability Appraisal form
- Copy of Candidate Site Submission Report (August 2018)
- Copy of Transport Statement

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 residential development 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 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/159/007, seeking the allocation of their land (edged red on Plan A) for a mix
of residential development, areas of formal and informal amenity space, habitat
enhancement areas, as well as improvements to local pedestrian and cycle link provision
and linkages, as part of the Replacement Local Development Plan.

Plan A

The Site would serve the settlement of Tycroes 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 off the access estate road shared with a recently
constructed residential development to its north east, although multiple pedestrian and cycle
linkages would also be available along all boundaries of the site. Locationally, the site is also
within close proximity to the range of community facilities and local services the settlement
and surrounding area has to offer.

Following its due consideration, the Council then excluded undeveloped element of the Site
from the proposed development limits for Tycroes 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 in its entirety would have a detrimental impact upon the character and
setting of the settlement and would exceed identified housing need. In considering smaller
areas of the site for inclusion it is concluded that there is sufficient and more suitable land
available elsewhere in Tycroes to meet its housing needs.”

The above decision was somewhat puzzling and in our view erroneous, particularly as
alternative allocations within the settlement and wider growth area were clearly neither
appropriate nor deliverable. In addition, the assessment also clearly failed to take into
account the mix of proposed uses, that reflected the immediate and wider landscape setting.

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:

“Inclusion of the site in its entirety would have a detrimental impact upon the character and
setting of the settlement and would exceed identified housing need. In considering smaller
areas of the site for inclusion it is concluded that there is sufficient and more suitable land
available elsewhere in Tycroes to meet its housing needs.”

As can be seen, the rationale presented by the Council replicates that at the 1st Deposit LDP
stage (impact on character and housing land supply), although when examined fully (see
below), they appear both illogical and erroneous. 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 Appraisals
- Transport Statement
- Indicative Master Plan

Response to Council’s Reasons for Non-Allocation of Site
Detrimental impact upon the character and setting of the Settlement
The first part of the Council’s rationale for the Site’s exclusion relates to the Council’s
perception that its development for the proposed mix of uses would lead to a “… detrimental
impact upon the character and setting of the settlement.”.
However, beyond this statement,
the Council has provided no further explanation of what ‘detriment’ would occur and to which
elements of the settlements “… character and setting…”.
As the originally submitted supporting information (copy enclosed) illustrates, the Strategic
Alternative Site does not form part of nor does it adjoin any designated Conservation Area.
In fact, the nearest (Llandeilo) is located a considerable distance to the north. Furthermore,
the Site does not contain nor is it within sight of any Listed Building or Ancient Monument. In
summary therefore, the allocation of the Site for the proposed mix of uses, would not have
any detrimental impact on the character or setting of any nearby historic interest.

From a landscape designation perspective, the Alternative Strategic Site does not form part
of a National Park or Area of Outstanding Beauty. On a more local level, the current LDP
has not defined any part of the Site or surrounding area as part of a Special Landscape
Area. The allocation of the Site for the proposed mix of uses, would not therefore have any
detrimental impact on the character or setting of any national or local landscape designation.

In terms then of the physical form of the adjoining settlement of Tycroes, its historic evolution
has followed the principal access routes to, through and within it, with later more recent
development then taking place in a more ‘in-depth’ manner of these routes. To suggest then
that the development of the relevant elements of the Strategic Alternative Site would be
counter – and so detrimental – to this existing setting and character is illogical. The proposed
pattern would in fact mirror and compliment the existing pattern of the adjoining settlement
and the erroneous inconsistent decision to exclude the Site by the Council is in itself grounds
to highlight that the 2nd Deposit LDP is unsound.
Sufficient Residential Land Allocated Within Settlement
The second 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 Tycroes 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.

Amend Plan to include the site

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Mr J Morris to prepare and submit
an Alternative Allocation Report for the allocation of land adjoining Waunfarlais Road,
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/082/002), but the Council
determined to exclude the Site for the following reasons:
“Development of the site would result in a ribbon pattern of development contrary to
general planning principles. Furthermore, the access roads to the site falls within the
C2 flood zone as identified in the TAN15 Development Advice Maps.”
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 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 (submitted at the Candidate Site
Stage), as well as a sustainability assessment undertaken in-line with the Authority’s
requirements.
Alternative Allocation Report April 2023
Land off Waunfarlais Road, Llandybie

2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Alternative Site relates to land measuring approximately 1.1ha in area in total,
edged red on the plan and the photograph below.
Plan A
Photograph 1
Alternative Allocation Report April 2023
Land off Waunfarlais Road, Llandybie
2.1.2 As can be seen from the aerial photograph above and the accompanying information,
the Alternative Site consists of two parcels of semi-improved grassland, each strongly
defined by mature hedge lines and trees. In terms of topography, the sites slopes
gently downwards in its southern portion, leading then to its more level element in its
northern half.
2.1.3 Access to the site is currently gained via an existing farm entrance lane (Photograph
2), but any future development of the Site would gain access directly off Waunfarlais
Road, which runs along the Site’s eastern boundary.
Photograph 2
2.1.4 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 Llandybie.
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 the
existing development limits extending along its frontage on the opposite side of the
road to the east, and beyond to the south.
Alternative Allocation Report April 2023
Land off Waunfarlais Road, Llandybie
Plan B
2.1.5 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 north west 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 Waunfarlais Road, Llandybie
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 nearest of which to the Alternative Site is at the junction of
Waunfarlais Road/McKays with Bonllwyn Road to the east. 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 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
Land off Waunfarlais Road, Llandybie
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 April 2023
Land off Waunfarlais Road, Llandybie

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 7 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 7 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
Alternative Allocation Report April 2023
Land off Waunfarlais Road, Llandybie
3.1.2 As illustrated above, the site is potentially capable of accommodating a mix of unit
sizes and types, with the associated density – 7 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 a single point of access serving a short section of adopted highway. From this
then would be further private shared drives as required.
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 April 2023
Land off Waunfarlais Road, Llandybie

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 Waunfarlais Road, Llandybie
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 As detailed above, in their assessment of the Site at the Candidate Site Stage, the
Council justified its exclusion of the Site as a housing allocation, in part, due to in its
view “…the access roads to the site falls within the C2 flood zone as identified in the
TAN15 Development Advice Maps.”. Below therefore are extracts of the current
Development Advice Maps or those produced by Natural Resources Wales, with the
Alternative Site edged red.
Alternative Allocation Report April 2023
Land off Waunfarlais Road, Llandybie
Plan F
(Development Advice Maps)
Plan G
(Flood Maps for Planning)
4.3.2 Based on the above plans, the Council’s stance is somewhat confusing. As can be
seen, no element of the Site – access road or otherwise – lies within any defined
flood risk zone in terms of either the DAM or the Flood maps for Planning. On this
Alternative Allocation Report April 2023
Land off Waunfarlais Road, Llandybie
basis alone, the Council’s assessment of the site is erroneous and quite clearly
inconsistent when compared with other allocations it has put forward for the
settlement (e.g. PrC3/h21 – Maespiode). In summary, flood risk would not prevent
the delivery of the Alternative Site.
4.3.3 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 Waunfarlais Road, Llandybie

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 (200 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 April 2023
Land off Waunfarlais Road, Llandybie
 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 7 units, based on an affordable housing level being a financial contribution
of £41.98 per square metre of internal floorspace.
Costs Cost Per Unit/Metre No. Units/Metres Total
5 Bed semi (200
sqm) 270000 7 1890000
Utility Connections 5000 7 35000
Road and Access 1200 50 60000
Professional Fees - 55020
Sprinklers 3500 7 24500
Affordable Hsng.
Cont. 58772
Parks and
Education Cont. 5000 7 100000
Total 2223292
Sales
5 Bed semi(200
sqm) 500000 7 3500000
Total 3500000
Developers Profit Total 630000
Residual Land Value 646708
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 Waunfarlais Road, Llandybie
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 Waunfarlais Road, Llandybie

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 Waunfarlais Road, Llandybie

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. Its inclusion within the development limits would also represent a logical
rounding off of the current built form, providing a defensible boundary with respect to
the surrounding open countryside beyond the Alternative Site.
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 Waunfarlais Road, Llandybie
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 site within 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/080/007, seeking the allocation of their and adjoining land for future residential
development within the defined settlement limits of Ffairfach as part of the Replacement
Local Development Plan. The Candidate Site is edged red below in Plan A.

Plan A

The Candidate Site comprised of the frontage elements of two existing enclosures, providing
a development opportunity that mirrored existing development found on the eastern side of
the adjoining public highway. The form and extent of the Candidate Site was also dictated by
future aspirations of the Welsh Government (Transport Division) in relation to the Llandeilo
and Ffairfach bypass and so ensured that this strategic project would not be prejudiced in
any way, should it come forward.
Following its due consideration, the Council then excluded the Site from the proposed
development limits for Ffairfach 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:
“Development would lead to an unacceptable extension of the urban form. There is sufficient residential land allocated in the settlement.”

At the time of publication of the 1st Deposit LDP therefore, the principle 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 settlement 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:

“Development would lead to an unacceptable extension of the urban form. There is sufficient residential land allocated in the settlement. The Site will remain outside of limits.”

As can be seen, the rationale of the Council for the exclusion of the Site as an allocation in the LDP has remained the same. This is somewhat puzzling and illogical and for the reasons set out below, puts the soundness of the Plan into question.

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 therefore 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)

Response to Council’s Reasons for Non-Allocation of Site
Sufficient Residential Land Allocated Within Settlement
Under the provisions of the 2nd Deposit LDP, Ffairfach in conjunction with Llandeilo and Rhosmaen is defined as a Service Centre, representing the largest and most sustainable settlement in Cluster 5 of the Settlement Framework. Despite this, and the fact that the Council’s objective through the Plan is to channel most development to these settlements, the current 2nd Deposit LDP has only allocated land for the provision of 27 new homes during the Plan period for the Service Centre. To therefore suggest that there is ‘sufficient residential land’ within the settlement to meet its community’s needs and satisfy the strategic policies of the Plan is incredulous and for the Council’s proposals to remain unchanged would result in the Plan being ‘unsound’.

In turn, the Service Centre then forms part of a group of settlements defined as Cluster 5 in the Settlement Framework, with the table below providing an indication of the proposed allocations in the 2nd Deposit LDP for the cluster.

Ref. No.
Site Name
Units
SeC15/h1
Land to north of Dan y Crug, Llandovery
61
SeC15/h2
Land adjacent to Bryndeilog, Tywi Avenue, Llandovery
8
SeC16/h1
Llandeilo Northern Quarter, Llandeilo
27
SeC17/h1
Land opp. Llangadog C.P School, Llangadog
16
SeC17/h3
Ger yr Ysgol, Llangadog
21
SuV49/h1
Ael y Mynyd, Llanfynydd
13
SuV51/h1
Opp. Village Hall, Cwmifor

Table 1

The above provides a worrying picture with regard to housing supply in the Cluster in question. Despite being the largest and most sustainable Service Centre of Cluster 5, Llandeilo/Rhosmaen/Ffairfach has a far lower level than the smaller settlement of Llandovery and less than half the number allocated for Llangadog, despite the settlement being half the size of Llandeilo.
The above is even more worrying when the deliverability, or the ability to deliver the assigned number of units of some of the above allocations are in serious question (SeC17/h1 and SuV51/h1), as well as some sites despite being allocated for over 30 years, still having not delivered as single unit (SeC15/h1)

As a result of the above, separate objections have been made in relation to a number of the aforementioned allocations and it is therefore important that alternative more deliverable sites should be identified, to ensure the Plan can be regarded as being ‘sound’ in targeting new housing development at the most sustainable location.
Development would lead to an unacceptable extension of the Urban Form.

The second reason given by the Council for not allocating the Candidate Site was on the basis that in its view it would “… lead to an illogical extension fo the urban form.”.As the accompanying Candidate Site Supporting Statement highlights, the Candidate Site is in fact well related to the existing settlement of Ffairfach and its current urban form. This is best apprecaited from an aerial photograph (see below), which illustrates the close proximity of the site (edged red) to existing residential development and the fact that it would represent a logical rounding-off opportunity of the settlement at this location.

Photograph 1

From an accessibility perspective, the site is within short walking distance of a number of the
settlement’s community facilities and local services, as well as well served bus stops. The
allocation of the Candidate Site would not only represent a logical addition to the existing
urban form, but would also represent a sustainable form of development.

