Include Candidate Site SR/019/007 within the Revised LDP.

Land between Bryn & Brynglas, Capel Iwan
We are instructed by Mr K. Thomas to make a formal representation with regards to the
above land and the Second Deposit Draft of the Carmarthenshire Local Development Plan.
Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/019/007, seeking the inclusion of their land within the development limits of Capel Iwan
as part of the Replacement Local Development Plan.
The Candidate Site comprises a rectangular-shaped grazing paddock set off the western
flank of the minor road that runs north to south from the centre of the village of Capel Iwan.
The proposals seek inclusion of the well-defined enclosure to provide a modest development
of detached and semi-detached houses to complement established properties which lie
directly alongside the road off the western flank of the road. It therefore represented a logical
opportunity for infilling within the settlement and providing a much-need and deliverable
residential opportunity which can generate 9 dwellings. Its extents are illustrated by the site
edged in red, being a site location plan, at Figure 1 below.
The Council published a First Deposit Draft of the Replacement Local Development Plan in
January 2020. At that time, the Council revealed its analysis of each submitted Candidate
Site within a “Site Assessment Table” (January 2020) We noted at that time that our Clients
land was considered as part of this process and as a result the Authority concluded that the
site had successfully passed through all four Assessment Stages, being 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) of the Council’s site
assessment. Accordingly at Stage 4 the Council reported “Site to be allocated with
reference SuV38/h2”
Figure 1 – Location plan of Candidate Site at Capel Iwan
As a result of the above Council assessment, Figure 2 presents an extract of the First
Deposit LDP Proposals Map for Capel Iwan, which clearly identified part of our clients’ land
as within the defined development limits and allocated for Residential Development.
Figure 2 – Extract of Proposals Map for Capel Iwan with site included within
settlement limits as shown by a red arrow
Our clients are therefore astonished to discover that upon publication of the Second Deposit
Draft of the LDP, the Council have sought to amend the draft settlement limits, to only
include a field frontage strip within the proposed settlement limits, and accordingly
exclude the rear portion of the field. That new Draft Plan for this northern part of Capel Iwan
is reproduced as Figure 3 below. A new Site Assessment Table, dated January 2023, now
indicates that the Council conclude that “Part of the site is suitable as small-scale infill,
for the remainder of the site, it is considered that there are more appropriate sites
elsewhere within the settlement.”
Figure 3 – Second Deposit Draft extract of Capel Iwan limits at Brynglas
Our clients consider 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, our clients consider that the draft settlement limits for Capel Iwan, as defined
under Policy SD1 “Settlement Limits”, should be amended to include the land as edged
in red upon the extract of the Proposals Map for Capel Iwan, as reproduced below in
Figure 4. The land should be appropriately allocated for housing under Policy HOM1
“Housing Allocations.”
Figure 4 – Extent of Representation Site edged in red
This formal representation letter supplements the following documents which comprise a
complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits
1.0 Overall Housing Supply at Capel Iwan and Cluster 4 within Deposit Draft
1.1 The Council consider that the only reason for the Candidate Site between Brynglas
and Bryn as not being included within the draft Plan as a Residential Allocation is that
they believe that there are sufficient residential sites allocated elsewhere in the
settlement. On this basis, it must be accepted that the form of the Candidate Site set
as an infill opportunity between established properties which front the minor road
running north from the village towards Newcastle Emlyn, together with the proposals
to utilise and reform the existing vehicular access onto that C class road is deemed
acceptable, and in accord with the spatial form and character of the settlement.
1.2 The proposals under this Representation merely seek the addition of 9 residential
units to the overall housing supply of Capel Iwan, which is regarded as a Tier 3
Sustainable Village, identified within the Teifi Valley Cluster within the draft LDP.
Figure 5 below provides an extract of the indicative site layout plan for this
Representation site. The proposals can provide a mix of 3 and 4 bed detached and
semi-detached dwellinghouses about a cul-de-sac formation.
Figure 5 – Proposed Indicative Site Layout Plan for Representation Site
1.3 The Teifi Valley Cluster (Cluster 4) aims to provide an additional 218 residential units
over the Plan period to 2033, with Capel Iwan (Settlement SuV38) providing only one
allocated site at “Maes-y-Bryn” expected to provide only 6 units to that overall Cluster
total (reproduced at Figure 6 below). We would submit in the first instance that the
addition of an additional allocated site of 9 units will not lead to an over-supply of
dwellinghouses within the Cluster, nor the defined Capel Iwan settlement supply.
Figure 6 – Extract from Policy HOM1 for Capel Iwan
1.4 We have examined and researched sites which have been brought forward as
Residential Allocations with the Deposit Draft. In Capel Iwan great emphasis within
the Draft Plan has been placed upon the continued allocation of the above proposed
housing site, which is still left allocated from the 2008-21 Local Development Plan.
The above table indicates that the Council expect that site to be delivered to the
market between LDP years 6-10, being 2023 to 2028. Therefore, given that it already
benefits from being allocated in the current adopted LDP, the landowner or
prospective purchase can seek planning permission in the knowledge of its
acceptance in principle. Indeed, when questioned by the Council as part of their
formal review of Allocated Sites from the 2014 adopted Plan they reported that “The
site was submitted as a candidate site and as such, the agent has provided evidence
showing its viability.”
1.5 However, we note that no application for planning permission has ever been
submitted on the site, despite it appearing in an adopted LDP for nine years. The
site made up part of the residential allocation SC7/h2 as reproduced at Figure 7
below.
Figure 7 - Extract of Current LDP Proposal Map for Capel Iwan
and Maes y Bryn Allocation
1.6 The site was also included with the Carmarthenshire Unitary Development Plan,
adopted in 2006, and accordingly it has laid undeveloped and not subject of any
planning application for a combined total of 17 years. We will lodge separate formal
representations seeking omission of this site, as it clearly is undeliverable, and
the landowner has no intent of bringing it forward for development.
2.0 Newcastle Emlyn
2.1 We have also examined Draft Allocations within the nearby town of Newcastle
Emlyn, which is regarded as a Tier 2 Local Service Centre in the new LDP. Figure 8
below provides a snapshot of the three allocations in the town.
Figure 8 – Newcastle Emlyn HOM1 Allocations
2.2 “Trem-Y-Ddol” allocated as SeC12/h1 for 17 dwellings. The site was allocated in the
adopted 2014 Local Development Plan, and also Carmarthenshire Unitary
Development Plan in 2006. Full Planning Permission was sought under application
W/18258 for the development of “17 Dwellings, Site Layout and Access Road” in
2008. The application lay undetermined until 2022 – a period of 15 years – until it
was finally refused due to the Applicants’ failure to commit to making a contribution
towards Affordable Housing.
2.3 It is clear that to leave a planning application continue for so long without a decision
is testament to a lack of desire and commitment by the landowner to implement a
development upon the site, and accordingly it is plainly undeliverable as a future LDP
allocation.
2.4 Finally, “Dolcoed” is allocated as Site SeC12/h3, apparently capable of providing 20
new homes, in two phases over the 10 years remaining of this new Replacement
LDP. However, upon closer examination, it is revealed that there have been no
planning applications made relating to the site subject of this allocation to date.
This is despite the site being allocated in the Carmarthenshire Local Development
Plan (2014) as allocation (T2/4/h1). After a period of 10 years, not a single dwelling
has been proposed at this edge of town site, and yet the Council persist in awarding
this inability to deliver by continuing the allocation in the new Replacement LDP.
2.5 We therefore highlight that a combined total of 37 dwellings upon two sites within 3
kilometres of our client’s site at Capel Iwan have remained stagnant and their
continued allocation in a new LDP for a further 10 years is undeniably questionable.
The Council should be seeking more deliverable sites such as that promoted by our
client at Brynglas, which should be allocated in replacement of one if not all the
above three sites.
In conclusion, this Representation to the Second Deposit Draft of the Revised LDP has
sought to examine the Council’s reasons for non-inclusion of a Candidate Site.
Our clients have illustrated that their indicative proposals to construct 9 dwellinghouses will
not appear at odds to the prevailing spatial pattern of development in Capel Iwan. The
proposals will provide a modern cul-de-sac development respectful to the character and
setting of the locality.
We respectfully request that this Representation be given careful examination, and
consequently the defined settlement limits of this part of Capel Iwan realigned to include the
Representation Site, as a Residential Allocation in the Proposals Map of the adopted Local
Development Plan.

Include site within the Plan

Land at Tynewydd, Whitland.Located in the village the site forms a natural extention to the development limits of Whitland with sensible infilling within the village. The site is servived by an existing road with a sound wide junction & would provide exellent self build plots on a site above the flood plain with acess to all services nearby.
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.