In view of the above, the decision of the Council is again somewheout confusing, when the
merits and attributes of the Candidate Site are taken into consideration. The decision is then
even more confusing – and indeed inconsistent – when similar allocations such as that
proposed for Cwmifor are taken into consideration. Both this allocation and the Candidate
Site clearly share the same attirbutes and objectives of rounding-off the existing urban form
of their respective settlements through mirroring existing residential development on the
opposite side of the public highway to which they relate. On this basis, the consistency of
approach with regards to the assessment of sites must be called into question and indeed
the soundness of the Plan.

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 Plan

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Gwili Developments Ltd to
prepare and submit an Alternative Site Report for the allocation of land at Bronwydd
Arms, 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 approved drawing
package, as well as an integrated sustainability assessment undertaken in-line with
the Authority’s requirements.
Alternative Allocation Report April 2023
Land at Bronwydd Arms, Carmarthenshire

2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Candidate Site relates to a parcel of land measuring approximately 2.2 acres in
area, edged red on the plan and image below.
Plan A
Photograph 1
Alternative Allocation Report April 2023
Land at Bronwydd Arms, Carmarthenshire
2.1.2 The site currently consists of a single enclosure of semi improved grassland with a
mixed topography. All its boundaries are currently well established, being defined by
a mix of mature hedgerows and treelines, agricultural and domestic fencing, with the
latter leading on to existing residential development on its eastern, southern and
northern edges.
2.1.3 Access (red arrow in Photograph 2) to the Site is currently gained directly off the
A484 at a point with excellent visibility, as illustrated below.
Photograph 2
2.1.4 It should be noted that the Alternative Site currently benefits from outline planning
permission for 15 houses (LPA ref. No. W/20622) and our Client and their Design
Team are currently working up a scheme for the submission of a reserved matters
application.
2.1.5 Under the provisions of the current Carmarthenshire LDP, the Site is allocated for the
purposes of residential development, as illustrated in the plan below.
Alternative Allocation Report April 2023
Land at Bronwydd Arms, Carmarthenshire
Plan B
2.1.6 It is recognised that the allocation has yet to be developed, but this is due to the fact
that although the aforementioned application was submitted in 2009 and was
conditionally approved in 2013 by the Council’s Planning Committee, the local
planning authority took a further 9 years to issue the outline planning permission in
2022, through no fault of the Applicant our Client.
2.1.7 The Alternative Site is therefore well related to the existing built form of the settlement
of Bronwydd as a whole when existing residential development directly to its south,
east and north is taken into consideration. Its position and proposed use therefore
continues to 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 Bronwydd. The existing built form and pattern of the settlement is elongated in
nature, principally following and spurring off the A484 and B4301 that runs through it.
However, the settlement does include some ‘in-depth’ examples of residential
schemes, such as Bron y Glyn opposite the Alternative Site, Maes y Dderwen, Gelli
Aur, Bro Celynin and Troed yr Ynys.
Alternative Allocation Report April 2023
Land at Bronwydd Arms, Carmarthenshire
2.2.2 In terms of community facilities and local services, the settlement includes a village
hall, cricket club and pitch, public house and chapel. It also has a number of very well
served bus stops regularly visited by the 460 and 215 services.
2.2.3 As a result of the above, the Alternative Site is also within a short distance and bus
journey from the nearby larger settlement and centre of Carmarthen, which includes a
wider range of community facilities and local services. 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, the settlement of Bronwydd forms part of Cluster 1 as
defined by Policy SP3, being designated as a Tier 3 – Sustainable Village. However,
despite this status, the settlement contains only 1 housing allocation, designated for
the delivery of only 6 units. This in itself is surprising and concerning in view of the
sustainable attributes and position of the settlement of Bronwydd in the County’s
settlement network.
2.2.5 In addition to the above, we have undertaken a comprehensive review of the
proposed allocations put forward by the 2nd Deposit LDP for Cluster 1 and 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
PrC1/h4 Land of 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
Alternative Allocation Report April 2023
Land at Bronwydd Arms, Carmarthenshire
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 April 2023
Land at Bronwydd Arms, Carmarthenshire

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 copy of the approved site layout for the proposed
residential scheme for the Alternative Site. With the approval of the Council, this
layout therefore demonstrates that the Site is capable of providing 15 units in a
deliverable and sustainable manner. The following information therefore expands on
this approved scheme.
3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Candidate Site be allocated in the forthcoming replacement
LDP for the purposes of15 residential units, in line with the current planning consent.
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 – 15 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. The
Alternative Allocation Report April 2023
Land at Bronwydd Arms, Carmarthenshire
positioning of the proposed units has also taken into account the topography of the
site.
3.1.3 With regards then to access, as detailed previously, the Alternative Site has an
existing point of vehicular access directly off the A484, which in turns represents the
currently approved point of access. The Alternative Site would therefore be served by
an adoptable highway off this point, with footway connections to the site also created.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Any development of the Candidate Site for residential units would be served by
mains water, public sewer and electricity, connections to which 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 April 2023
Land at Bronwydd Arms, Carmarthenshire

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 site boundary
features, as per the existing outline planning permission.
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. In addition, it is sufficient distance from
the nearest designation to ensure that it will not have any detrimental impact on this
feature.
Alternative Allocation Report April 2023
Land at Bronwydd Arms, Carmarthenshire
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 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 at Bronwydd Arms, Carmarthenshire
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 at Bronwydd Arms, Carmarthenshire

5.0 VIABILITY
5.1.1 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.
5.1.2 In terms of the Alternative Site, no less than two viability appraisals have been
prepared and produced for the proposed development put forward by this report, with
the most recent accompanying this submission. As can be seen from the
accompanying Appraisal – which was fundamental in granting outline planning
consent – the scheme put forward has been demonstrated to be viable.
5.1.3 In terms of deliverability, we note the comments of the Council in their Site
Assessment document with regards to the Alternative Site (as an existing allocation).
The Council expressed the view that “There are concerns regarding the deliverability
of the site. The site represents a longstanding residential allocation.”. However, it
should be noted that the failure to deliver any new units on the Site has not been at
the fault of our Client, but that of the Council in taking 13 years to issue a planning
consent.
5.1.4 With the consent now issued, our Client has begun undertaking further detailed
design work with the aim of preparing a reserved matters application due course, as
the Site is clearly a viable and deliverable form of residential development.
Alternative Allocation Report April 2023
Land at Bronwydd Arms, Carmarthenshire

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 at Bronwydd Arms, Carmarthenshire

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. These are in fact views shared by the Council due to it finally recently
issuing an outline planning permission for the Site’s development.
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 also benefits 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 settlement and wider Cluster 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 April 2023
Land at Bronwydd Arms, Carmarthenshire
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.

Amend Plan to include the site

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/004/032, seeking the allocation of their land for future residential development within the
defined settlement limits of Penybanc as part of the Replacement Local Development Plan.
The Candidate Site is edged red below in Plan A.

Plan A

The Candidate Site comprised of an existing enclosure, accessed directly off the adjoining
recently constructed residential development known as Parc Fferws. The site has a
developed appearance, due to its historic use as a construction compound for the
aforementioned residential development. The site is 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 Penybanc 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
settlement 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 settlement 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
settlement to accommodate its housing need.”.

As can be seen, the initial rationale presented by the Council mirrors that at the 1st Deposit
LDP stage (housing land supply). However, we consider the Site’s 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
therefore 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 (August 2018)

Response to Council’s Reasons for Non-Allocation of Site
Sufficient Residential Land Allocated Within Settlement
As detailed above, 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 Tycroes 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.

Allocate the site for housing within the Revised LDP.

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Mr M Ingram to prepare and
submit an Alternative Allocation Report for the allocation of land adjoining Rhosdeg,
Rhosmaen 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, as well as an integrated sustainability
assessment undertaken in-line with the Authority’s requirements.
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen

2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Alternative Site relates to land measuring approximately 2.7 acres in area in
total, edged red on the plan and the photograph below.
Plan A
Photograph 1
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen
2.1.2 AS can be seen from the aerial photograph above, the Alternative Allocation forms
part of a larger agricultural enclosure, which currently consists of improved grassland,
used historically for a mix of grazing or silage/hay purposes. The Site’s south
western, southern eastern and north eastern boundaries are all well defined by a mix
of domestic fencing and established hedgerows. Its remaining north western
boundary is then currently undefined, leading on to the remainder of the
aforementioned agricultural enclosure.
2.1.3 Access to the site is currently gained via an existing agricultural gateway leading
directly onto the adjoining A40, with good levels of visibility in both directions as
illustrated below.
Photograph 2 Photograph 3
2.1.4 Under the provisions of the current Carmarthenshire LDP, as illustrated in the plan
below, part of the Site’s frontage currently lies within the defined development limits
for Rhosmaen, with its remainder then lying beyond.
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen
Plan B
2.1.5 Notwithstanding the above, as can be seen, the Site (outlined in red) adjoins the
current built form of the urban area directly to the south west, south east and north
east and so is well related to the settlement’s existing built form as a whole. 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
Rhosmaen, which forms part of the wider urban area of Llandeilo and Ffairfach (Tier
2 – Service Centre). As a result, the Site is within walking distance of a number of its
community facilities and local services, including the following:
 Primary School
 Secondary School
 Several Retail Units (A1 and A3)
 Several Public Houses (A3)
 Several Places of Worship
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen
2.2.2 From an accessibility perspective, Rhosmaen is within walking distance of a station
on the Heart of Wales line, is located on a main transport artery in the form of the A40
Trunk Road, as well as having very well served bus stops, the nearest of which to the
Alternative Site is less than 100m to the south west. The bus services serving the
settlement are numbers 280 and 281, which provide regular access to many
settlements in between and including Llandovery and Carmarthen. The strong
sustainable position of Rhosmaen should therefore be given full consideration when
considering potential future growth options.
2.2.3 As detailed above, Rhosmaen forms part of a Service Centre as defined by the 2nd
Deposit LDP, where second only to Principal Centres, the Council expects a large
portion of the planned growth in the County to take place due to their sustainable
attributes. In turn, the Service Centre then forms part of a group of settlements
defined as Cluster 5 in the Settlement Framework, with the table below providing an
indication of the proposed allocations in the 2nd Deposit LDP for the cluster.
Ref. No. Site Name Units
SeC15/h1 Land to north of Dan y Crug, Llandovery 61
SeC15/h2 Land adjacent to Bryndeilog, Tywi Avenue, Llandovery 8
SeC16/h1 Llandeilo Northern Quarter, Llandeilo 27
SeC17/h1 Land opp. Llangadog C.P School, Llangadog 16
SeC17/h3 Ger yr Ysgol, Llangadog 21
SuV49/h1 Ael y Mynyd, Llanfynydd 13
SuV51/h1 Opp. Village Hall, Cwmifor
Table 1
2.2.4 The above provides a worrying picture with regard to housing supply in the cluster in
question. Despite being the largest and most sustainable Service Centre of Cluster 5,
Llandeilo/Rhosmaen/Ffairfach has a far lower level than the smaller settlement of
Llandovery and less than half the number allocated for Llangadog, despite the
settlement being half the size of Llandeilo.
2.2.5 The above is even more worrying when the deliverability, or the ability to deliver the
assigned number of units of some of the above allocations are in serious question
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen
(SeC17/h1 and SuV51/h1), as well as some sites despite being allocated for over 30
years, still having not delivered as single unit (SeC15/h1)
2.2.6 As a result of the above, separate objections have been made in relation to a number
of the aforementioned allocations and it is therefore important that alternative more
deliverable sites should be identified, to ensure the Plan can be regarded as being
‘sound’ in targeting new housing development at the most sustainable location.
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen

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 31 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 31 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
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen
3.1.2 As illustrated above, the site is potentially capable of accommodating a mix of unit
sizes and types, with the associated density – 31 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 a single point of access directly off the A40. From this then would be a new
adoptable estate road, with private shared drives where required.
3.1.4 As illustrated on the plan above, provision would also be made for a Local Equipped
Area of Play, a facility that is not currently present in the settlement of Rhosmaen.
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. Due to the Site falling within the River Tywi
SAC catchment, the scheme would also include provision for on-site foul water
treatment infrastructure to adhere to current phosphate regulations, as illustrated on
the accompanying drawings.
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 adjoining Rhosdeg, Rhosmaen

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 Rhosmaen 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 SAC is within 1km of the site,
due to the intervening distance and topography, the development of the Alternative
Site will not have any detrimental impact on this features.
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen
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 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 Below are extracts of the current Development Advice Maps or those produced by
Natural Resources Wales, with the Alternative Site edged red.
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen
Plan F
(Development Advice Maps)
Plan G
(Flood Maps for Planning)
4.3.2 Although a very small portion of the Site’s north eastern edge lies within an area
determined as being at risk of flooding, as can be seen, this would not prevent its
delivery for the proposed number of new housing units. Nor would it prevent access
to the Site during an extreme flood event. In summary therefore, flood risk would not
prevent the delivery of the Alternative Site.
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen
4.3.3 In terms of ground conditions, due to its greenfield nature, the Alternative Allocation
has no ground contamination related constraints.
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen

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 £1150 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 adjoining Rhosdeg, Rhosmaen
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 31 units, with 4 three bed units being affordable.
Costs Cost Per Unit/Metre
No.
Units/Metres Total
2 Bed (90 sq m) 103500 10 1035000
3 Bed (115 sq m) 132250 16 2116000
4 Bed (145 sq m) 166750 5 833750
Road Construction 1200 140 168000
Utility Connections 5000 31 155000
Professional Fees - 153192
Sprinklers 3500 31 108500
Parks and Education
Cont. 5000 31 100000
Total 4669442
Sales
3 Bed (115 sq m)
(Aff) 78286 4 313144
2 Bed (90 sq m) 170000 10 1700000
3 Bed (115 sq m) 245000 12 2940000
4 Bed (145 sq m) 300000 5 1500000
Total 6453144
Developers Profit Total 1161565.92
Residual Land Value 622136.08
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 adjoining Rhosdeg, Rhosmaen
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 3 years from the adoption of the Replacement Local Development
Plan.
Alternative Allocation Report April 2023
Land adjoining Rhosdeg, Rhosmaen

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 adjoining Rhosdeg, Rhosmaen

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. Its inclusion within the development limits would also represent a logical
rounding off of the current built form, providing a defensible boundary with respect to
the surrounding open countryside beyond the Alternative Site.
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 wider settlement group it
forms part of. From a wider sense, the Site will also benefit from well served excellent
public transport links to the nearby conurbations of Llandovery, Ammanford 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 adjoining Rhosdeg, Rhosmaen
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.

Amend Plan to include the site

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/148/002, seeking the allocation of their land for future residential development within the
defined settlement limits of Saron as part of the Replacement Local Development Plan. The
Candidate Site is edged red below in Plan A.

Plan A

The Candidate Site comprised of a series of enclosures, with its south western boundary
fronting onto the adjoining public highway (A484), from which access to the site is gained. Its
remaining boundaries were as equally well defined through a combination of established
field boundaries and residential properties.
Following its due consideration, the Council then excluded the Site from the proposed
development limits for Saron 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:

“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.”

At the time of publication of the 1st Deposit LDP therefore, the principle 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 settlement 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:

“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.”

As can be seen, the rationale of the Council for the exclusion of the Site as an allocation in
the LDP has remained the same. This is somewhat puzzling and illogical. In terms of
‘alternative sites’ in the 2nd Deposit LDP, Saron has only one small allocation being put
forward. In addition, the number of units proposed to be accommodated by the allocation
does not seem to have taken on board the requirement for on-site provision for phosphate
provision, which can amount to up to 25% of a development site’s area. (Please see
accompanying Site Layout plan for site at Heol Hathren, Cwmann). This and the low number
of allocations within the settlement seems an extremely erroneous decision, particularly in
terms of (a) the sustainable attributes of the settlement and (b) the number of undeliverable
allocations being put forward by the 2nd Deposit LDP and so further sites are required (see
below).

The second reason given for the exclusion of the site is completely illogical and inconsistent
with other decisions taken by the Council in the preparation of its 2nd Deposit LDP. As can be
seen form the accompanying Candidate Site Report, the settlement of Saron has a nuclear
pattern of growth that then extends along the main transport arteries that support it.

Overtime as the settlement has evolved and grown, such growth has occurred then in
between these strands of development. Contrary to the Council’s view, it is clear therefore
that the development of the Site in question would harmonise with the settlements existing
character and setting.

On the basis of the 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.
In addition, we consider that alternative allocations within the wider Cluster that Saron forms
part of (discussed below) 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 therefore 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)

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 not allocate the
land in question and understand that this may be because the Council holds the view that
alternative allocations within the wider Cluster 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 Cluster 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 Cluster 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
SeC12/h1 Trem y Ddol, Newcastle Emlyn 17
SeC12/h3 Land to r/o Dolcoed, Newcastle Emlyn 20
SeC13/h1 Adjoining y Neyadd, Llanybydder 10
SeC14/h1 Blossom Garage, Pencader 20
SeC14/h2 Land adj. Maescader, Pencader 24
SuV33/h1 Land opp. Brogeler, Llangeler
SuV28/h1 Maes y Bryn, Capel Iwan 6
SuV39/h1 Adj. Yr Hendre, Llanfihangel ar Arth 7
Su41/h2 Cilgwyn Bach, Pontyweli 14

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.

Amend Plan to include the site

1.0 INTRODUCTION
1.1 Evans Banks Planning Ltd. has been instructed by Ms A Morgan and Mrs I Wright to
prepare and submit an Alternative Allocation Report for the allocation of land at
Glynderi, Tanerdy, 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 March 2023
Land off Glynderi, Tanerdy

2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Candidate Site relates to a parcel of land measuring approximately 3.5 acres in
area, edged red on the plan and image below.
Plan A
Alternative Allocation Report March 2023
Land off Glynderi, Tanerdy
Photograph 1
2.1.2 The site currently consists of a sloping grassed enclosure, as shown in Photograph 2
and 3.
Photograph 2 Photograph 3
2.1.3 The site is surrounded by strongly defined boundaries. Its north-western boundary is
defined by an area of mature trees, its southern by a number of residential properties,
while its western and eastern boundaries by existing hedgerows.
2.1.4 As detailed above, vehicular access is obtained directly off Glynderi at the southern
boundary of the site, via an existing hammerhead access located between existing
Alternative Allocation Report March 2023
Land off Glynderi, Tanerdy
dwellings. The road is constructed to adoptable standards and therefore provides a
good level of visibility for vehicles entering and leaving the site, as illustrated below.
Photograph 4 Photograph 5
2.1.5 Under the provisions of the current Carmarthenshire LDP, the Site presently lies at
the northern edge of the defined Development Limits of the settlement of Tanerdy.
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 south, with its
northern boundary presenting a very strong and defensible boundary to the much
more open landscape to the north of the site (Photograph 6).
Plan B
Alternative Allocation Report March 2023
Land off Glynderi, Tanerdy
Photograph 6
2.1.6 As can be seen, the Alternative Site is therefore well related to the existing defined
Development Limits for Tanerdy and the settlement’s built form as a whole when
existing residential development directly to its south 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 Tanerdy. The existing built form and pattern of the settlement follows key access
routes, with then further development leading off those along roads such as Glynderi.
2.2.2 Due to this position and close association with the existing built form, the Alternative
Site has excellent access to the range of community facilities and local services the
settlements of Tanerdy and Carmarthen have to offer, with such facilities and
services being within walking distance of the site (in part due to its position near an
existing Public Footpath to the south of the site – pictured below with the site
indicated by a red star), as well as being accessible via regular bus services.
Alternative Allocation Report March 2023
Land off Glynderi, Tanerdy
Plan C
2.2.3 The following table then provides a summary of some of the key facilities and
services present nearby, together with their approximate walking distance.
Facility/Service Distance from Candidate Site
Nearest Bus Stop 200m
Primary School 1 mile
Secondary School 2.8 miles
Hospital 0.8 miles
Shopping Area 1.3 miles
Place of Worship 0.8 miles
Table 1
2.2.4 In addition to the above, the Alternative Site is also within a short distance and bus
journey from the nearby larger settlement and centre of Carmarthen, which includes a
wider range of community facilities and local services. The strong sustainable position
of the Alternative Site should therefore be given full consideration when considering
potential future growth options.
Alternative Allocation Report March 2023
Land off Glynderi, Tanerdy
2.2.5 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:
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
2.2.6 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 off Glynderi, Tanerdy

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 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 Candidate Site be allocated in the forthcoming replacement
LDP for the purposes of 20 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
Alternative Allocation Report March 2023
Land off Glynderi, Tanerdy
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
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, as detailed previously, the Candidate Site has an
existing point of vehicular access directly off Glynderi that benefits from excellent
visibility in both directions. The Candidate Site would therefore be served by an
adoptable highway off this point, with footway connections to the site also created.
3.1.4 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. For the purposes of the accompanying viability assessment however, it
is proposed that 3 of these units would be affordable in nature, being a mix of social
rent and intermediate in terms of tenure.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Any development of the Candidate 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 off Glynderi, Tanerdy

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 site boundary
features.
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 March 2023
Land off Glynderi, Tanerdy
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 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 off Glynderi, Tanerdy
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 March 2023
Land off Glynderi, Tanerdy

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 £1,150 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 March 2023
Land off Glynderi, Tanerdy
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 two bed units).
Costs
Cost Per
Unit/Metre
No.
Units/Metres Total
3 Bed semi (90 sqm) 108000 6 648000
3 bed bungalow (100sq
m) 120000 14 1680000
Road Construction 1200 300 360000
Utility Connections 5000 20 100000
Professional Fees - 105600
Sprinklers 3500 20 70000
Parks and Education
Cont. 5000 20 100000
Total 3063600
Sales
3 Bed semi(90 sqm) (Aff.) 78286 3 234858
3 Bed semi(90 sqm) 260000 3 780000
3 bed bungalow (100sq
m) 290000 14 4060000
Total 5074858
Developers Profit Total 913474.44
Residual Land Value 1097783.56
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 March 2023
Land off Glynderi, Tanerdy
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. Tanerdy 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 March 2023
Land off Glynderi, Tanerdy

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
Land off Glynderi, Tanerdy

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 March 2023
Land off Glynderi, Tanerdy
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.

Amend Plan to include the site

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/109/005, seeking the allocation of their land for residential development within the
defined settlement limits of Llanybydder as part of the Replacement Local Development
Plan. The Candidate Site related to the land edged red in Plan A below.

Plan A

The Candidate Site comprised of a single enclosure, with its western boundary leading onto
Heol y Dderi and existing development found directly to its north. Its remaining boundaries
were then defined by established field boundaries. The land therefore clearly represented a
logical extension opportunity to the existing settlement and its extents are illustrated by the
red line below.

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

Plan B

Allocated under reference SeC13/h2, the allocation in its totality was expected to deliver a
total of 30 units within 11-15 years of the Plan’s commencement date.

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:

“Large scale development within Llanybydder is limited due to the town falling within the
phosphate sensitive SAC catchment. It is considered that there is sufficient and more
suitable land available for development within the town to accommodate its housing need
According then to the 2nd Deposit LDP Proposals Maps, the Site is no longer allocated for
the purposes of residential development, as illustrated in Plan C.

Plan C

The rationale given by the Council in reaching its decision is deeply worrying and provides a
strong indication that their process of assessment of Candidate Sites within the phosphate
sensitive SAC catchment has been incorrect, in turn causing the Plan to be deemed
unsound. The Council does not provide any evidence to substantiate its claim that “Large
scale development within Llanybydder is limited due to the town falling within the phosphate
sensitive SAC catchment.”. In fact, from our experience of dealing with planning applications
within such catchemetn’s, it is the larger scale developments that represent the more
deliverable and viable option for securing new housing than the smaller sites.

As can be seen form the accompanying drainage drawing for a site at Heol Hathren,
Cwmann, the area necessary to provide the infrastructure for dealing with phosphates on an
on-site basis in line with the current regulatory requirements, would amount to 25% of the
total site area. On this basis (and with allocation SeC13/h4 under construction), the
proposed allocations put forward by the Council for Llanybydder – if technically possible –
will only deliver 7 units. This is incredibly low for such a sustainable settlement containing a
wide variety of community facilities and local services.

In addition to the above, the decision to not allocate the Alternative Site is not only
technically flawed, 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 Cluster 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 for the purposes of 24 units to allow for provision on site for the
aforementioned foul water infrastructure.

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)

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 not allocate the
land in question and understand that this may be because the Council holds the view that
alternative allocations within the wider Cluster 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 Cluster 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 Cluster 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
SeC12/h1 Trem y Ddol, Newcastle Emlyn 17
SeC12/h3 Land to r/o Dolcoed, Newcastle Emlyn 20
SeC13/h1 Adjoining y Neyadd, Llanybydder 10
SeC14/h1 Blossom Garage, Pencader 20
SeC14/h2 Land adj. Maescader, Pencader 24
SuV33/h1 Land opp. Brogeler, Llangeler
SuV28/h1 Maes y Bryn, Capel Iwan 6
SuV39/h1 Adj. Yr Hendre, Llanfihangel ar Arth 7
Su41/h2 Cilgwyn Bach, Pontyweli 14

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
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 in 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/138/010, seeking the allocation of their land for future residential
development within the defined settlement limits of Pontyberem as part of the
Replacement Local Development Plan. The Candidate Site is edged red below in
Plan A.