Include new site within the Plan

1. Introduction
1.1. Pegasus Group is instructed by the Co-operative Group (the ‘Co-op’) to submit
representations to the Carmarthenshire Second Deposit Revised LDP consultation.
1.2. The Co-op own a Site referred to as ‘Land south of Penygroes Road, Gorslas’ (the ‘Site') and
are promoting the Site for residential development. A copy of the Site Location Plan is
enclosed with a copy of these representations (Appendix 1) and the extent of the land is
shown below:
1.3. The Site comprises an area of c. 6.5ha and is considered to be capable of accommodating
approximately 120 dwellings.1
1.4. A call for sites form was submitted to the Council in August 2019 by Pegasus Group on behalf
of the Co-op. A copy of this submission is also appended to these representations
(Appendix 2).
1.5. Representations were submitted to the Deposit LDP in March 2020 and these are
resubmitted here and amended as necessary. The Site has not been included as a candidate
site in the Second Deposit Revised LDP and we consider that it should be included as a
residential allocation for the reasons given in these representations.
1 Assuming 30dph on 60% of the site.
R002 | CE | April 2023 2
Executive Summary
1.6. These representations respond directly to the following policies and paragraph references,
as set out in the Second Deposit Revised LDP:
 Preferred Spatial Option (Chapter 8);
 Paragraph 8.20;
 A New Strategy (Chapter 9);
 Policy SP1: Strategic Growth;
 Policy SP3: Sustainable Distribution – Settlement Framework;
 Policy SP4 – A sustainable Approach to Providing New Homes; and
 Policy SD1: Sustainable Distribution - Development Limits.
1.7. Our comments on the above policies would support a higher quantum of growth to the Tier
1 settlements in the interests of making the plan more effective in delivering its key aims and
more appropriate in terms of delivering sustainable development and mitigating its impact
on climate change.
1.8. This will, in turn, require the identification of additional sites for housing at these settlements
and we consider that the Site should be allocated for residential development as part of this
process, based on the updated sustainability appraisal we have undertaken using the
Integrated Sustainability Appraisal (ISA) template provided for developers. This
demonstrates that the Site is a sustainable, deliverable and logical location for housing.
R002 | CE | April 2023 3
2. Preferred Spatial Option (Chapter 8)
2.1. Paragraph 8.20 sets out the preferred Spatial Option and is unchanged from the Deposit
Draft LDP. The Option is stated as being a hybrid of a Balanced Community and Sustainable
Growth Strategy. The Spatial Option acknowledges the need to recognise and reflect
investment/economic benefits and opportunities, seeks to be community led, and will aim to
allocate development in a sustainable way.
2.2. Whilst we are broadly supportive of the preferred Spatial Option, we feel that it needs to be
more explicit in stating that the strategy needs to align with the ambitious economic
aspirations of the plan.
2.3. At present, we do not feel that this is reflected in the proposed Spatial Option and, therefore,
it has not been fully justified in the context of the Council's economic growth ambitions.
2.4. We would stress that this does not require wholesale changes to the proposed Spatial Option
as this could still be community led and the delivery of sustainable development should be
at the heart of all Plan strategies. However, we would wish to see it reflect the Council's
ambitious economic growth aspirations and acknowledge that this will influence the spatial
distribution of development.
R002 | CE | April 2023 4
3. A New Strategy (Chapter 9)
3.1. We are broadly supportive of the Plan's ambitions to deliver economic growth and an uplifted
housing requirement to support this. However, the perceived reduced importance of
delivering the Council's ambitious economic growth targets within the Preferred Spatial
Option has manifested in what we consider to be an ineffective Plan Strategy.
3.2. This is because the Second Deposit Revised LDP seeks to take a balanced approach to the
distribution of housing supply (paragraph 9.4), despite the fact that it will be reliant on only
a few key centres to deliver the vast majority of the economic growth it aspires to (namely,
Llanelli, Ammanford/Cross Hands and Carmarthen).
3.3. We accept that growth will need to come forward at all levels of the settlement hierarchy
(including rural areas) to support the vitality and viability of the diverse communities across
the county. However, the Plan's focus on delivering economic growth and a balanced
approach to the distribution of development are unlikely to be an effective combination in
meeting the plan's aspirations.
3.4. The plan acknowledges that the Tier 1 settlements are the strongest economic drivers from
a market demand and delivery perspective and states that they will receive an "appropriate
proportion" of the anticipated growth. However, this should be quantified within the plan
(which it is not at present) alongside the level of housing and other types of development
needed to be delivered in conjunction with it.
3.5. The Plan Strategy needs to be more realistic in acknowledging that it cannot rely on lower
order settlements and rural areas to deliver the economic growth it aspires to and that the
Tier 1 settlements will likely need to play a greater role than is currently identified.
3.6. It also needs to acknowledge that employment sites will only come forward where they have
access to good services, facilities and infrastructure. Furthermore, they will also need to be
accessible for the local/regional labour market.
3.7. It is, therefore, essential that the Plan identifies the supporting development and
infrastructure that needs to be delivered alongside employment sites in order to stimulate
investment and economic growth. The plan currently fails to do this, and this has resulted in
deficient policies which are discussed further below.
R002 | CE | April 2023 5
4. Policy SP1: Strategic Growth and Policy SP4: A
Sustainable Approach to Providing New Homes
4.1. As stated above, we support the Council's decision to deliver a higher quantum of dwellings
over the plan period to align with the Council's economic growth ambitions. We support the
proposed 10% flexibility applied to the housing requirement as this will provide a reasonable
(albeit not optimal) level of flexibility to improve the prospects of meeting the minimum
housing requirement.
4.2. However, we question why this has been reduced from the 15% flexibility applied in the First
Deposit Revised LDP. This is particularly important in the context where one of the reserve
sites under Policy SG2 has been removed.
4.3. In addition, we are not convinced the distribution of housing has been properly justified in
the context of the ambition to deliver higher levels of economic growth. Our principal concern
is that the ambitions to deliver economic growth will be jeopardised by the balanced
approach to distributing growth across the county.
4.4. This has, in turn, resulted in a distribution pattern that does not appear to appreciate the
importance of the spatial relationship between employment growth and housing delivery as
they support the delivery of one another.
4.5. In simple terms, the distribution strategy does not take a realistic view of the capacity of
lower order settlements to deliver economic growth, relative to the Tier 1 settlements and
has, accordingly, failed to allocate a sufficient level of housing in close proximity to key
employment areas.
4.6. It is important for housing to be delivered in close proximity to key employment areas for a
number of reasons. Two particularly pertinent reasons are as follows:
1. It encourages commuting via alternative modes of transport to the private motor
vehicle in the interests of sustainability and mitigating impacts on climate change;
2. Housing delivery creates a critical mass and local workforce which stimulates
investment and job creation.
4.7. Policies SP1 and SP4 (including their supporting text) need to clearly justify the overall
quantum of development to be delivered at each settlement tier and then explain how it will
be distributed to support the economic aspirations of the plan, alongside its sustainability
and community aspirations. Its failure to do so at present is a significant deficiency with the
plan that needs to be addressed.
R002 | CE | April 2023 6
5. Strategic Policy SP3: Sustainable Distribution –
Settlement Framework
5.1. Policy SP3 sets out the settlement hierarchy and settlement clusters. We largely agree with
the structure and support the Ammanford/Cross Hands area being included within the first
tier – Principal Settlements.
5.2. We also agree with the assertion that growth and development will be directed to sustainable
locations in accordance with the spatial framework; however, as mentioned above, we have
some reservations with how this has been implemented.
5.3. Whilst we note that the highest proportion of development is due to be delivered at the Tier
1 settlements (a principle we support), we consider that too great a proportion of growth has
been allocated to lower order settlements. As stated above, the Plan is unrealistic in the way
it proposes to distribute growth to deliver its economic aspirations and the allocation of
housing sites to support this is also unsuitable as a result.
5.4. If the Plan is serious about delivering economic growth, sustainable development and
mitigating its impacts on the environment to combat climate change, then it needs to rethink
its distribution framework and allocate higher levels of development to the Tier 1
settlements.
R002 | CE | April 2023 7
6. Policy SD1: Development Limits
6.1. This policy states that development within the identified development of Tier 1-3 settlements
will be acceptable, provided that they accord with other relevant policies of the LDP.
6.2. Whilst there are exceptions to this rule (for example, Policy HOM6), the policy does not set
out a scenario whereby development for traditional housing can come forward beyond the
development limits. This will be problematic in circumstances where the Council's housing
delivery fails to keep pace with their proposed annual requirement.
6.3. Whilst we support the principle of identifying specific sites to meet the development needs
of the district within the LDP to guard against excessive unplanned development, Local Plans
still need to be sufficiently flexible to ensure that housing and other types of development
can come forward to meet the needs of the population. This is especially important in
situations when delivery does not match up with the plan's target levels of growth. This could
be due to any number of reasons, from deficiencies with the plan, unforeseen technical issues
affecting the delivery of certain sites or broader macro-economic factors.
6.4. We note the identification of Reserve Sites (Policy SG2) and acknowledge that this will go
some way to securing supply in the event allocated sites cannot come forward albeit one of
the reserve sites has been removed from the Second Deposit Revised LDP over the Revised
Deposit version. However, we would question whether this is a sufficiently flexible approach
that will help to guarantee the delivery of the plan's housing requirement. We note that the
delivery of a reserve site will need to be subject to a masterplanning exercise. This
requirement is something that would potentially delay its delivery and prevent it from
addressing a specific need (e.g. housing shortfall) in a timely manner.
6.5. As such, we consider that this policy should incorporate wording to allow for development in
sustainable locations that would otherwise comply with the relevant policies of the LDP in
the event that the supply and delivery of housing failed to keep pace with the Local Plan
Housing Requirement (i.e. the absence of a five-year supply of housing land).
6.6. We would suggest additional wording to the policy to make it clear to prospective applicants
when it would be acceptable to propose development on unallocated sites. This would
provide certainty and allow for windfall sites to come forward in accordance with the LDP to
meet shortfalls when they arise.
6.7. We acknowledge that the plan has attempted to plan positively for housing growth in
particular and sought to incorporate measures to secure this (10% buffer to the housing
requirement (albeit reduced from 15%) and the identification of reserve sites) over the plan
period. However, we consider that policy SD1 should incorporate additional flexibility to allow
development to come forward under certain circumstances (as specified above) in order the
ensure the plan can remain as effective as possible for its duration.
R002 | CE | April 2023 8
7. Land to the south of Penygroes Road, Gorslas,
Llanelli
7.1. As stated in the Introduction, the Co-op controls an area of land to the south of Penygroes
Road, Gorslas comprising a number of fields which cover an area of around 6.5ha and would
be capable of delivering c. 120 dwellings.
7.2. Vehicular access could be taken from the B4556 to the east with an emergency/pedestrian
access being taken from the north via an existing driveway/access.
7.3. The Site is well related to development around the 6-way junction along the A476 which is
home to a number of services and facilities that would meet the day to day needs of future
residents.
7.4. The Site is also well related to existing and future large-scale employment and commercial
development areas at Cross Hands.
7.5. The Site's proximity to these services, facilities and employment opportunities would reduce
the reliance on the private motor vehicle to meet the day to day needs of future residents
and would encourage the use of active modes of travel such as walking and cycling.
7.6. The Site is free from any land use allocation or other designations that would otherwise
constrain development; it could be made available for development in the short-term and
be built out comfortably within a five-year time frame once detailed planning permission is
granted.
R002 | CE | April 2023 9
8. Integrated Sustainability Appraisal
8.1. Our representations to the Deposit LDP in March 2020 included an assessment of the
sustainability of the Site with regard to the guidance available at that time. Since then, the
Council has published an Integrated Sustainability Appraisal (ISA) document for consultation
alongside the Second Deposit LDP.
8.2. Paragraph 1.7 of the ISA states that:
“The Council strongly advises that in responding to the Deposit rLDP, any relevant new,
site(s) proposed should be accompanied by an integrated Sustainability Appraisal
(incorporating Strategic Environmental Assessment). A site not subject to ISA is unlikely
to be considered suitable for allocation in the plan.”
8.3. As a result, we have provided an assessment of the sustainability of the Site against this
updated criteria in the below table.
8.4. As shown by our responses, the Site performs extremely well against the various elements of
the SA with only the fact that the Site is a greenfield site and may contain high carbon soils
being the only constraints affecting the Site's development.
9. Summary Representations
9.1. These representations have been submitted on behalf of the Co-op in respect of its land to
the south of Penygroes Road, Gorslas. The Co-op is promoting the Site for residential
development and consider it to be a sustainably located, deliverable and logical site for the
proposed use. The Co-op has a good track record of promoting sites for development and
working with developers and house builders to ensure that sites are sold on and deliverable.
It does not sit on sites or ‘land bank.’
9.2. Whilst we are broadly supportive of the economic aspirations of the LDP and agree with the
uplift to the housing requirement accordingly, we have reservations with the proposed
strategy to deliver this ambitions targets.
9.3. This is namely down to the following reasons:
 The Preferred Spatial Option and Plan Strategy appear to have diminished the
importance of delivering these said economic aspirations;
 They are unrealistic in their view that lower order settlements will be able to deliver the
currently proposed economic growth and role Tier 1 settlements will need to play has
been underestimated;
 There is a disconnect with the spatial distribution of employment development and
residential development and it is not clear how they will support the delivery of one
another; and
 The proposed flexibility measures notwithstanding, we consider that the plan should
include a policy to facilitate development beyond the defined settlement limits in the
case of severe plan failure.
9.4. We suspect that when the plan is reviewed in light of these issues, a higher proportion of
growth will be identified at the Tier 1 settlements and this will require additional housing
allocations to be included.
9.5. Our client's Site is available, deliverable and sustainably located. We have assessed it against
the Council's ISA template and it has performed very well with few minor issues. We would,
therefore, support a new policy allocating the Site for residential development in the final
version of the LDP.