Plan A

The Candidate Site comprised of a single enclosure laid to grass, with its eastern boundary
fronting onto the adjoining public highway, from which access to it was gained. Its remaining
boundaries were as equally well defined through a combination of existing hedgerows, stock
and domestic fencing.
Following its due consideration, the Council then excluded the Site from the proposed
development limits for Ffairfach 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:

“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 village to accommodate its housing need.”.

At the time of publication of the 1st Deposit LDP therefore, the Council presented two separate reasons for justifying its exclusion, although no further detail or explanation than the above statement was provided.

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:

“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 village to accommodate its housing need.”.

As can be seen, the rationale of the Council for the exclusion of the Site as an allocation in the LDP has remained the same. This is somewhat puzzling and illogical and for the reasons set out below, puts the soundness of the Plan into question.

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 therefore 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)

Response to Council’s Reasons for Non-Allocation of Site
Sufficient Residential Land Allocated Within Settlement
Under the provisions of the 2nd Deposit LDP, Pontyberem is defined as a Service Centre, representing one of the largest and most sustainable settlements in Cluster 3 of the Settlement Framework. Despite this, and the fact that the Council’s objective through the Plan is to channel most development to these settlements, the current 2nd Deposit LDP has only allocated land for the provision of 34 new homes during the Plan period for the Service Centre, with one allocation not expected to deliver any housing until the last years of the Plan’s lifetime. To therefore suggest that there is ‘sufficient residential land’ within the settlement to meet its community’s needs and satisfy the strategic policies of the Plan is illogical and for the Council’s proposals to remain unchanged would result in the Plan being ‘unsound’.

In addition to the above, Pontyberem and the Cluster it forms part of 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 Cluster 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.
Development would lead to a detrimental impact on the character and setting of the settlement
The second reason given by the Authority for not allocating the Candidate Site was on the basis that in its view it would “… lead to a detrimental impact on the character and setting of the settlement.”.

As the accompanying Candidate Site Supporting Statement highlights, the Candidate Site is in fact well related to the existing settlement of Pontyberem. This is best apprecaited from an aerial photograph (see below), which illustrates the close proximity of the site (edged red) to existing residential development to its south and west.

Photograph 1

As can also be seen from the aerial photograph, the ‘character and setting’ of Pontyberem is defined by residential development along its main arteries, with further in-depth developments of them, such as New Road and Bryn Tirion illustrated above. To suggest therefore that the development of the Site in the same manner would be ‘detrimental’ to the character and setting is incredulous and demonstrates that the assessment process of Candidate Site undertaken by the Council has been inconsistent and therefore flawed.

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.

No change, site to remain unallocated in the Revised LDP.

With reference to the above I wish to raise in the following objections to this land being adopted as a LDP.
Advertising boards have already been erected and the services of an Estate Agent engaged, these boards state various size houses, bungalows and fully serviced plots are, ‘coming soon’.

Grossly misleading advertising. No planning permission has even been applied for to date.
There were always serious concerns regarding any possible development of this land resulting in Carmarthenshire County Council refusing planning permission E/21000 in 2009. Although after a second appeal permission was upheld in 2011 (obviously now expired) the Welsh Assembly attached lengthy conditions to be strictly adhered to for the future.

APP/M6825/A/11/2143981.
I wish to draw your attention to several such items listed below.

The document demanded a Full Intrusive Mining Legacy Survey.
This land is of major concern geologically due to historical mining activities with shallow mine working under.

In 1999 it was necessary to demolish a bungalow due to uneconomical repair of its subsidence. The Consulting Engineers acting on behalf of the Coal Authority concluded the subsidence was caused by shallow workings beneath the property, …upward migration of weakened strata overlying collapsed old mine workings most likely caused by water from surface runoff following a pathway along the rock head.
Another condition states hedgerows were to be maintained, already some have been ripped out.
This land has lain undisturbed for many many years and because of its uniquely wet state is supporting its own Ecco system. A full and in-depth survey must therefore be carried out before any disturbance takes place.
I have grave concerns regarding the access road on and off the site which will bring increased traffic to an already busy road. This section of the road has a history of minor traffic accidents.

I will also add my concerns regarding the use of the farm track adjacent to 277 Cwmamman Road and Ty’n y Wern Vestry the track leads to Ty’n y Wern Farm and runs in front of my bungalow.

It is also possible to access the field in question via this track and has already been used on a least two occasions to my knowledge to transport plant machinery into the field in order to clear a hedgerow.
The track is very poorly maintained and will not withstand heavy use. The winter months are particularly challenging regarding the surface water carried by the track causing mud, pot holes and erosion. I am elderly and drive a small car I also need to walk this track for access to the main road. I fear any amount of use by such vehicles will render my use hazardous to say the least.

No change to the Plan.

With reference to the above, I strongly object to this land in the future being included in the LDP. It has come to my attention that advertising boards by an Estate Agent has already been erected with possible intention to obtain as much interest from buyers as possible in order to submit planning application with the intention to obtain the approval of planning permission based on enquires from potential buyers. This is my theory. This is false advertising as this land has NO planning permission in force.
There are serious concerns with this site. It was subject to Carmarthenshire County Council refusing planning under planning application no E/21000 in 2009. Although a successful appeal in 2011 was lodged with the Welsh Assembly – the consent given has now obviously expired. In their report -conditions were strictly restrictive and had to be adhered to their specific requirements.
The land in question is geologically a major factor due to historical mining activities with shallow mine workings, and a demolition of a detached bungalow which suffered subsidence damage beyond economical repair in 1999. Shallow workings beneath the property of 272 Cwmamman Road resulted in the collapse and upward migration of weakened strata overlying collapsed old workings, probably augmented by water from surface runoff following a pathway along the rockhead as confirmed by Consulting Engineers on behalf of the Coal authority.

Residents are concerned that if this land is included for future LDP, there could be possible subsidence and ground heave with sudden movement that could affect adjacent properties if ever a housing development was erected.
The land is totally unsuitable for various reasons including history of traffic accidents on the highway. These issues were pointed out under the above reference number that is accessible to yourselves.
Please take into consideration my objection if ever the land is considered to be included in future LDP.

Include site within the Plan

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.

1. Introduction
This report has been prepared in support for the inclusion of land which is to the west of
Bryngwyn, Salem, Llandeilo which is located on the edge of the settlement of Salem.
2. Site Details
The potential candidate site is located on the edge of the settlement of Salem. The site
currently adjoins the settlement boundary of Salem. The land currently is used for pasture
by the proposer of this site. There are currently no structures or buildings within the parcel
of land.
3. Proposed Use of the Site and it’s Deliverability
The site is proposed to be allocated for residential housing purposes. It is the aim of the
land owner to provide a housing site for around 3-5 dwellings for local people. It is aimed
that once this land is allocated for housing and included within the settlement boundary for
Salem that a full planning application is prepared and submitted to Carmarthenshire County
Council. The aim is to provide housing for local people within the area with an application
submitted within 18months of the plan being adopted.
4. Site Assessment Methodology
The site is a relatively flat site that would be able to accommodate housing without
producing a visual impact on the local and wider area.
The site is a greenfield site with no history or evidence of past activities which would have
resulted in the contamination of any soils. Any development undertaken within this area
would be designed to enhance and improve the character of the area and not cause any
impact.
The site is located some distance away from any significant water course and therefore is
not identified as being liable to flood under the Natural Resources Wales Flood Maps. In
regards to the disposal of surface water, the site is sufficiently large enough to
accommodate the provision of soakaways within good ground conditions, which will be
able to drain freely with no signs of waterlogging or standing water.
It is not believed that there is a public sewerage system within Salem therefore the
provision of a private sewerage system such as septic tanks or sustainable drainage
systems. Access to all other services is readily available and would be easily accessible to
any new development within the area.

Any development on this site would involve the retention of the hedgerow and trees that
run along the site boundary to partially screen the development from the surrounding area.
There is no current evidence of any current habitats or protected species within the site.
5. Viability of the Site
The viability of the site is imminent. As previously mentioned the land owner intends to
submit a planning application on this site as soon it is adopted and included within the
settlement boundary of Salem. Having family that want to move to live within close
proximity to the family home has meant that the promoter wishes to provide housing locally
to ensure the return of local people to the area.
6. Accessibility
The site can be accessed from the existing road network. This would be adequate to
provide regular vehicle use and would have the provision to be widened to provide a
footway as required. Visibility splays to comply with current standards from vehicles
emerging onto the public highway are good in both directions.
7. Sustainability
The potential candidate site is immediately adjacent to the settlement limit as identified
and defined by the Local Development Plan. The extension to the settlement limit at this
location would provide an appropriate location for rounding off the settlement boundary to
provide much required residential properties within the area.
Salem is served by good public transport bus services which operate through the village,
with a bus stop located in close proximity. Bus routes provide links to Carmarthen and
Swansea. There are good cycle facilities to surrounding settlements, and there is also an
extensive footpath network available within the locality.
There are many facilities available within the village such as a community hall, a church and
a chapel. A couple of miles to the south, the town of Llandeilo offers and extensive range of
facilities, such as shops, offices, industrial units, community facilities, medial and pharmacy
facilities.
8. Conclusion
In conclusion, this site is believed to be a perfect site for inclusion within the Local
Development Plan to allow for further residential properties within the locality for local
people. In a climate where there are not enough housing available, it is considered that the
authority should re-asses their assessment of this site and consider it’s inclusion due to the
land owners being keen in developing the land.

Include site within the Plan.

AS/017/006

1. Introduction
We would like to include a field next to Capel Dewi Ucahf Farm in the new Local
Development Plan. This parcel of land has got a long planning history. It is located
200 m of the Capel Dewi village on its eastern side amongst a spread of more recent
individual housing and is a site identified in the UDP – ref ALT/021/001/N.

2. Site Appraisal
This candidate site consists of an area of unused land which was covered with selfseeded saplings, which had been cleared a while ago. It lies on the north side of the
B4300 from which it falls northward at gradients of 1 in 5 beyond a linear hedge like
and some mature trees.
The land in question once belonged to the Farm known as Capel Dewi Uchaf. In later
years the village became known by the farms name, being the oldest Farmhouse in
the village and Grade II listed at the end of 20th century. Capel Dewi Uchaf is
mentioned in many historical books written on Carmarthenshire.
A trackway to Capel Dewi Uchaf Farm the northern edge, given a site depth of 13m to
the west and 40m to the east. The eastern boundary forms a roman road. The O.S.
reference is 248200-248350, 220150-22020.
A well building exists at the western edge of the site, a heritage asset which will be
retained and repaired by the applicant. It is reported to have served the local school in
the last century.
It becomes apparent from the attached maps that there is a separation from the two
settlements which constitute the village of Capel Dewi. The land in question for
inclusion in the 2nd revision of the LDP 2018 - 2033 is shaded in orange sited, near to
the centre of the village. There are two immediate residential properties to the West a
few yards from the land in question and two immediate residents to the East of the
proposed land marked in orange.
There are 30 residential homes in the post code SA32 8AY plus one commercial site,
the land in question is in the middle of the span of the postal code. The two parts of
the village would become connected. Giving the village the opportunity to apply for a
foot path to be extended through the village so residents can walk their children and
pets in safety to Bus Stops. The village is on cycle way 47. Horses traverse through
the village regularly, there is a warning sign appertaining to horses. The village is in
need of re defining to make it a safer place to live.
The land has been cleared and professionally surveyed and check for suitability for
development being deemed positive for inclusion in the village. The proposed site
does not lock away any accesses to land behind.
Architects drawings have been provisionally completed to show the type of
development intended for two affordable houses with three bedrooms, sharing a new
entrance off the road taking the vehicles to four garages and 4 parking places. The
two houses are intended to appeal as village housing for young families. There is a
school bus for the village children and a primary school in Nantgaredig. The village
has many retired residents with a lively Community Association.
3. Access
There is no existing access to the site from the main road. A new access off the B4300.
An access of the trackway to Capel Dewi Uchaf cannot be safely provided
for 2 dwellings additionally, an ash tree would be in the way. The proposed access is
deemed sage by the highway’s dep, which had been contact in the pre-discussion
stage.
4. Flooding
The site lies well above the water level and in good distance from the Towy. No
evidence can be found on the flood maps issued by the Environmental Agency –
Wales.
5. Pollution
The land is currently a greenfield site, with no use for agricultural or forestry. Nobody
has used the site for more than since the 1930 or even longer. It has a spread of selfseeded saplings. Scrub have recently been cleared.
No evidence can be found of any past development.
6. Main services
The applicant site has mains water, electricity and phone lines including broadband
running along the southern boundary to the road. These can easily be accessed. The
area is serviced by the local bin collection.
7.Proposal for sewage / waste water
A sewage Treatment Plant should be installed to the proposed site. This treatment
works would be for the use of both properties which are two 3 Bed roomed Village
style houses, accommodating a maximum of 12 people in total.
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 to a water course,
via a network of ditches to the River Towy.
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.
A special permission for access to empty the tank annually of sludge would be given
by the land owner at the back of the site.
There is a small need for electricity to run the plant, enough to run a 60watt light bulb
- this will require a shared electricity supply along with a shared meter. There will need
to be an agreement drawn up for a shared amount of maintenance on an annual basis,
this is to safe guard the environment and the neighbouring property.
8. Historic Importance
See attachment
9. Planning history
See attachment
10. 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
No underground or phone lines would cause a problem for a possible development.
12. Settlement - Boundaries
This candidate site lies just outside the settlement limits of Capel Dewi. In the LDP
referred a Capel Dewi 1 & 2. as defined in the local UDP. This site forms part of the
original boundary belonging to the grade II listed Capel Dewi Uchaf Farm. New
residential developments can be found in close proximity, along the B4300 towards
the East away from the center of the village. This settlement Capel Dewi 2 can be
found on the same side of the road as our site as well as the opposite one. Some of
these dwellings have only been erected in the last few years.
Capel Dewi is a village which has lost its local amenities. However various necessities
are in close proximity.
 General hospital, in Carmarthen 4 miles
 Secondary school 5 miles and 8 miles
 Primary schools, about 2 miles
 Leisure centers, 2 miles
 GP surgeries, 2 miles
 Various pubs and restaurants are in close by
 Shops are between 2.3 miles to 5 miles
13. Transport links
The transport links to Carmarthen, Cross Hands and Llandeilo town are well
established and developed.
 train station is in Carmarthen, 4.7miles
 4 bus line service the village of Capel Dewi; Celtic Travel, Morris Travel, First
Cymru and First South & West Wales
 Carmarthen town 4.7 miles
 Llandeilo town 17 miles
 Cross Hands 8 miles
 3 miles to the A48
 M4 is reached in about 11 min
 cycle way 47 runs along the site
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.
A new development would bring both parts (Capel Dewi 1 & 2) of the village of Capel
Dewi closer together.
The site is fairly large but it should not be overdeveloped and restricted to only 2
dwellings in similar size to the ones just down the road. This way the development will
protect and can incorporate the existing vegetation into a new layout.
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.
It should not be forgotten that Capel Dewi Uchaf is the oldest settlement in this area.
It's long important history is dating back centuries. Even the name of the settlement
has been given to the village. Numerous attempts to have part of the unused land
included in the previous LDPs have all failed. However, sites, further to the EAST away
from the proposed site have been included in the last LDPs.

Appendices
1. Site
2. Site photos
3. Historic impact
4. Planning history
5. Map of new build developments
6. Photos of recent build dwellings
7. Transport links – bus map
8. Flood map
9. Tree survey
10. Possible site layout
11. LDP & LDP 2
West - Towards the village centre – Capel Dewi 1 East - Capel Dewi 2
1.The site
2. site photos
Eastern direction
Eastern direction – position of the proposed access
Western direction
Potted History of
CAPEL DEWI UCHAF
2019
Capel Dewi Uchaf dates back to medieval times. A more recent history is recorded in
several publications. (see references at end of text). Clearly the name of the farm
denotes the naming of the village.
A record of ownership in the previous centaury: I bought Capel Dewi Uchaf Farm in
1986 from Mr and Mrs Lewis of Carmarthen, they shared with me the history as they
had known it; they bought the farm in 1954 from a Commander Alexander who had
purchased the farm in 1948 from Thomas Gwyn Jones. I believe there had been a
compulsory purchase in 1939 from the farm of several acres for the building of The
Water Works by The Glamorgan Water Board. Noted as Capel Dewi Water Works.
There was also a sale of some grazing land to a neighbouring farm Ffynnon Dewi
belonging to Thomas family in 1982: where there is a Holy Well. Hence the name of
the village being named as Capel Dewi. Capel Dewi Uchaf Farm (formerly described
as the Mansion House of Capel Dewi) is reputed to be visited by Pilgrims in medieval
times on their way to St David's, a regular and famous pilgrimage of those times. One
can still see on the land the remains of a 'Roman Road' built of stone with some
remaining walls left (That part of the road was later 'lifted' to become part of the
B4300!)
Historically there is a drovers road, to the western boundary, still visible and used
today which used to lead to a wooden bridge crossing the Towy River, there have
been one or two foot paths crossing the fields for the children from Nantgaredig to
attend school in the village of Capel Dewi, this would have been in Victorian times
when the school was built. There is a very small building which leans against a barn
and is believed to be a Chapel of Easement as there are two gothic style windows in
this building. There is a county map by Thomas Kitchen c1754 which is marked with
Rees, Gent and appertains to Capel Dewi Uchaf Farm. It is noted that the Mansion
existed before this map. The oldest coin found on the site is dated 1632.
As a point of fact the farmstead had not been lived in for over 30 years, the property
was in a derelict state when I purchased it in 1986. In my ownership I have
sympathetically renovated the Farmhouse, Cottage, Out Buildings and land for
habitation. I ran my very successful B&B business for 20 years, attracting many
awards and recognition throughout the world. Hosting Royal Princes, Diplomat's,
Lords and Ladies amongst delighted guests. I have been presented to His Royal
Highness, Prince Charles for my Outstanding Contribution to Tourism in
Carmarthenshire. In that time the farmhouse and the curtilage of the farmstead has
been Grade 11 listed. In 2012 due to retirement I sold the farmhouse, cottage and 10
acres of land and moved across to the renovated stable block, known as The Stables. I
continue to look after the well being of the property and 20+ acres. It should be noted
that all of this commitment to the property has contributed to the much needed
revenue put into the local economy over the years I have lived and worked in
Carmarthenshire. I should also like to point out that we now have three rateable
homesteads with one more to see it's full potential. The land proposed for inclusion
for development would also put into the market place two very well designed family
properties for which there is great demand.
I loath to mention that there has been other land 'released' for development
which is NOT in any LDP to the East of the so called village, further more these
Easterly developments are further out of the so called 'Village of Capel Dewi'
and amount to a total of approximately 12 homesteads, within a stones throw of
my property, some of which are on the boundary of Capel Dewi Uchaf, having
been built since the early 1980's. As you will see from the included time line list. I
have been endeavouring to release the land in question since 1988 for
development to no avail the land has not been used for around 60 years as it is
not fit for agricultural use. There is a strong case to say that the boundaries of
the village have NOT been properly defined.
Please note inclusion of plan of the above mentioned properties not included in
the LDP.
I see no reason why this application should not be noted as overlooked in the previous
UDP/LDP and processed as such.

Please see the sustainable appraisal to go with this application

Include site within 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/088/003, seeking the allocation of their land for future residential development within the
defined settlement limits of Llanfihangel-ar-Arth as part of the Replacement Local
Development Plan. The Candidate Site is edged red below in Plan A.
Plan A
The Candidate Site comprised of a single enclosure, with its eastern boundary fronting onto
the adjoining public highway, from which access to it was gained. Its remaining boundaries
are equally as well defined through a combination of existing hedgerows and residential
properties.
Following its due consideration, the Council then excluded the Site from the proposed
development limits for Lanfihangel-ar-Arth 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:
“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.”.
At the time of publication of the 1st Deposit LDP therefore, the principle 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 settlement 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:
“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.”
As can be seen, the rationale of the Council for the exclusion of the Site as an allocation in
the LDP has remained the same. This is somewhat puzzling and illogical. In terms of
‘alternative sites’ in the 2nd Deposit LDP, Llanfihangel-ar-Arth has only one small allocation
(SuV39/h1) being put forward. It should be noted that this site has been allocated since the
adoption of the Carmarthenshire Unitary Development Plan (2006) and with the withdrawal
of a recent longstanding outline planning application that failed to satisfy the new phosphate
regulations, it is difficult to understand the Council’s logic that there are either ‘sufficient’ or
‘more suitable’ sites in the settlement to deliver new housing. The truth of the matter is there
are none.
Following on from the above, the number of units proposed to be accommodated by
allocation SuV39/h1 (7) does not seem to have taken on board the requirement for on-site
provision for phosphate provision, which can amount to up to 25% of a development site’s
area. (Please see accompanying Site Layout plan for site at Heol Hathren, Cwmann). This
further confirms that the decision of the Council to not allocate the land on housing supply
basis seems an extremely erroneous decision, particularly in terms of (a) the sustainable
attributes of the settlement and (b) the number of undeliverable allocations being put forward
by the 2nd Deposit LDP and so further sites are required (see below).
The second reason given for the exclusion of the site is completely illogical and inconsistent
with other decisions taken by the Council in the preparation of its 2nd Deposit LDP. As can be
seen form the accompanying Candidate Site Report, the settlement of Llanfihangel-ar-Arth is
a settlement who’s growth has extended along its principal routes of access. The Alternative
Allocation follows this pattern and its development would provide a defensible line with
respect to the northern portion of the village and the open countryside beyond. Contrary to
the Council’s view, it is clear therefore that the development of the Site in question would
harmonise with the settlements existing character and setting.
On the basis of the 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.
In addition, we consider that alternative allocations within the wider Cluster that Llanfihangelar-Arth forms part of (discussed below) 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 therefore supplements the following documents, which comprise
a complete submission to the 2
nd Deposit LDP Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Integrated Sustainability Appraisal form
- Copy of Candidate Site Submission Report (August 2018)
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 not allocate the
land in question and understand that this may be because the Council holds the view that
alternative allocations within the wider Cluster 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 Cluster 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 Cluster 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
SeC12/h1 Trem y Ddol, Newcastle Emlyn 17
SeC12/h3 Land to r/o Dolcoed, Newcastle Emlyn 20
SeC13/h1 Adjoining y Neyadd, Llanybydder 10
SeC14/h1 Blossom Garage, Pencader 20
SeC14/h2 Land adj. Maescader, Pencader 24
SuV33/h1 Land opp. Brogeler, Llangeler
SuV28/h1 Maes y Bryn, Capel Iwan 6
SuV39/h1 Adj. Yr Hendre, Llanfihangel ar Arth 7
Su41/h2 Cilgwyn Bach, Pontyweli 14
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

Request of Re-assessment of Candidate
Site Submission
At land to the North-East of Ael y Bryn,
Carmarthen

1. Introduction
This report has been prepared in support for the inclusion of land which is to the northeast of Ael y Bryn, Carmarthen which is located on the edge of the settlement of Carmarthen.
2. Site Details
The potential candidate site is located on the edge of the settlement of Carmarthen. The
site currently adjoins the settlement boundary of Carmarthen. The land currently is used
for pasture by the proposer of this site. There are currently no structures or buildings
within the parcel of land. The site is located adjacent to the cul-de-sac of Ael y Bryn.
3. Proposed Use of the Site and it’s Deliverability
The site is proposed to be allocated for residential housing purposes. It is the aim of the
land owner to provide a housing site for around 25 dwellings for local people. It is aimed
that once this land is allocated for housing and included within the settlement boundary for
Carmarthen that a full planning application is prepared and submitted to Carmarthenshire
County Council. The aim is to provide housing for local people within the area with an
application submitted within 18months of the plan being adopted.
4. Site Assessment Methodology
The site is a relatively flat site that would be able to accommodate housing without
producing a visual impact on the local and wider area. As previously mentioned the land to
the east of the site is heavily wooded, largely with significantly sized conifers. These act as a
natural screen to the proposed site.
The site is a greenfield site with no history or evidence of past activities which would have
resulted in the contamination of any soils. Any development undertaken within this area
would be designed to enhance and improve the character of the area and not cause any
impact.
The site is located some distance away from any significant water course and therefore is
not identified as being liable to flood under the Natural Resources Wales Flood Maps. In
regards to the disposal of surface water, the site is sufficiently large enough to
accommodate the provision of soakaways within good ground conditions, which will be
able to drain freely with no signs of waterlogging or standing water.
The town is lucky to benefit from the provision of a public sewerage system, mains water
supply and electricity. It would be possible to connect to the foul sewerage system through
gravity linking into the sewer which is located within the public highway. If there are any

capacity issues, this could be remedied by providing private sewerage system such as septic
tanks or sustainable drainage systems. Access to all other services is readily available and
would be easily accessible to any new development within the area.
Any development on this site would involve the retention of the hedgerow and trees that
run along the site boundary to partially screen the development from the surrounding area.
There is no current evidence of any current habitats or protected species within the site.
5. Viability of the Site
The viability of the site is imminent. As previously mentioned the land owner intends to
submit a planning application on this site as soon it is adopted and included within the
settlement boundary of Carmarthen. Having family that want to move to live within close
proximity to the family home has meant that the promoter wishes to provide housing locally
to ensure the return of local people to the area.
6. Accessibility
The site can be accessed from the existing cul-de-sac Ael y Bryn. This would be adequate to
provide regular vehicle use and would have the provision to be widened to provide a
footway as required. Visibility splays to comply with current standards from vehicles
emerging onto the public highway are good in both directions.
7. Sustainability
The potential candidate site is immediately adjacent to the settlement limit as identified
and defined by the Local Development Plan. The extension to the settlement limit at this
location would provide an appropriate location for rounding off the settlement boundary to
provide much required residential properties within the area.
Carmarthen is served by good public transport bus services which operate through the
town and County, with a bus stop located in close proximity. Bus routes provide links to
Carmarthen, Swansea and beyond. There are good cycle facilities to surrounding
settlements, and there is also an extensive footpath network available within the locality.
Carmarthen offers and extensive range of facilities, such as shops, offices, industrial units,
community facilities, education facilities from primary schools, secondary schools and
further education collages, medial and pharmacy facilities.
8. Conclusion
In conclusion, this site is believed to be a perfect site for inclusion within the Local
Development Plan to allow for further residential properties within the locality for local people. In a climate where there are not enough housing available, it is considered that the
authority should re-asses their assessment of this site and consider it’s inclusion due to the
land owners being keen in developing the land.