Allocate whole of Candidate Site reference SR/132/009 in the Plan.

Carmarthenshire Local Development Plan 2018-2033 – Deposit Draft
Representation on Behalf of Low Carbon Construction Ltd
Former Emlyn Brickworks Site, Penygroes
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 SG 1 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/132/009, seeking the allocation of their land (edged red on Plan A) for a mix
of residential development, areas of formal and informal amenity space, together with an
area preserved for ecological interests, as part of the Replacement Local Development Plan.

The site would serve the settlement of Penygroes and the surrounding area of the
associated Principal Centre. The Strategic Candidate Site comprised largely of a single
enclosure of brownfield land, with vehicular access gained off the newly constructed A4076
spur leading to Norton Road to the north, Waterloo Road to the east and Gorsddu Road to
the south. Several pedestrian and cycle points of access are also located on each of these
boundaries. 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.
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 are concerns regarding the deliverability of the whole site, and so it is considered
appropriate to allocate part of the site for mixed use. The site reference is PrC3/MU1.”
As a result of the above, only an element of the Alternative Strategic Site was
proposed for allocation, as illustrated by Plan B below.

At the time of publication of the 1st Deposit LDP therefore, the only reason presented by the
Council for not allocating the whole of the Site, was on the basis of concerns with regards to
its delivery in totality. It should be noted, that there has been a strong desire by the land
owners and developers for some time to see the Parc Emlyn site developed out, but this has
been hampered and significantly delayed due to the lengthy process of the construction of
the new A4076 (broken red line on Plan B). With its recent completion, progress on the
development of the Parc Emlyn site can continue and there are in fact two planning
applications currently being prepared for elements of it.
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 Site was considered as part
of this process and as a result the Council concluded as follows:
“There are concerns regarding the deliverability of the whole site, and so it is considered appropriate to allocate part of the site for mixed use. The site reference is PrC3/MU1.”

Accordingly, the 2nd Deposit LDP Proposals Maps replicate the position shown by those of
the 1st Deposit (Plan B), with the rationale given by the Council for doing so also remaining
unchanged.

For the reasons given above, this is not only an illogical and ill informed decision, but also
appears to be a dangerous and erroneous decision to make, particularly in light of the level
of under provision of deliverable housing sites within the Plan. As a result of this decision we
therefore consider that the LDP as it stands is “unsound” and fails to meet the required Tests
of Soundness. As detailed, this is particularly worrying, in view of the lack of deliverable
allocations within the Principal Tier of which the Alternative Strategic Site forms part of
(please see below).
We consider therefore that all the land edged red in Plan A, should be allocated for mixed
use development under the provision of Policy HOM1 and SPG1 of the Carmarthenshire
Local Development Plan.
This formal representation letter 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 and associated Plans
Response to Council’s Reasons for Non-Allocation of Site
Sufficient Residential Land Allocated Within Settlement
As detailed above, we are deeply concerned with the Council’s decision to reduce the
proposed housing allocation in question, and understand that this may be because the
Council holds the view that alternative allocations within Penygroes and the wider Principal
Centre it forms part of will deliver sufficient housing for the area during the Plan period. This
is in our view wholly incorrect.
Under the current provision of the Deposit LDP, the Principal Centre has a range of
proposed residential allocations. Having undertaken a comprehensive review of the
proposed allocations put forward by the 2nd Deposit LDP for the Principal Centre in question,
it has been identified that a number have significant questions over their ability to be
delivered within the Plan period, including the following:

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

As a result of the above – all of which have been allocated in previous development plans -
separate objections to their inclusion with the LDP have been made. This is due to the fact
that to continue to allocate such sites for residential development results in the Plan being
unsound. Alternative sites, such as that put forward by our Client, must therefore be
considered and brought forward in order to address this deficiency and ensure that the Plan
is sound in all respects.
In conclusion, this Representation to the 2nd Deposit Draft of the Revised LDP has sought to
examine the Council’s reasons for non-allocation of the whole of the Candidate Site. It has
successfully addressed the reasons put forward by the Authority for its exclusion and has
highlighted that the reason given are illogical and erroneous. In addition, it has been
highlighted in conjunction with our submissions made by this Practice, that the currently
proposed allocations put forward by the 2nd Deposit LDP are undeliverable.
We therefore respectfully request that this Representation be given careful examination, and
consequently the land in question be allocated for residential development in its entirety as
part of the Carmarthenshire Local Development Plan to ensure that the document passes all
the relevant tests of soundness.