Include site within the Plan

I should be grateful if the inspector would consider reinstating the Pendderi Road land, shown coloured blue on the attached plan, into the County’s Revised Development Plan 2018-2033. My request is based on the fact that a number of opportunities to dispose of this land to developers for residential development have failed for reasons entirely beyond our control. I attach three pages (Document1) which provide an explanation of what has happened in each interest and it is felt that reinstatement of our land into the LDP will provide assurance and help progress matters with these developers.

Include site within the Plan

Land between Ffrwdwen and St Annes Avenue.
Letter seeking a change to the draft LDP 2018 -2033 – a request to carry forward SC18/h4 from the current LDP into the 2018-2033 LDP (land between Ffrwdwen and St Annes Avenue, Cwmffrwd, Carmarthen.) 2nd Deposit February 2023.
In reference to LDP consultation in the village of Cwmffrwd please consider the following pertinent points in support of this application.

Planning / housing stock.
1. The land between Ffrwdwen and St Annes Avenue, Cwmffrwd, Carmarthen is allocated within the current Local Development Plan (LDP) for residential use with the reference SC18/h4. It is therefore reasonable to believe that as a competent authority Carmarthenshire County Council (CCC) undertook a due diligence process - involving all relevant departments - at pre-allocation stage of drafting the current LDP to ensure that the site was deliverable in all aspects. To be of value the LDP process must allocate sites upon their merits of delivery without significant burden to the Developer or indeed be reliant upon third party land take that could prevent delivery. The principle of development has already been established by a LDP process.

2. The current LDP has been considered to be sound.

3. The site currently sits within the “Development Limits” that have been drawn up by CCC for the village of Cwmffrwd.

4. SC18/h4 is approximately 1.1 hectares in size with a current allocation for 23 units. The current LDP Inset Map (Figure 1) is provided below.

5. Other opportunities to build homes within Cwmffrwd are very limited. This site is now considered to be the premier location within Cwmffrwd to develop.

6. The site has little agricultural value due to the unfavourable soil type. The enclosure is best described as vacant land.

7. It is well documented that there is a chronic national housing shortage, and the provision of these houses would go some way to contributing to both the local and national target for new build homes. An under supply of desirable, modern, energy efficient housing fundamentally underpins the growth of an area. The upward pressure that the lack of housing within an area puts on house prices often displaces local young families to seek less amenable properties further afield.

8. The construction and habitation of new homes will provide significant annual income to Carmarthenshire County Council, Dyfed Powys Police Authority and Llandyfaelog Community Council through Council Tax revenue (upwards of £40,000 per annum). It is expected that the money derived from Council Tax would be a welcome addition to funding and bolster both the Council and Police Authority finances during the lifetime of the properties.

9. Demand for good quality housing both within Carmarthenshire and at a national level currently outstrips supply. This development will not only provide an opportunity for first time buyers to get onto the property ladder but also allow families already on the property ladder to move up the rungs thereby creating a turn-over of housing stock within the marketplace.

10. The Office for National Statistics (ONS) has recently reported that the UK population is projected to rise by 2.1 million to 69.2 over the decade to July 2030: this would be a 3.2% increase (see ONS website). Carmarthenshire shall need to a house a proportion of this increase.

St Anne’s Lane.
11. St Anne’s Lane is generally of straight horizontal alignment which provides good forward visibility. With CCC being a competent authority it would be correct to believe the intensification of St Anne’s Lane would have been assessed during the previous LDP allocation stage.

12. As no footpath currently exists at the eastern section of St Anne’s Lane then it is anticipated that as part of pedestrian improvements a footpath shall be provided to join the pavement that exits at Ffrwdwen and the A484.

13. R, H and D Jones have already commissioned Asbri Transport Limited to produce a Transport Technical Note. Page 20 of the Transport Technical Note states:

“These highway improvements will provide a betterment for existing and proposed
residents of St Anne’s Lane”


14. Paragraph 5.1.5 of the Transport Technical Note (p21) goes on to state that,

“there is no material harm in terms of highway and pedestrian safety associated
with the proposed development”.


15. This Transport Technical Note dated 11 May 2022, shall be presented at the hearing.

16. In line with the Welsh Government’s strategy to reduce traffic speed within residential areas and introduce a default 20mph speed limit on restricted roads in Wales, on the 7th February 2023, Carmarthenshire County Council published a consultation document to enable residents to comment on such proposals within the County. As can be seen from the Figure 2 below, Carmarthenshire County Council propose that this section of St. Anne’s Lane becomes a 20mph zone when the new default speed limit comes into effect on the 17th September, 2023.

17. If this 20mph zone is adopted as expected then this will further enhance road user and pedestrian safety along St. Anne’s Lane, and further reduce the visibility requirements.

18. A Swept Path Analysis for SC18/h4 has been undertaken by Roger Casey Associates Ltd. The proposed access into the site has been designed to accommodate a 10.3m refuse collection vehicle with an internal carriageway width of 5.5m and 1.8m wide footways.

19. The Swept Path Analysis dated June 2022 shall be produced at the hearing.


Employment / Economic Growth.
20. The addition of up to 23 new homes may secure the future and provide a reason for employment growth of several businesses that operate within Cwmffrwd. These existing businesses include a car garage, a children’s nursery and a milkman. A florist, another children’s nursery, a van hire business, a bridal boutique and a garden machinery business also trade from premises within a 1Km radius of the site. There are also numerous self-employed tradesmen within the locality and it is predicted that the provision of these dwellings may assist the viability of these local businesses.

Education.
21. The construction of 23 dwellings would yield a sizeable financial contribution towards local education provision via a s106 agreement (circa £25K).

Site specifics.
22. The design and development of the site will adhere to all current Building Regulations and requirements.

23. R, H and D Jones have commissioned Hammond Architectural Ltd to create an indicative site layout plan for 23 dwellings. The drawing indicates that all 23 units can easily be accommodated on the proposed site together with an area for ‘Sustainable Urban Drainage’ (SUDS).

24. The indicative site plan produced by Hammond Architectural Ltd during February 2022 shall be presented at the hearing.

25. Cwmffrwd is a desirable village due to its proximity to Carmarthen. It is envisaged that due to the level of demand for new homes in and around Carmarthen, some- if not all – of these proposed houses will be purchased “off plan”.

Environmental.
26. Due to advancements in energy efficient materials and construction techniques the homes will be built to an enhanced environmental standard with greater energy efficiencies and a lower carbon footprint than older housing stock.

27. Natural Resources Wales have no objection to the site being developed. Evidenced by letter dated 4 October 2022 that shall be presented at the hearing.

28. The site is not on a floodplain.

29. The site is not within a Special Site of Scientific Interest (SSSI).

30. The site is not designated a Special Area of Conservation (SAC).

31. The site is not contaminated with solid or liquid waste.

32. The site has already been checked for the presence of protected flora and fauna including dormice and bats. Separate Dormouse and Bat surveys have been undertaken by I+E Ecology Consulting Ltd. In both cases the surveys concluded that the habitat was not conducive to these species, and development would not be detrimental to the conservation of these protected mammals. Both these surveys shall be presented at the hearing.

33. A tree survey has been undertaken by Arboricultural Technician Services Ltd during September 2022. The survey confirmed that no trees were present on SC18/h4. This survey shall be presented at the hearing.

34. During February 2023, R, H and D Jones commissioned I+G Ecology Consulting Ltd to produce a Reptile and Amphibian Mitigation Method Statement. This method statement recommends that any site clearance is undertaken in a phased approach with gradual and stepwise reduction in potential reptile habitat in order to encourage natural reptile dispersion from the site. This method statement shall be presented at the hearing.

35. Odour, dust and noise will be kept as low as reasonably practicable during the construction phase to minimise any detrimental impact and inconvenience to dwellings and residents within the vicinity by adherence to industry best practise and guidelines.

Transport.
36. A detailed Transport Technical Note accompanies this application with the inclusion of both strong and favourable conclusions.

37. Cwmffrwd benefits from being on a bus route that is regularly serviced. This mode of public transport allows people to travel easily and quickly into Carmarthen, Llanelli and many other villages within the district.

38. Carmarthen is accessible from Cwmffrwd by an established continuous footpath.

39. A well-used cycle path runs through Cwmffrwd and onto Carmarthen.

40. An Automatic Traffic Count took place St Anne’s Lane during September 2021. This survey revealed that the mean two-way measured speed is 18.3miles per hour. The 85th percentile speed is 24.4 miles per hour, based upon a total of 979 vehicular movements over 7 days. This report shall be presented at the hearing.

41. No known traffic accidents have occurred along St Anne’s Lane.

Utilities.
42. All utility services are available close by. Dwr Cymru Welsh Water have advised that there is capacity within their network. This is evidenced by a letter from Dwr Cymru Welsh Water dated 24 July 2022.

43. Internet connectivity within Cwmffrwd is very good and this feature will definitely assist individuals who “Work from Home” and children’s educational needs.
Social.
44. It is possible that occupiers of these proposed new homes will use St Anne’s Church Hall for social functions and may become members of either of the two Places of Worship that exist within Cwmffrwd – namely St Anne’s Church and The Seventh Day Adventist Church. Both these Places of Worship are considered hubs within the community and it is predicted that each church would welcome new membership in order to secure the future of each.

45. Due to the quality, spacing and relatively low number of these new homes it is likely that this proposed housing development shall probably increase the value of neighbouring properties rather than devalue them as Cwmffrwd will be considered by many as an “aspirational village” where people would like to live.

The library of documents referenced above give strong evidence that SC18/h4 is already a live site whilst the paragraphs support our application that this land should be carried forward as a housing allocation into the next Adopted LDP.

No change.

SR/019/008
CA0775
Capel Iwan

This site is proposing to change its status to residential. This would be detrimental to Capel Iwan. This site is outside the development boundary listed for Capel Iwan - June 2011 SC7.

This proposed change of status would be detrimental to the village of Capel Iwan.
The site is outside the development plan boundary.
There are no amenities in the village to accommodate a potential increase in population therefore more traffic would be expected.
The existing roads are narrow single track with numerous blind corners - long standing hedges may be removed.
There are already existing building plots in the village with building permission that have land dormant for some years.
Any development on this plot would reduce the absorption of rainfall causing more water run-off overloading the already stretched sewage system and potential for flooding.
The reduction in grassfields is known to reduce the absorption of carbon dioxide from the atmosphere - A factor which is becoming an increasing concern.
An increase in building development would alter the village environment - It being a quiet rural area which already has seen a significant increase in traffic as shopping habits have changed.

Amend the plan to include the site

We are instructed by Ms D England and Mr D Davies to make a formal representation to the
“soundness” of the Deposit Draft of the Carmarthenshire Local Development Plan.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/149/010, seeking the allocation of their land for future residential development within the
defined settlement limits of Saron as part of the Replacement Local Development Plan. The
Candidate Site comprised of two single existing enclosures, accessed directly off the
adjoining public highway on its northern boundary. The enclosures are then well defined,
with existing residential development to its north, east and to a degree west. The site is also
within close proximity to the range of community facilities and local services the settlement
has to offer.