Include site in Plan

Our client owns an agricultural holding which is set to the rear of residential properties and
fronting the southern flank of Nant-y-Glyn Road, on the western edge of Glanamman. The
land comprises low-grade, rough pasture which also borders detached and semi-detached
housing which are orientated to front that highway, and also lies directly individual housing
set off the opposite, northern flank of the road as it extends westwards from the village core.
Our client’s land interests at the western edge of Glanamman benefit from an edge-of
settlement location, immediately adjoining established housing, and set fronting Nant-Y-Glyn
Road, which is of sufficient width with footways and alignment. The site also lies within
walking distance of the settlement’s community facilities, including a medical surgery and
pharmacy, and public bus service. It can be regarded as inclusive within the settlement
form.
Our client therefore seeks inclusion of their land as an Alternative Site for a future
Residential development within the defined settlement limits of Glanamman within the
Replacement Local Development Plan.
The Site comprises a single rectangular-shaped field frontage, and generally level to gently
sloping grazing field set off the immediate southern flank of Nant-y-Glyn Road. The field is
naturally screened from Nant-y-Glyn Road by existing frontage residential properties to the
east, and virtue of a perimeter of mature trees and scrub about the far rear, southern field
perimeter and also western side of the field, where mature hedgerows and trees screen the
paddock from wider views. The Figure 1 below provides a Google Earth image of the site.
Figure 1 – Google Earth – April 2021 – of Representation Site
Figure 2 – Ordnance Survey Map extract of Representation Site
We have noted that the draft settlement limits have been placed along the rear garden
boundaries of existing residential properties, but which also includes an undeveloped
building plot off Nant-y-Glyn Road, and to the north-eastern edge of the field.
Our clients consider 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, our clients consider that the draft settlement limits for Glanamman / Garnant, as
defined under Policy SD1 “Settlement Limits”, should be amended to include the land as
edged in red upon the extract of the Proposals Map for Glanamman / Garnant, as
reproduced below in Figure 3. The land should be appropriately allocated for Housing
under Policy HOM1.
Figure 3 – Extract from Proposals Map with Representation site edged in red
This formal representation letter supplements the following documents which comprise a
complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
- Location plan and Indicative Masterplan
Reasons for Allocation as Residential Development within
Settlement Limits
1.0 Position within Residential Setting at Nant-y-Glyn Road
1.1 The Council within the Settlement Framework of the LDP, have categorised
Glanamman as a Tier 2 “Local Service Centre”, as it benefits from a range of retail
and community facilities and has good public transport links to the nearby Principal
Service Centre of Ammanford. In such circumstances, the introduction of a modest
residential allocation to the edge of Glanamman certainly meets the spatial criteria for
locating new dwellings as part of the settlement form.
1.2 In terms of its physical location, the Representation Site is flanked on one side by
residential development, with the field enclosure extending over a field frontage of
some 95 metres, equivalent in form to the opposite, northern flank of this section of
highway, with frontage properties at Nant-y-Glyn Road orientated to face the
Representation Site.
1.3 Nant-y-Glyn Road itself continues from this point for only a few hundred metres to
join Heol Amman and the range of community facilities including public bus stops
(Services 145 & 146 to and from Ammanford). In the context, the site is directly
related to the settlement, with proposed occupants able to easily access
facilities and public transport. Consequently, the proposals would meet the
relevant initial criteria of the Policy SP16 where new residential development should
seek to be placed in sustainable locations, accessible on foot / cycle to the
settlement’s range of community and commercial facilities and services.
2.0 Representation Site Proposals
2.1 This submission is accompanied by an Indicative site layout plan which indicates an
indicative setting for a frontage of detached, two-storey dwellinghouse to be
orientated to front the public highway and thus mirror the established residential
properties over the opposite, northern flank of Nant-y-Glyn Road. Figure 4 below
provides a reproduction of that Plan which seeks to provide paired accesses onto
Nant-Y-Glyn, and dwellings set back to allow for adequate parking and turning
facilities. Traditional rear gardens of a minimum of 10 metres depth would be typically
arranged, with the rear perimeter of the site denoted with new hedgerow planting.
Figure 4 – Indicative Site Layout Proposals
2.2 The Representation proposals would ensure that massing of scale was sensitively
designed with buildings not rising to more than two storeys. The development of the
field frontage will not necessitate re-modelling of ground levels given that the field is
gently undulating towards its southern extremity and corresponds to the ground
levels of adjoining Nant-y-Glyn properties, as shown in the photographs below.
Photo 1 – view looking east along Nant-y-Glyn Road with field frontage to right
and established housing directly opposite
Photo 2 – view westwards along public highway with younger trees and scrub
evident along site frontage
Photo 3 – the site has limited ecological value being semi-improved grassland
with pockets of scrub to roadside
3.0 Sustainable Location
3.1 The Site at Nant-y-Glyn Road lies off a public highway which extends about a localauthority-built estate and onto Heol Amman. Public bus stops lie only some 300
metres distant from the site access at Maesybont and Tabernacle Road. Main public
bus services call at these bus stops, and in particular:
- Service 145 – Cwmamman to Ammanford, via Garnant and Glanamman
- Service 146 - Ammanford to Cwmamman via Garnant and Glanamman
3.2 The Site is within 10 minutes’ drive, or journey by public bus, to the Heart of Wales
rail service at Ammanford station.
Local Industrial Estates at Station Road and Raven Industrial Estate are a 10
minutes’ walk from the Site.
3.3 The Alternative Site lies within a 5 minutes’ drive distance of Ysgol-y-Beddol, which is
located near the junction of Hendre Road with Maes-y-Beddol.
Glanamman contains a post office, range of convenience stores, petrol filling station,
medical surgery, pharmacy, play facilities, community centre, public houses and
cafés.
Ysgol Dyffryn Aman and Coleg Sir Gar at Tir-y-Dail are located a 10-minute road
journey from Glanamman.
3.4 Ammanford town centre provides a whole range of large food supermarkets,
comparison shops, high street banks, public houses / cafes, offices, bus station,
industrial estates, library and leisure / recreation facilities.
Figure 5 below provides an indication of the proximity of the Alternative site to
Glanamman village centre at Cwmamman Road, and nearby Ammanford town
centre, bus and rail stations, and strategic road network.
The red star denotes the position of the Representation Site.
Figure 3 – proximity of Site to Glanamman village centre, Ammanford town
centre and major road network
4.0 INFRASTRUCTURE CONSIDERATIONS
4.1 Development of the Alternative Site for residential units would be served by mains
water, gas, public sewer and electricity connections, which either lie within the
adjoining stretch of Nant-y-Glyn Road, and adjoining Maes-y-Glyn estate.
4.2 The public highway itself is equipped with roadside gullies and drainage which aid to
discharge run-off from the extended carriageway. The Site comprises of former
agricultural pasture. There are no areas of water-logging evident, and therefore at
first inspection, it appears that the site benefits from good ground percolation of
rainwater and discharge to existing perimeter drainage ditches.
Soakaways would be the most sustainable means of disposing of surface water from
individual buildings. If required, attenuation measures can be deployed on site to
control surface water run-off during extreme storm events, which could also allow for
additional capacity, making allowances for climate change. The field enclosures are
served by a series of drainage ditches along the field’s boundaries, which eventually
combine and inter-connect discharging surface water to minor watercourses flowing
eventually to discharge into the River Aman. It is considered that as a result of on-
site features, there would be several options available to a future development of the
site in terms of surface water disposal.
4.3 We have also referred to The Coal Authority Map detailing “Development High Risk
Areas” and the location of historic mine entries. Figure 6 below is an extract from that
map, and which confirms that the site is free from any mining legacy.
Figure 6 – extract from Coal Authority interactive map with site hig
5.0 Housing Land Availability in Glanamman / Garnant
5.1 Despite being a Tier 2 Local Service Centre, Policy HOM1 indicates only two sites
allocated for housing in the whole of Glanamman and Garnant. An extract from that
HOM1 schedule is reproduced below.
Figure 7 – Housing Allocations at Glanamman and Garnant
5.2 The re-development at the former Garnant Primary School have already been
completed, whilst the site at Bishop Road has been advertised for sale for the last
few years without any apparent success in being sold. Therefore, for a settlement
with several thousand residents, there are no residential development opportunities.
The development of the Alternative Site for only five additional dwellings will not
place any burden whatsoever, or indeed compromise housing land supply.
CONCLUSION
This Representation to the Second Deposit Draft of the Revised LDP has sought to promote
the inclusion of an Alternative Housing allocation on land off Nant-y-Glyn Road in
Glanamman.
Our client has illustrated that their indicative proposals to develop a small site of frontage
dwellings to mirror that currently in existence off the northern, opposite flank of the road.
Accordingly, the development of the field frontage with five detached dwellinghouses will not
appear at odds to the prevailing spatial pattern of development in Garnant / Glanamman.
The locality has numerous examples of modern frontage development being completed at
edge of settlement locations, which in turn, advocates that the form of development
proposed for modest housing numbers is no different, resulting in it being respectful to the
character and setting of the locality.
We respectfully request that this Representation be given careful examination, and
consequently the defined settlement limits of this part of Garnant / Glanamman realigned to
include the Representation Site in the Proposals Map of the adopted Local Development Plan.

Include the site for housing within the Revised LDP.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/082/002, seeking inclusion of their land for future residential development within the
settlement limits of Llandybie in the Replacement Local Development Plan. The Candidate
Site comprises of part of a grazing field fronting the eastern side of Waunfarlais Road.
We have noted that the settlement limits within the Second draft Proposals Map have
encircled the existing built development of Waunfarlais Road, which essentially comprises
road frontage development off both flanks of the minor road, extending south from the
railway level crossing of that highway to residential properties about Aberlash.
The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our clients’ submission, reasons why the site was not selected for inclusion within the draft
settlement limits of Ammanford, 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) and Stage 2A (Initial
Detailed Site Assessment) of the Council’s site assessment. However, it was rejected at
Stage 2B (further detailed site assessment), for reasons reported as follows:
“Development of the site would result in a ribbon patter 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.”
Our clients consider 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, our clients consider that the draft settlement limits for Llandybie, as defined
under Policy SD1 “Settlement Limits”, should be amended to include the land as edged
in red upon the extract of the Proposals Map, as reproduced below in Figure 1.
Figure 1 – Extract from Proposals Map with Representation site edged in red
This formal representation letter supplements the following documents which comprise a
complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
- Location plan and Indicative Site Layout plan
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits
1.0 Perception of Ribbon Development
1.1 The Council consider that the inclusion of the site within defined settlement limits
would be likely to result in a ribbon pattern of development, contrary to general
planning principles. In response, our clients would point to the prevailing spatial
pattern of development at Waunfarlais Road. We consider that the setting of the draft
limits to encompass the established form, which is “ribbon development” in character.
1.2 Waunfarlais Road includes for two groupings of frontage dwellings, the respective
settlement limits of each are literally separated by only some 20 metres, as shown in
Figure 1 above.
However, there are instances where the Council have allowed for the settlement
limits to cross to the opposite, undeveloped flanks of the minor highway, and beyond
the end of each grouping of properties. Such breaks from the established form have
allowed the respective landowners of those undeveloped parcels to seek planning
permission for further residential properties. We have noted that since the Candidate
Site consultation stage completed in August 2018, two detached houses have been
constructed with planning permission granted off the opposite flank of the minor road.
Their presence is shown in the current version of Google Earth dated April 2021 at
Figure 2 below.
1.3 The new development appears stark in contrast to the pre-development appearance
of that field frontage, which took a form as that displayed at the Candidate Site.
Google Earth from June 2018 illustrates the locality at Waunfarlais at the time of the
Candidate Site stage (Figure 3).
The completion of those two new houses has dramatically reduced the gap between
the two clusters of built development at Waunfarlais to a level where the further
development proposed by the Candidate Site will mirror that experienced opposite,
and not lead to any detrimental effects, in the form of ribboning, as suggested by the
Council.
Figure 2 – Google Earth – April 2021
Figure 3 – Google Earth – June 2018 – pre-development off the western flank of
Waunfarlais Road
1.4 An indicative site layout plan has been prepared to illustrate for 5 detached
dwellinghouses across the site frontage, and is reproduced below as Figure 4. The
setting of detached dwellinghouses set fronting the eastern flank of Waunfarlais Road
will be complementary in form to adjacent established forms of residential
development along this highway and particularly the exisiting and proposed form of
frontage development off the opposite, western flank of Waunfarlais Road.
New Housing
completed since
Candidate Site stage
Figure 4 – Indicative site layout plan of proposed Representation Site
2.0 Proximity to Zone C2 Flood Zone & Means of Emergency Access / Egress
2.1 The Council indicate that the Candidate Site fails to be included within defined
settlement limits as access to the site is likely to be gained through a “C2 flood zone
as identified in the TAN15 Development Advice Maps.” The Council are referring to
the designated flood zone of the River Lash as reproduced below as Figure 5.
The newly compiled “Flood Map for Planning” (Figure 6) also shows that extreme
fluvial flood waters are predicted as flowing over the public carriageway of Aberlash
Road, where that highway underpasses the Heart of Wales railway line. The Afon
Marlais is also predicted to overtop its natural banks in an extreme event, and partly
flow over the Waunfarlais highway.
Figure 5 – Extract from NRW DAM map for Waunfarlais / Aberlash locality with
the Representation site edged in red
Figure 6 – Flood Map for Planning
2.2 Our clients would point to the recent implementation by Natural Resources Wales of
their flood alleviation works to this section of the River Lash, as part of their capital
expenditure programme for the town of Ammanford. NRW concluded that “a
combination of measures is needed to reduce the risk of flooding. We believe that the
best option is to construct a series of flood defence embankments and walls in
several areas in the town to contain flood water in the River Loughor, and installation
of Property Flood Resilience (PFR) measures to houses on Aberlash Road.”
2.3 We therefore submit that flood prevention matters are being put into place by NRW to
effectively manage the effects of flood waters during such extreme events.
Furthermore, we submit that the land subject of this Representation remains within
Zone A, and as such is not subject to flood risk. In accordance with TAN 15
advice, new residents could remain in their properties, as a place of safe refuge, and
await those extreme floodwaters to recede. We submit that in any extreme event the
depth of floodwaters at this point and are of a depth so as to not to prevent
emergency vehicles from accessing Waunfarlais Road properties.
2.4 The nearby presence of a flood plain did not prevent planning permission
being granted for two new dwellinghouses opposite the Representation Site as
shown above in Figure 2. Planning Permission E/34695 in May 2017. New
residents and visitors to those new houses will have to travel “through
floodwaters” as suggested by the Council, in response to this Candidate Site
submission. However, no objections were received from Natural Resources
Wales as to any potential risks to people or property as a result of nearby flood
risk. The Council’s argument in relation to flooding at our clients’
representation site is therefore tantamount to being complete inconsistency
when applied formally at Waunfarlais Road.
3.0 Overall Housing Supply at Ammanford with Deposit Draft
3.1 The proposals under this Representation merely seek the addition of five residential
units to the overall housing supply of Ammanford. Waunfarlais forms part of the
principal service centre centring upon the Ammanford Cluster as defined within the
Second draft LDP.
3.2 The new Draft Proposals Map reveals that the Council have allocated a total of 8
sites at Ammanford as shown below.
3.3 The above eight alocated sites proposed for Ammanford reveal a combined total of
292 units, howeve upon analysis it is clear Wind Street, Llys Dolgader, Gwynfryn and
Yr Hen Felin have already been constructed, totalling 49 dwellings.
3.4 Of the other four Ammanford allocations, it is immediately noteworthy that they are
predominately “roll-overs” from earlier Development Plans with those sites showing
no commitment whatsoever to commit to the implementation of a planning
application. We would comment on the two largest of those sites as follows:
Site PrC3/h4 - Tirychen Farm, Dyffryn Road, Penybanc - for 150 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.
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. Clearly, there is
no historic demand for a site of this scale in this part of the Ammanford area. More
physically challenging sites, such as the re-development of the Betws Colliery site at
Betws and Cae Pound at Cross Hands West Tip have come forward long before
Tirychen, and yet still the Council is prepared to allocate the site once again in a new
Development Plan.
The decision to retain Tirychen Farm after a period of 30 years within the LDP is
shown to be inconsistent, as does not sit with LDP Procedural Guidance which
encourages Local Planning Authorities to only re-allocate sites based upon firm
evidence of deliverability.
Figure 7 – wider view of Ammanford draft Proposals Map
3.5 Site Prc3/H36 - Betws Colliery – for 66 units
Outline planning permission was first granted for residential development on the
allocation as far back as 2005 (Application E/09584), with reserved matters being
granted in 2011 (Application E/24724). A Non-Material Amendment (Application
PL/04568) has been granted in September 2022 for the ‘Removal of chimneys and
raising the height of window sills’.
The site was allocated in the Carmarthenshire Local Development Plan (2014) as
part of a larger allocation (GA3/h9), and Allocation PDB27 of the Carmarthenshire
Unitary Development Plan (2006), which included the land south of Ffordd y Glowyr,
which has been developed.
However, the northern element continues to be allocated for 66 units in the Second
Draft LDP. This is despite having almost 20 years of support for the principle of
residential development at the historic allocation from the Council, with not a single
housing unit has been delivered to date.
In conclusion, this Representation to the Deposit Draft of the Revised LDP has sought to
examine the Council’s reasons for non-inclusion of a Candidate Site. It has successfully
addressed two technical issues. The new dwellings’ occupants will be able to access the
A483 Ammanford Road via Aberlash Road where the NRW have embarked upon a series of
flood prevention measures, with the aim to lessen the effects of fluvial flooding upon the
locality. The site itself nevertheless remains flood-free.
This Report has also painted an inconsistent rationale applied by the Council in continuing to
allocate historic allocations in the LDP, without the majority of those units having been
brought forward over the last 20 years. Their continued retention within the Plan renders the
Plan as undeliverable, contrary to Planning Policy Wales guidance. Those sites should be
omitted, and more modest alternatives included such as that promoted at Waunfarlais Road.
Our clients have presented their indicative proposals to promote a frontage development of
only four additional dwellinghouses. The proposals will be compatible with existing and
proposed development along both flanks of Waunfarlais Road, and thus ensuring that future
development respects the character and setting of the locality.
We respectfully request that this Representation be given careful examination, and
consequently the defined settlement limits of this part of Ammanford /Llandybie realigned to
include the Representation Site in the Proposals Map of the adopted Local Development
Plan.

Allocate the site for housing within the Revised LDP.