The Council have published a “Site Assessment Table” (January 2020) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our Client’s submission, the reason why the site was not selected for allocation for
residential development purposes within the draft settlement limits of Capel Hendre, as
contained within the Deposit Draft.

We note that the submission successfully passed through Stage 1 (site compatible against
the location of future growth presented in the Preferred Strategy), Stage 2A (Initial Detailed
Site Assessment), Stage 2B (further detailed site assessment) and Stage 3 (Sustainability
Appraisal and Habitat Regulation Assessment). However and despite passing each stage of
the Council’s assessment, the Authority determined not to allocate the site for residential
development for the following single reason:
“There is sufficient and more suitable land available in Saron to meet its housing needs.
We however consider its exclusion to be an erroneous decision by the Authority and
consider therefore that the LDP is “unsound” and should be changed, as it fails to meet the
tests for “soundness”, in that the Plan “is not appropriate”, and “will not deliver”, as defined
by the Planning Inspectorate’s LDP Examinations Procedural Guidance.

Specifically, we consider that alternative allocations within the settlement and wider growth
area are neither appropriate nor deliverable. We consider therefore that the land edged red
in Plan A below, should be allocated for residential development under the provision of
Policy HOM1 of the Carmarthenshire Local Development Plan.

Plan A

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

- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
- Copy of Candidate Site Submission Report
- Copy of Transport Statement

Response to Council’s Reasons for Non-Allocationof Site
Sufficient Residential Land Allocated Within Settlement
The Council consider that the allocation of the site for the purposes of residential
development is unnecessary due to their view that alternative allocations within Saron and
the wider growth area (Cluster 3) it forms part of will deliver sufficient housing for the town.

Under the current provision of the Deposit LDP, Cluster 3 has a range of proposed
residential allocations. Having considered each one in terms of its sustainability level,
technical deliverability and recent planning history, we consider that a number will not be
brought forward during the Plan period and so will result in the Plan being unsound if it is
adopted in its current form. These proposed allocations are listed below and now
considered:

Ref. No. Site Name Units
PrC3/h4 Tirychen Farm, Penybanc 150
PrC3/h9 Land adjacent to Maesyrhaf 9
PrC3/h10 Land to the rear of Gwernllwyn, Cross Hands 30
PrC3/h14 Nantydderwen, Drefach 13
PrC3/h20 Land north of Maespiode, Llandybie 42

Table 1

Allocation PrC3/h4 is currently allocated for 150 residential units. Planning permission was
last granted in 2014 for 289 dwellings, under Application E/21633. However, that permission
was only granted in outline form. It subsequently lapsed, and the landowners sought to vary
conditions upon that permission to extend the validity of the outline permission. That
Variation of Condition application was finally approved in October 2019, under Application
E/38686.

A Phasing Plan has been introduced, which proposes that a first phase of 50 dwellings be
brought forward with full details to be submitted within two years of the date of the above
variation approval. The remaining phases are shown as long-term proposals, with details not
required to be submitted for up to a further five years.

The recently approved Variation of Condition permission does little to display any real
progress in the deliverability of the site. It merely amounts to the landowners seeking to
continue to benefit from an outline planning permission at the site. Full planning permission
was granted as far back as 1992 (D6/19332), which subsequently lapsed. The Land
continued to be allocated within the Dinefwr Local Plan (1996), and subsequent
Carmarthenshire Unitary Development Plan (2003). No progress was made in bringing the
site forward, and yet it was allocated within the Local Development Plan in 2014.

Consequently, thirty years of Development Plan allocations have elapsed without any signs
of delivery of this site – not a single new housing unit has been constructed on the site in
that time. More physically challenging sites, such as the re-development of the Betws
Colliery site have come forward long before Tirychen, and yet still the Council is prepared to
allocate the site once again in a new Development Plan despite clear doubts over its
deliverability within the Plan period.

The Council has seen fit to re-examine housing land supply and residential land availability
in preparation of this draft LDP, and ultimately decided to omit various sites that were
allocated in the 2014 Local Development Plan, from the new Deposit Draft. Those sites
include “Heol Ddu” at Tycroes (LDP site GA3/h23) which was allocated for 150 units, and
also had an outline planning permission. However, the Council now consider that a
residential development will not be deliverable on the site.
The decision to retain Tirychen
Farm after a period of 30 years within the LDP is shown to be even more inconsistent, and
does not sit with LDP Procedural Guidance which encourages Local Planning Authorities to
only re-allocate sites based upon firm evidence of deliverability. The allocation of the site for
residential development is therefore clearly unsound.

The above trend of re-allocating undeliverable sites continues then through the other
allocations highlighted in Table 1 above. Each of these has seen consents granted on them
some time ago, but each has seen little or no evidence of any development since these
approvals were issued. Table 2 provides a summary of this information.

Allocation Name Units Planning History
PrC3/h9 Land adjacent to Maesyrhaf 9 S/01815 – Full (10 Units) – 09/09/1999
S/13257 – 10/07/2006 – Extended existing time limit of S/01815
S/22921 – 01/04/2011 – Residential Development
S/35926 – 08/082017 – Construction of 9 dwellings
PrC3/h10 Land to the rear of Gwernllwyn,
Cross Hands
30 W/29164 – Outline 28 Units – 12/11/2013
PrC3/h14 Nantydderwen, Drefach 13 W/20230 – Full (33 Units) – 14/11/2008
PrC3/h20 Land north of Maespiode,
Llandybie
42 E/21328 – Full – 23/06/09
E/22540 – Full (1 Unit) – 25/2/10
E/26446 – Full (4 Units) – 17/04/12
E/39129 – Full (2 Units) – 12/07/19

Table 2

As can be seen, despite each having historic consents, often repeated through extension of
time applications, each of the above application has still failed to deliver a significant level of
housing for the growth area in question. Combined with the failure of the Tirychen Farm
allocation to deliver any units, the historic under provision of these sites has resulted in a
deficit of almost 250 units being delivered for the benefit of the local community they should
serve. Each clearly has significant questions over its deliverability and genuine availability for
development. To continue to allocate such sites for residential development therefore 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 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 reason put forward by the Authority for its exclusion and has identified 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.

Allocate the whole of candidate site SR/067/004 for housing within the Revised LDP.

CARMARTHENSHIRE LOCAL DEVELOPMENT PLAN 2018-2033

CANDIDATE SITE SUBMISSION

PROPOSED RESIDENTIAL ALLOCATION ON LAND OFF CEFNEITHIN ROAD,
GORSLAS, CARMARTHENSHIRE.

MANNOR HOMES LTD.

CONTEXT DOCUMENT

A site of 17.5 acres, largely overgrown and with a covering of large areas of scrub, self seeded
saplings and undergrowth, but Willi some 2.4 acres centrally located on its northern (roadside),
boundary occupied by an established scrap metal and breaker’s yard. That northern boundary
follows the line of Cefneithin Road, which for its greater part is fronted by established residential
properties, and also the entrance to a major comprehensive school. There is a fall in levels across
the site from north to south, being the shallow, western valley slope‘of the Gwendraeth Fawr
which meanders along the site’s southern boundary.

The Local Planning Authority have not previously questioned the sustainability of the site’s
location, and Gorslas in itself is a bustling community, effectively extending from Cross Hands
(immediately to the south), but with its own identity. Extensive employment, retail and social
activities are within cycling/walking distance, as are the local primary and comprehensive schools
and local playground, whilst a number of local bus routes traverse Cefneithin Road and Cross
Hands Road. The extant Development Plan identifies Gorslas as part of the Ammanford and
Cross Hands Growth Area and the potential to accommodate growth is reflected in the Plan’s
housing allocation of over 340 new dwellings in Gorslas and Cross Hands during the 2006- 2021
plan period. The majority of this allocation having been taken up.

Historically (since the 1960’s), and sited as it is in close proximity to an exclusively residential
area containing both a primary school and the entrance to a secondary school, the presence of a
large scrap metal and breaker’s yard, its appearance (when in full operation stockpiles of scrap
were clearly visible from the A48), noise, dust (see accompanying Geotechnical Report), and the
numbers and type of vehicles it generates (see accompanying Transport Statement) has been an
intrusive element for residents and a source of concern.

It is valued in the trade as it has an absence of planning conditions relating to hours of operation,
working capacity, machinery, height of stockpiles, etc. whilst at its busiest it generated heavy
vehicles transporting scrap metals and materials in and out which would queue at times along
Cefneithin Road almost to Gorslas Square. With a new road network and additional new housing
in place around Cross Hands, a significant number would now be likely to travel past residential
properties and the entrances to the new schools.

Residents’ antipathy to the scrap metal business was further charged in May 2002 when the yard
erupted in a series of small explosions and a major fire raged for nearly a week, closing the A48
for half a day before being extinguished. No matter how well operated there is always the
possibility of combustion or pollution with such a potentially volatile facility, and indeed in early
2020 there was a further on site fire.
Environmentally, visually, and in temrs simply of public health and safety, the location of the
scrap metal yard is not appropriate in close proximity to numbers of residential properties and
to local schools. The Local Planning Authority has clearly recognised this in the past, and thus
the operational scrap yard site is currently the greater part of an undeveloped 6.2 acres (in single
ownership) of a residential allocation identified in the extant Local Development Plan. This land
could not have been brought forward for residential development until recently, as the landowner
had been unable to secure vacant possession from a long lease to overseas operators. The lease
has been retained despite the fact that the operators had not been successful in the British market
and had ceased trading, but can be relinquished when either party serves notice.
Undoubtedly there is a business appetite for a local scrap metal facility largely unfettered by
planning conditions, and if the current Local Development Plan submission is not successful it
is likely that business operations will recommence. Whilst the viability of developing just the 6.2
acres currently allocated for residential development is currently being examined, land remedial
costs to enable residential development, coupled with social and development contributions and
recognition of ecology interests, currently render the site of questionable viability.
Historically, locationally, and environmentally therefore there is a clear case justifying the
allocation of the proposed site for residential development. The Indicative Layout, Drainage
Strategy, and Transport Statement forming part of the original Local Development Plan
submission in August 2018 have not, been challenged and presumably therefore are deemed
acceptable in principle. The Site Layout then put forward a proposed development of up to 150
dwellings over 13.22 acres (75.4% of the whole site), whilst in recognition of the identified
ecological interests the remaining 4.82 acres (24.6% of the site) , were retained, undeveloped,
alongside the periphery of the land and the river.
In the interim, a combination of factors have influenced amendment to that original submission,
including;
*an increasing awareness of the significance of the Caeau Mynydd Mawr SAC and general
ecological interests.
*changes in working practice in respect of soil treatment, resulting in a reduction in potential
decontamination costs.
* an increase in the gross development value of the proposal being brought forward.
Consequently, the proposal has been revised to the provision of up to 120 dwellings on 10.44
acres (60% of the site area), and the retention of 7.1 acres (40% of the site) for its ecological and
amenity interest. The majority of the land proposed for development comprises the existing
scrapyard (brownfield), and that other land currently allocated for residential development in the
extant Local Development Plan. The applicant is prepared to work fully with the Local Authority
to safeguard and enhance the proposed 7.1 acres, and if required is prepared to gift it to the
Local Authority to ensure its protection.
Nevertheless, the two reasons cited by the Local Planning Authority for not including this land
as a residential allocation referred to;

a) The adverse effect upon ecological interests

b) A questioning of the site‘ 5 deliverability

In February 2020 and in light of the sigrificant environmental and safety improvements that
would accrue to residents from removal of the scrapyard, a request was made to the Local
Authority that the applicant’s retained ecological consultant meet with the Local Authority‘ 5
ecologist to seek common ground. This was denied as; “.... There would be little merit for a
meeting at this stage...” If this is such an important site in the County in terms of biodiversity it.
was assumed that a meeting with the landowner would have been of merit at any stage or time.
That attitude was surprising and extremely disappointing, especially in the light of the Revised
Local Development Plan Policy NE2 Biodiversity, which requires “ Development proposals to
maintain and enhance biodiversity in accordance with Section 6 of the Enxironment (Wales)
Act” It is understood that an appropriate level of mitigation measures should be introduced as
part of any application for development, and in this case they would be significant - but the Local
Authority’s ecologist refused to even discuss the likely requirements. What is clear is that clear
and appropriate conditions on any development can mitigate and enhance biodiversity interests.
The frustration the applicant has felt is in the fact that the local Authority has declined to discuss
this matter until apparently it is almost too late, and the site is formally proposed to be omitted
from the residential allocations.
A detailed Biodiversity Appraisal formed part of the original site submission in 2018, identifying
ecological issues on the site and proposing appropriate solutions — assuming the presence of all
species to be surveyed for - thus demonstrating the applicant’s recognition of the site’s character.
There has been no suggestion that these proposals have even been looked at, and certainly no
questioning of the applicant or the retained ecologist The applicant has no recollection or
knowledge of any representative of the Local Authority entering upon the land or undertaking a
season long ecological survey before, or in response to the site submission. A full and thorough
survey of the whole site for the whole season was undertaken through to November 2020 by the
applicant’s ecologist, and is being repeated in 2023 so that a completely accurate picture can be
produced. It is at that time that the appropriate levels of management, mitigation and/ or
compensatory measures can be established, and the feasibility of the appropriate level of
development can be established. Given the significant level of environmental enhancement that,
the local residents would benefit from if the scrap metal and reclamation yard were removed, it.
would be inappropriate that is established

A further, apparently illogical frustration is that whilst the core of this site is a potentially
dangerous brownfield use which is totally inappropriate in in a residential setting, the Local
Authority does not see fit to utilise it as a residential opportunity, but instead are proposing an
incomprehensible situation wherein agricultural pasture, a pleasant, greenfield site (PrC3/h12)
directly opposite the established entrance to the scrapyard, is newly allocated in the Deposit Plan
for 29 dwellings. Quite what the future occupants of these dwellings (along with the many others
nearby), will make of the activity, the noise, the smell, and the heavy traffic, should the scrapyard
re-open? It is of course normal planning practice to prioritise the re-use of brownfield sites in
preference to greenfield, and yet further to the west, also on the opposite flank of Cefneithin
Road (PrC8/hl2), is also a proposed greenfield site of 12 dwellings.