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 submitted form completed in respect
of land at Bryngwili Road, Cross Hands, Carmarthenshire. It is submitted on behalf of Suzie Jones and
Bryn Jones.
1.2 A 5.2 hectare site was previously submitted for the First Deposit Revised LDP in 2018 (Ref: SR/031/008)
but was not allocated for residential development as it was considered that there was sufficient suitable
land available elsewhere in Cross Hands to meet its housing needs. This resubmission of the site at
Bryngwili Road, Cross Hands only concerns a much-reduced area of land at the most western portion of
the land that was originally submitted, amounting to approximately 1.5 hectares.
1.3 The site is located to the north of Bryngwili Road, approximately equidistant from Cross Hands and
Tumble. The land can be entered via an existing gated access along Bryngwili Road.
1.4 This submission will demonstrate that the site should be allocated for residential development which is
sympathetic to its surroundings in terms of scale and form, and addresses the opportunities and
constraints of the site. Furthermore, Appendix 2 reveals that the site received planning permission in
1990 for residential development thus confirming that in the past the Local Planning Authority have
considered it suitable for residential development.
1.5 The deposit LDP states that there are a number of housing allocations within Cross Hands/Tumble area.
On further examination it is evident that 3 of which have already been built out. Occupants are moving
into the dwellings along Ffordd y Neuadd and Clos yr Eithin (PrC3/h11), the residential development at
land adjoining A48 and Heol y Parc (PrC3/h12) has been completed, whereas development at the land at
Heol Cae Pownd (PrC3/h13) has been partially completed. The remaining allocation at the land adjacent
to Maesyrhaf only concerns an allocation of 5 dwellings. Furthermore, it should also be noted that the
Central Garage allocation in nearby Tumble (PrC3/h29) has also now been completed and occupied. As a
result of this, it is considered that additional candidate sites need to be put forward. The land owners
have stated that they are keen for the site to be developed in the short term, with a contractor in place to
start building, along with an estate agent that has clients ready to purchase.
1.6 In terms of the content of this Supporting Statement, Section 2 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 sets out the site’s general location and provides a brief description of the candidate site and
its immediate surroundings.
2.2 The site is located equidistant between Cross Hands and Tumble, on land just north of Bryngwili Road. It
is situated roughly 12.5 miles south east of the county town of Carmarthen and circa 9 miles to the northeast of Llanelli. Bryngwili Road lies along the A476, which runs from Llanelli to near Llandeilo via
Carmarthen. It is a single carriageway road which is approximately 27km long. Within the deposit LDP,
Cross Hands and Ammanford form a Tier 1 principal settlement, where the vast majority of the growth will
be focused during the plan period.
2.3 The irregular shaped parcel of land comprises circa 1.5 hectares in area, with its most southern point lying
within the development limits of Cross Hands. Bryngwili Road is mainly residential in character, with a
mixture of dwelling types. Retail and services can be found to the east in Cross Hands. To the west lies the
village of Tumble, which provides a number of key services such as schools, a doctor’s surgery and a place
of worship. While to the north and south of the site, the land is in agricultural use. In terms of community
facilities, Cefneithin RFC is situated along Carmarthen Road, approximately 900m to the north of the site.
Llechyfedach Primary School and Ysgol Gyfun Maes y Gwendraeth are within walking distance of the site.
2.4 The site is currently in agricultural use, with a boundary of hedgerows and some mature trees. As
previously mentioned, planning permission was gained by the current land owner in 1990 for residential
development at the site.
2.5 The nearest bus stops are situated along Bryngwili Road, at the southern end of the site, which offer
services heading to several destinations in Carmarthenshire including Ammanford, Carmarthen and
Llanelli. The northbound side is services by the 129 and 166, whereas the southbound side is serviced by
the 128, 129 and 166. These stops are serviced on a regular basis, with a service calling once every
hour/two hours between the hours of 6am and 7pm on weekdays. In terms of train provision, two
stations are a similar distance away from the site, those being Ammanford and Pantyffynnon. Both stations are roughly 5.5 miles from the site, and they are both located on the Heart of Wales line which runs
from Swansea to Shrewsbury. Five trains a day travel northbound calling at both stations, and another
five head southbound from Monday to Friday. On Saturdays, four services head in both directions,
whereas this number is halved on Sundays. All trains calling at both stations are operated by
Transport for Wales, and proposed enhancements have been made to the line as part of the Swansea Bay
and West Wales Metro. Lying to the north of the site is National Cycle Route 47 which is 195 kilometres
in length, running from Newport to Fishguard and forms part of the Celtic Trail West.

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 climateresilience, 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”.
3.12 In terms of the historic environment, Paragraph 6.1.5 notes that “The planning system must take into
account the Welsh Government’s objectives to protect, conserve, promote and enhance the historic
environment as a resource for the general well-being of present and future generations. The historic
environment is a finite, non-renewable and shared resource and a vital and integral part of the historical and
cultural identity of Wales. It contributes to economic vitality and culture, civic pride, local distinctiveness and
the quality of Welsh life. The historic environment can only be maintained as a resource for future generations
if the individual historic assets are protected and conserved.” This is a key aspect of wider sustainable
development responsibilities which should be taken into account in both the formulation of planning
policies and the exercise of development management functions. The conservation of the historic
environment also contributes to the Welsh Government’s seven well-being goals for a sustainable Wales
Carmarthenshire Local Development Plan
3.13 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.

3.14 The site lies immediately outside the development limits of Cross Hands and Tumble, to the north of
Bryngwili Road. However the site is still designated under a number of different categories by the LDP
such as: High Specification Aggregate - Sandstone and Igneous Rocks MPP3, Secondary Resource
Zone MPP3, Caeau Mynydd Mawr SPG Area EQ7, Higher proportion of Welsh Speakers SP18 and the
Affordable Housing Viability Targets AH1 (10%).
3.15 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.
3.16 The following section will seek to establish that national planning guidance is supportive of a limited form
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 merits of the site as a housing land
allocation 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 Tumble and
Cross Hands, and its development for residential purposes represents a logical extension of those limits
for residential development and inclusion within the settlement boundary, at this location. As previously
mentioned, there are several facilities and amenities within walking distance of the site, primary and
secondary schools, and a surgery.
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 until 2033.
Accessibility
4.4 The site sits directly north of Bryngwili Road, which can be accessed via a gate along the southern portion
of the land. Transport links are also good, with the A48 being easily accessible from the site. Bus stops are
also provided along Bryngwili Road, with the nearest within 20m of the access point, which enables travel
to and from Llanelli, Ammanford and Carmarthen bihourly. In terms of train provision, both Pantyffynnon
and Ammanford stations lie a quarter of an hour away and are situated along the Heart of Wales line. A
national cycle route lies in close proximity to the north, providing a route for cyclists and pedestrians to
use at their leisure.
Land Ownership
4.5 The land to which this Candidate Site Representation refers is within the joint-ownership of the Site
Promoter – Suzie Jones and Bryn Jones. Both landowners are fully committed to bringing forward the
development of the site. They have informed us that there is a contractor ready to build on site and an
estate agent has clients waiting to purchase. Bringing this site forward will help meet the housing need of
Cross Hands in the short term. Within the deposit plan, three of the four housing allocations for Cross
Hands have been built out, whereas the other allocation only concerns a small scale allocation.
Consequently, other sites within the settlement ought to be considered, and due to limited land within
settlement limits, the search ought to be extended to areas outside the development boundary whilst
taking into consideration the nature of the existing settlement pattern.
Capacity of Infrastructure
Utilities
4.6 The site lies adjacent to existing development at Bryngwili Road where utility services are readily available
or can be provided. 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
4.7 The site is located within ‘Zone A’ of National Resources Wales (NRW) Development Advice Map, which
means it is considered to be at little or no risk of fluvial or coastal/tidal flooding. Appropriate means of
surface water drainage, including SUDs will be considered. It is not anticipated that there are capacity
issues in the area regarding foul drainage.
Access
4.8 The site sits directly north of Bryngwili Road, and currently benefits from a gated access with good inter
visibility along the site frontage.
Impact on the Community/Welsh Language
4.9 The site is located within an area designated as being a higher proportion of Welsh Speakers (under
policy SP18). It is considered that a housing development at this site will accord with Policy SP18 by
assisting in ensuring sufficient and proportionate housing supply for Welsh Speakers, including
affordable housing provision comprising greater than or equal to 10% of the site, which is fully policycompliant with policy AH1 of Carmarthenshire’s LDP – providing young, local Welsh Speakers the
opportunity to stay in the area. In terms of Welsh speakers, this will be helped by the fact that there are 5
Welsh medium primary schools in close proximity to the site, along with comprehensive school Ysgol
Maes y Gwendraeth,
Physical and Environmental Constraints
Ecology
4.10 It is considered that any existing trees and hedgerows on site could be incorporated into a residential
layout. Notwithstanding it may be necessary for further ecological and tree surveys to be undertaken to
determine any potential impacts on protected habitats/species.
Visual Impact
4.11 Given the surrounding residential development, the design of the dwellings would need to be in keeping
with the character of the area with the existing dwellings mainly consisting of more traditional two storey
dwellings with pitched roof design. It’s not anticipated that a residential development on this site would
give rise to any adverse visual impacts with good design and layout of the site.
Flood Risk
4.12 The site is not identified in the TAN 15 Development Advice Map as being at risk from flooding.
Site Contamination
4.13 In terms of ground conditions there are no known constraints that prevent the development of the site
for residential uses in trems of ground contamination.
Compatibility with Neighbouring Uses
4.14 Given the land use in the surrounding settlement is mainly that of a residential nature, it is considered
that the principle of residential development at this site would form a compatible use with the
neighbouring uses. To ensure residential amenity is protected, adequate separation distances and
compatible design of any future dwellings will need to be carefully considered. Currently, the site
benefits from strong boundary features including hedgerows, which could be incorporated into the
design of the site to provide a buffer between residential developments.
Coalescence of settlements
4.15 Development on the site would not result in the coalescence of settlements. Development of the site will
result in a marginal extension of Cross Hands` development limits, although the most southern part of
the site already within settlement limits in the deposit plan. Extending the boundary a little further north
will not impact the make up of the settlement.
The potential to reduce carbon emissions through co-location with other uses
4.16 The site is considered to be located in a sustainable location with a bus stop within 20m of the site access
along Bryngwili Road. Links to Ammanford, Llanelli and Carmarthen are provided bihourly, with a school
service number 109 also serving the secondary school along Heol y Parc in Cefneithin. Therefore it can be
seen that the location of the proposed development will encourage travel by means other than car, thus
reducing carbon emissions.
Relationship with Historic Environment
4.17 Approximately 175m to the west of the gated access to the site, a Grade 2 listed building can be found
that demarcates a milestone between Cross Hands and Tumble. It is not anticipated that any proposed
works at the site will affect the setting of this historic asset.
Delivery of Key Placemaking Objectives
4.18 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.
5 Conclusion
5.1 This Candidate Site representation is made by Asbri Planning Limited on behalf of Suzie Jones and Bryn
Jones and requests that land to the north of Bryngwili Road, Cross Hands is brought forward as a
housing land allocation through the Carmarthenshire County Council Second Deposit Revised Local
Development Plan 2018 - 2033.
5.2 The allocation of the site will assist in ensuring the adequate delivery of housing in Cross Hands, with
most of the housing allocations within the deposit LDP having already been developed, therefore there is
an additional need for housing in the area. 4 of the housing allocations ought to be removed from the
deposit plan as they have already been built out, whereas the remaining one at the land adjacent to
Maesyrhaf only has an allocation for five dwellings across the plan period. The scale and nature of this
site would be attractive to house builders, which would facilitate delivery in the short to medium term.
The land owners have stated that they are keen for the site to be developed in the short term, with a
contractor in place to start building, along with an estate agent that has clients ready to purchase. The
southern end of the 1.5 hectare site lies within the development limits of the deposit plan, however this
submission requests that the boundary is extended further north as shown in Appendix 1 in order for the
site to accord with Policy SD1 (Development Limits).
5.3 The site could potentially deliver several 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.
Furthermore, it is positioned in a sustainable location where several amenities lie nearby, and there are
adequate public transport connections on offer.
5.4 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.
5.5 In light of the above, it is, therefore considered that Carmarthenshire County Council should, in its review
of the Local Development Plan, identify the land at Bryngwili Road, Cross Hands as a housing land use
allocation.

Include the site within the Plan.

Land at Llwyn Ty Gwyn,Whitland owned by Whitland RFC

The Proposed site is owned by Whitland RFC and is located in the village.Thee site forms a natural extention to the development limits of Whitland & applies sensible infilling within the village. The site is servived by an existing road with a sound wide junction & would provide exellent self build plots on a site above the flood plain with acess to all services nearby.
The land is surpus to reqirements & is usrd for overspill car parking on rare occasions.Allowing this site to be included for housing development will ebnable the Rugby club to invest in improved acilities for the benefit of the local community.

The adjacent 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 shaded pink. I have also highlighted Sec19/h3 site at Lingfield that is fully developed in yellow.

Allocate the alternative site for housing within the Revised LDP.

1.0 I NTRODUCTION
1.1 Mr. A. Williams (the Land Owner) have instructed Evans Banks Planning Limited to prepare and submit a formal Representation for the inclusion within defined settlement limits of land adjacent to Pen-y-Bryn, off Thornhill Road, Cwmgwili, Carmarthenshire for the purposes of residential development in the forthcoming Replacement Carmarthenshire Local Development Plan.
1.2 This Statement has been prepared in line with the Authority’s published documents entitled Revised Carmarthenshire Local Development Plan: Guidance Note and Revised Carmarthenshire Local Development Plan: Candidate Site Assessment Methodology. The contents of this Statement therefore address the set criteria, determining the issues and each qualifying point raised within these documents.
Consideration has also been given to ensuring that this formal submission complies with the guidance and requirements of Planning Policy Wales (Edition 11), in relation to the preparation of development plans and the allocation of land for residential purposes as part of that preparation process.
1.3 The contents of this Statement therefore provide a comprehensive case for the inclusion of the land for residential development purposes within the defined settlement limits of Cwmgwili, and it should also be read in conjunction with the accompanying supporting information and indicative site layout plan.
1.4 This site did form part of a larger Candidate Site formally presented to the Council in August 2018, and referenced SR/040/003. Consideration has subsequently been given by our client as to the extent of site sought under the LDP process, following the conclusions of the Council in their Site Assessment Table (January 2023). The Council consider that “The site is located immediately adjacent to a site designated for importance to nature conservation.” This Statement seeks to examine that conclusion and provides an Amended Site proposals which seeks to address and ultimately overcome this biodiversity issue.
Representation Supporting Statement March 2023
Land off Thornhill Road, Cwmgwili Mr A. Williams