Finally, the cited Inatler of doubt over the deliverability is bewildering and of unknown source of
origin. The lease to the tenant Sims Group UK Ltd, ended in December 2021, and although
they have currently vacated the site they continue to pay rent. As a result, although the original
contractual term has ended, the lease continues until either party serves notice.

Attached:

Candidate Site Location Plan

Indicative Site Layout

Transport. Statement

Biodiversiw Appraisal, Checklist and Update
Drainage Strategy

Market. Valuation

Site Abnormals

Geotechnical Report

Include the site in the Plan

Land opposite Roadhouse Restaurant ,Whitland.Natural extention to adjacent commercial premises ie Roadhouse Restaurant & Ivydene Nurseries.The paddock is also surrounded by 4 houses & would be sensible infilling . The field has all sevices on site & no flood risk.It has good access to quiet B Road with good visibility & existing access.We are desperate in Whitland for sites for quality self build housing.
The site at Gerddi lingfield for 57 houses (SeC19/h3) has been fully developed & were all pre sold prior to build.The 48 allocated to Whitland creamery ( SeC19/h2) have been sat on for years & is also on the flood plain.People in the village are desperate for new homes & are often forced to move to St Clears where allocations for development seem unfailry generous compared to Whitland.
I have attached plans showing the proposed candidate site

Allocate the site for housing within the Revised LDP.

CARMARTHICNSHIRIC LOCAL DEVEIKH’MEN'I‘ PLAN 2018 - 2033

CANDIDATE SITE SUBMISSION II

PROPOSED RESIDENTIAL ALLOCATION ON LAND AT WATERLOO ROAD,
PENYGROES, CARMARTHEN SHIRE.

MANNOR HOMES LTD.

CONTEXT DOCUMENT

This is a greenfield site of 4762 sq. metres of improved pasture abutting the rear garden
boundaries of recently constructed dwellings fronting the eastern flank of the B4297 Waterloo
Road, and also abutting the rear garden boundaries of properties on the southern flank of
Bryndedywddfa, Perrygrocs. The land falls gently to the north eastern corner.

Full planning permission was granted across the road frontage of the field for “ the erection of .1
dwellings and a compensatory ecology area,” on :13” February 2019. Three of the dwellings have
been constructed and are occupied, whilst the fourth plot remains undeveloped in order to
provide appropriate width for a vehicular access of adoptable standard into the site subject of this
submission. The proposed vehicular access lies within current development. limits.

Otherwise, there is an entirely built up frontage in both directions along this flank of the classified
road which forms the north/ south highway axis through Penygroes, whilst the northern boundary
of the candidate site adjoins the rear wall/fence line of the established residential properties in
Brjndedrwddfa. To the south lies the extensive garden area of the detached dwelling named
Garnllywd, separated from the candidate site by a drainage ditch, and screened by a line of self
seeded trees and scrub. The Transport Statement, the Biodiversity Appraisal and Checklist, and
the Drainage Strategy, all of which are submitted herewith, all indicate that, there are no issues
which would prevent development,

Mannor Homes are a small, local building company with all its employees and sub contractors
living in, or close to, Penygroes. The three dwellings completed to the front of the submission
site are of quality, with high levels of sustainability, and the company has received many enquiries
from local residents about the possibility of purchasing further properties (particularly retirement
bungalows), on the land to the rear. As will be demonstrated in this Statement there is no site in
or near Penygroes that caters for such local needs.

In the context of the extant Local Development Plan the site immediately adjoins the current
defined development limits of the Ammanford and Cross Hands Growth Area (GA3). As an
acknowledged growth area with good access to the A48 corridor, there was a substantial allocation
of 2552 residential units over the plan period. Given its extremely convenient location, with
excellent accessibility not only to the A118 and A476, but also to local employment, retailing and
educational opportunities, sites in and adjoining Penygroes had an allocation of some 250 new
dwellings within the current Local Development Plan, and for the plan period 2006 2021.

The 2nd Deposit Revised Carmarthenshire Local Development Plan 2018-2033 — Proposals
Map appears to address the need and the suitability of sites for new housing in Penygroes with a
total allocation of some 293 new dwellings. However, just, 5 years into the plan period;

PrC3/h23 Land at Waterloo Road allocation 13 dwellings — completed

PrC3/h24 Land between 123 and 137 Waterloo Road allocation 7 dwellings - completed

PrC3/h25 Land off Gate Road allocation 8 dwellings — completed

PrC3/h35 Land at Clos Penpont allocation 9 dwellings - completed

The only allocated sites that still retain potential for development during the plan period are;

PrC3/h22 Adjacent to Pant y Blodau, allocation 79 dwellings, 0 built, and

PrC/MU1 Emlyn Brickworks allocation 177—9 built.

Examining both these sites;

PrC3/h22 Adjacent to Pant y Blodau

This is located almost directly opposite Mannor Homes candidate site 011 the lacing Flank of
Waterloo Road, the greater part of the land being in the ownership of a large building contractor
from outside the area. An original full planning application (Ii/22.1189) for 79 dwellings on part of
the proposed allocation was refused permission by the Local Planning Authority in February
2013 as, amongst, other reasons, there were concerns of the affect a single development of this
size would have on the character and culture of the area and the Welsh language in Penygroes.
This decision was supported by the Planning Inspectorate on appeal.

A second, almost identical application (E29910) was subsequently granted planning permission
by the Local Planning Authority despite there being no reduction in number of dwellings . This
was approved in April 2015. In what would appear to be 2m act seeking to “safeguard” the full
planning permission the developer has made what it regards as a “start.” to development. The
validity of such a “start” is strongly disputed as;

a) In an obvious (failed) attempt to lay, (or at least, appear to commence to lay) the access
road into the site, a lorry load or two of tarmacadam has been tipped and rolled on the
line of the access road. No kerb lines, pavement, etc. have been formed From its
appearance it. will need to be removed and properly reconstructed if and when work starts
in earnest. It is clearly an artifice, and it is hoped the Local Planning Authority have not
been fooled into conceding a commencement on this basis. No other “proper”
commencement appears to have been made, in which case the planning permission on
which the site relies would have expired in 2020.

b) In any event. there are at least 1'1 conditions of the planning permission (nos. 11, 12, 141
and 17), which require tasks to be undertaken prior to the commencement of any
development. Thus unless these conditions Were fully complied with beforehand, the
laying of tarmac cannot be held to be a start.

If this is the case, and it, must be ascertained by the Local Planning Authority, then the
planning permission expired in 2020, and there is no commitment to carry the land forward as a housing allocation. It must be noted that the figure of 79 dwellings refers only to the area of the proposed development that (previously) had the benefit of planning permission. The
remaining land at the road frontage of the site and now part, of the residential allocation is
shown as being in separate ownership, and ill developed at the same density could accommodate some 25 additional dwellings, resulting in a single site of more than 100 properties.

c) The development company which owns this land has been advertising it, [or sale since at
least 2015 despite stating originally that development was to start in 2017. Eight years on
the market, it, is all the more obvious that the gesture of an attempted “commencement”
was little more than an attempt to keep the planning permission alive. The previously
approved layout of this site is appallingly tight and regimented in order to maximise the
number 01‘ properties on the land. There is a demand in Penygroes, but locals do not
want this sort of~ development which is more akin to an entirely urban environment.
Taking up as it does, an extremely significant percentage of the housing allocation
remaining for Penygroes over the next 10 years it should be removed as a housing
allocation and be replaced by several smaller sites more appropriate to the settlement.

PRc/MU1 Emlyn Brickworks

The original allocation of this site, following on from a reclamation project is fully understood. It is previously developed or “brownfield” land relatively close to the crossroads axis of Penygroes. However, the first outline planning permission on this extensive site, (E/02150) for;

“reclamation of site for industrial, warehousing, commercial and residential development”, was
approved on the 26”" April 2000.

Subsequently, there have been several applications (all approved) [or extension of time to submit, approval of reserved matters, and indeed latterly for approval of some reserved matters (also all approved) .

The only residential development that has actually taken place in the 23 years since outline planning permission was first 0ranted is the construction off) bun allows adjacent to the northern boundary of the site, approximately 9-10 years ago.

As a third party we have no knowledge as to why there has been no further development of this site, but, only 9 dwellings in 23 years have been built, and it is now proposed as an allocation of 177 dwellings during the plan period 2028-2033. This appears incomprehensible to rely on a site which has shown such desperately limited progress over 23 years to supply such a huge
percentage of the acknowledged requirement for Penygroes, which is obviously acknowledged
as being a “growth area. In total the Development. Plan allocates 293 dwellings during the plan
period. However, when broken down;

37 across 4. small sites have already been constructed.

79 at the Pant y Blodau site, not 1 has been constructed in 8 years since planning permission was granted, and the site has been on the market throughout that period.

177 at the Emlyn Brickworks Site, of which 9 have been constructed in the 23 years since outline planning permission was first approved

What is extremely interesting from the above is that the four small sites have been fully built out
to their capacity. This fully supports the eloquent. and knowledgeable comments in this
submission’s supporting valuation by local estate agents Cymru Estates. As well as reflecting the
views of the Planning Inspectorate in the 2018 planning appeal on the Pant y Blodau appeal, the
character and nature of local residents and local people is such that they simply do not like
housing estate living, much preferring the smaller developments. It is understood that on
reclamation sites, particularly those in close lying Cross Hands and Gorslas, residential
development has been a funding source of schemes, but when this has not been forthcoming for
whatever reason then the Local Planning Authority must look to smaller, self funding sites.
There is clearly a case a case for reviewing and/or replacing/ adding to the proposed residential
land allocations in Penygroes — which is clearly viewed by the Local Planning Authority as a
growth settlement, and given the take -up 01‘ the four smaller local sites, popular with purchasers.
The role 01‘ the Development Plan is to provide [or 2u1d meet housing needs, especially in areas
of identified growth, and it is clear and obvious that if previously allocated sites are not being
brought. forward to meet those needs then alternative sites should be sought. For smaller
settlements such as Penygroes it is surely more appropriate in terms of desirability and
minimizing impact. that provision should be met through several smaller developments. The
candidate site put. forward provides for just six, small bungalows at. the heart. of this linear
settlement. The landowner is a local builder, and the intent would be to bring forward the site
immediately using local labour ;u1d contractors.

Attached.

Candidate Site Location Plan and land in same ownership

Indicative Site Layout

Transport Statement.

Biodiversity Appraisal and Checklist

Drainage Strategy and Review

Market Valuation

Marketing of Pant y Blodau (PrC3/H/23)

Include site in the Plan

Land adjacent to Pentremeurig Farm, Pentrehydd Road, Carmarthen

We would like the Authority and the Planning Inspector to assess the proposed housing allocation, as this will provide a natural rounding off to this area of Carmarthen. With a significant amount of housing required, it is believe that this proposed site should be included within the LDP for the next plan period

Include site within the Plan

New site: land to the East of Meadows View,
Pibwrlwyd Lane, Carmarthen

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.