2.0 SITE CONTEXT
2.1 THE SITE
2.1.1 The Amended Site relates to a parcel of undeveloped agricultural pasture which is set off the eastern flank of Thornhill Road, being a C class road near the centre of the village of Cwmgwili. The field parcel is irregular in shape and extends to a gross area of 1.65 acres (0.66 hectares). The northern perimeter of the field borders part of the Heathfield Industrial Estate, although the southern part of that estate is undeveloped, being covered in grass and scrub, with the main activity being associated about an undulating yard and shed outbuildings to the centre and eastern part of that large land enclosure.
2.1.2 The northern perimeter of the Candidate Site is separated from the above estate by a linear row of mature trees and a public footpath – FP51/5, which runs in a east to west alignment parallel with the northern perimeter and marked with a metal kissing gate as it emerges onto Thornhill Road, re-commencing off the opposite flank of that highway. The path runs east from the subject site in to an area designated as a Site of Special Scientific Interest (SSSI), known as “Caeau Lotwen”.
2.1.3 To the south, lies the nursing home known as Pen-y-Bryn, which is set within its own spacious grounds, which are well tree-line and which offer a natural screen and buffer to the Candidate Site. Those trees form the entire eastern perimeter of the site with the eastern part of becoming more denser as the site borders the SSSI.
2.1.4 Individual residential properties lie directly opposite, all fronting the western flank of Thornhill Road, and set within modest plots, which are set back from the roadside frontage. The site’s frontage is linear set off the back edge of a continuous pavement, and comprises thinner, younger tree specimens and band of scrub.
2.1.5 The parcel of land is identified in red by Plan A, which illustrates its wider position within the settlement of Cwmgwili and shows the existing consolidated form of
Representation Supporting Statement March 2023
Land off Thornhill Road, Cwmgwili Mr A. Williams
modest industrial estate and frontage development to Thornhill Road. Plan B provides a detailed Ordnance Survey map extract with the site perimeters identified.
Plan A – wider setting of Cwmgwili with site highlighted
Plan B – detailed OS Plan of Alternative Site
Representation Supporting Statement March 2023
Land off Thornhill Road, Cwmgwili Mr A. Williams
2.1.6 Photographs of the Alternative Site are reproduced below, showing its current March 2023 condition and form. The Alternative Site is relatively level and is well grazed to the extent that no overgrowth vegetation is visible. All rear and side mature perimeter trees appear in good health which warrant retention.
Photo 1 – view of level field from Thornhill Road
Photo 2 – view of gated access and footpath entrance
Representation Supporting Statement March 2023
Land off Thornhill Road, Cwmgwili Mr A. Williams
Photo 3 – view to centre of field and thinner, sparse vegetation to road frontage
2.1.7 The open enclosure can be categorised in two portions, being the open expanse of pasture visible from the highway, and an eastern third, segregated from the front field by a drainage ditch. Within this eastern third, the land is more succumbed to nature, overgrown and dense in vegetation as it borders the Caeau Lotwen SSSI to the east.
2.2 SETTLEMENT SUSTAINABILITY AND SITE SETTING WITHIN THE CURRENT ADOPTED LOCAL DEVELOPMENT PLAN & SECOND DEPOSIT DRAFT (FEBRUARY 2023)
2.2.1 Under the provisions of the current adopted Carmarthenshire Local Development Plan, the proposed land adjoins the Settlement Limit of Cwmgwili. The site is shown edged in red at Plan C below. The draft Proposals Map within the Second Deposit Draft repeats the same settlement limits, as shown in Plan D:
Representation Supporting Statement March 2023
Land off Thornhill Road, Cwmgwili Mr A. Williams
Plan C – 2014-adopted Proposals Map with Alternative Site edged in red
Plan D – Second Deposit Draft of Cwmgwili
Representation Supporting Statement March 2023
Land off Thornhill Road, Cwmgwili Mr A. Williams
2.2.2 The Alternative Site adjoins and is well related to the draft defined Development Limits of Cwmgwili. At present the development limits are drawn tightly about the existing settlement form at Thornhill Road. The Alternative Site seeks to form an infill development set between the Heathfield Industrial Estate and Pen-y-Bryn Nursing Home, closing the only modest, undeveloped field frontage along the eastern side of that highway.
2.2.3 Cwmgwili has good accessibility to the nearby settlements of Cross Hands and Ammanford, and the A48 Trunk Road, which junctions at Cwmgwili some one kilometre to the south-west.
2.2.4 In terms of the Thornhill Road Site, it is located within easy driving and walking distance of all community facilities and local services present provided within the Cross Hands settlement.
2.2.5 Transition from Adopted Local Development Plan (2006-21) – Allocation Status
In terms of planned growth, the proposed Alternative Site is located within the identified SC34 Sustainable Community within the current LDP, adopted in December 2014. Cwmgwili is regarded by the Council as sustainable settlement
2.2.6 Two housing allocations were presented within the LDP as shown in Plan E below, which provides an extract from the 2014 Proposals Map for Cwmgwili. Both allocations at Coed-y-Cadno (SC34/h1) and land at the frontage of the Heathfield Industrial Estate (SC34/h2) have long since been completed.
The Second Draft of the Replacement LDP continues to allocate land at Coed-y-Cadno but this was completed several years ago. Plan F illustrates the remarkable contrast where no new residential allocations are brought forward, or new sites introduced, which equates to only infill opportunities being available in the new settlement limits.
Representation Supporting Statement March 2023
Land off Thornhill Road, Cwmgwili Mr A. Williams
Plan E – adopted 2014 LDP Extract for Cwmgwili illustrating two residential allocations
Representation Supporting Statement March 2023
Land off Thornhill Road, Cwmgwili Mr A. Williams
Plan F – Second Draft Plan for Cwmgwili with no new residential allocations
2.2.7 Second Deposit Draft LDP (February 2023) – Housing Land Availability
The Council published a Deposit Draft in February 2023, which is now subject of public consultation. Within the Second Deposit Draft, Cwmgwili sits within the Cross Hands / Ammanford Cluster. The Cluster aims to provide an additional 1257 residential units over the Plan period to 2033, and thus the addition of an allocated site of 20 units at Cwmgwili will not lead to an over-supply of dwellinghouses within the Cluster, nor indeed the settlement itself.
Representation Supporting Statement March 2023
Land off Thornhill Road, Cwmgwili Mr A. Williams
2.2.8 We have examined and researched sites which have been brought forward as Residential Allocations with the Second Deposit Draft. On behalf of clients in this LDP Cluster, we have made formal Representations seeking the omission of the following draft Allocations:
Site PrC3/h4 - Tirychen Farm, Dyffryn Road, Penybanc - for 150 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.
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. Clearly, there is no historic demand for a site of this scale in this part of the Ammanford area. More physically challenging sites, such as the re-development of the Betws Colliery site at Betws and Cae Pound at Cross Hands West Tip have come forward long before Tirychen, and yet still the Council is prepared to allocate the site once again in a new Development Plan.
The decision to retain Tirychen Farm after a period of 30 years within the LDP is shown to be inconsistent, as does not sit with LDP Procedural Guidance which encourages Local Planning Authorities to only re-allocate sites based upon firm evidence of deliverability.
2.2.9 Site PrC3/h22 Land at Pant-y-Blodau in Penygroes for 79 units.
The site was allocated as GA3/h35 in the Adopted 2014 LDP for 90 units. Planning Permission was granted in April 2015, and yet some 8 years later, no work has been undertaken on the site, and the land remains undeveloped. No indication is provided within the Site Assessment Report (January 2023) as to why the Council consider this long-standing allocation to remain in the Plan?
2.2.10 Site PrC3/h14 - Nantydderwen - for 33 Units.
The Land was allocated Carmarthenshire Unitary Development Plan (2006). No progress was made in bringing the site forward, and yet it was allocated within the Local Development Plan in 2014. Consequently, twenty years of Development Plan
Representation Supporting Statement March 2023
Land off Thornhill Road, Cwmgwili Mr A. Williams
allocations have elapsed without any signs of delivery of this site. Clearly, there is no historic demand for a site of this scale in this part of the Drefach area. More physically challenging sites, such as Cae Coch, Cae Pound at Cross Hands and Heol-y-Parc at Cefneithin have come forward despite topographic issues and previous ground contamination, and yet still the Council is prepared to allocate the site once again in a new Development Plan. The land is relatively level with immediate access onto the local highway network.
The decision to retain Nantydderwen after a period of 20 years within the LDP is shown to be inconsistent, as does not sit with LDP Procedural Guidance which encourages Local Planning Authorities to only re-allocate sites based upon firm evidence of deliverability.
2.2.11 We submit that the draft allocations at Tirychen, Nantydderwen and Pantyblodau be omitted from the Plan, and that housing allocations be redistributed to modest Candidate Sites, of up to 20 units such as that proposed at Thornhill Road.
There is clear evidence in Tycroes, Capel Hendre and Cwmgwili that such modest sites are far more likely to be brought forward and developed in full by regional and small housebuilders given that construction and development costs are more likely to be viable in relation to house sales and the general housing market in this part of Carmarthenshire.
In the case of Thornhill Road, there are little signs within the immediate locality of properties for sale, and no evidence of undeveloped land available within this part of the settlement limits, which is a strong indicator of a healthy property market at Cwmgwili. Consequently, it is a location where housing proposals are deliverable, assisting to meet housing needs in this part of Ammanford / Cross Hands.
Representation Supporting Statement March 2023
Land off Thornhill Road, Cwmgwili Mr A. Williams

3.0 THE PROPOSAL
3.0.1 This Statement is accompanied by an indicative layout for a potential residential scheme that could be development on the site. It should be emphasised that the accompanying layout is for illustrative purposes only, and that other design solutions for the site could be reached. Notwithstanding this, the accompanying layout drawing has taken into account all potential assets and constraints of the site and demonstrates that it can deliver 22 units in a deliverable and sustainable manner.

3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Alternative Site be allocated in the forthcoming replacement LDP for the purposes of a combined total of 22 residential units. The accompanying illustrative layout demonstrates that the site can accommodate this number in a deliverable and sustainable manner. Plan G illustrates the indicative site layout for the Alternative Site, as edged in red, extending off the Thornhill Road highway.
Plan G – Site Layout
Representation Supporting Statement March 2023
Land off Thornhill Road, Cwmgwili Mr A. Williams
3.1.2 As illustrated above, the site is capable of accommodating detached and semi-detached houses to replicate and being reflective to the existing form of the development to the west along Thornhill Road, particularly those properties constructed off the frontage of Heathfield Industrial Estate, known as Clos Gwili.
3.1.3 With regards to access, it is proposed that the Alternative Site would be served by a new 6.0 metres wide radii junction, set centrally in the site frontage. The existing Public Right of Way would be fully retained off the northern perimeter, with kissing gate access remaining unaffected. Vehicle speeds are consistent with the 30mph speed limit, and thus visibility splays of 2.4m x 43m can easily be achieved where the accesses adjoin the Thornhill Road.
3.1.4 The Alternative Site proposals can fully retain all existing boundary treatments being established tree perimeter and hedgerows about the Pen-y-Bryn Nursing Home.
3.2 Significant Amendment to Candidate Site Submission of August 2018
3.2.1 The amended Site Proposals put forward under this Representation crucially differ from the Candidate Site submission made in August 2018, where the eastern third of the ownership is omitted from the proposals. The Council’s formal response to that Candidate Site submission, as reproduced in the Site Assessment Table – January 2023 – states that “The site is located immediately adjacent to a site designated for importance to nature conservation.” The Council are referring to the Caeau Lotwen SSSI, the perimeters of which are reproduced in Plan H below, being an extract from the Council’s Constraints Map.
Representation Supporting Statement March 2023
Land off Thornhill Road, Cwmgwili Mr A. Williams
Plan H – Extent of Caeau Lotwen SSSI
3.2.2 The 2018 Candidate Site proposals are reproduced below at Plan I and are shown to extend eastwards from the road frontage to share a perimeter with the SSSI. An ecological buffer strip was shown to the eastern perimeter to segregate new development from that nature conservation designation.
Plan I – 2018 Candidate Site Proposals
Representation Supporting Statement March 2023
Land off Thornhill Road, Cwmgwili Mr A. Williams
3.2.3 In contrast, the new proposals have been scaled back to allow the eastern third of the former Candidate site to remain undeveloped, and thus dramatically increasing the extent of open and retained buffer zone to the SSSI as shown in Plan J below. That buffer zone extends for a depth averaging 50 metres across the northern perimeter and up to 85 metres across the southern perimeter.
Plan J – greater extent of Buffer Zone between Site and SSSI
3.2.4 It is therefore firmly contended that the revised Alternative Site Proposals will overcome the Council’s objections to the original Candidate Site submission, in providing a significantly larger ecological buffer zone between SSSI and proposed development site.
SSSI
SITE
Buffer zone
Representation Supporting Statement March 2023
Land off Thornhill Road, Cwmgwili Mr A. Williams

4.0 CONCLUSION
4.1 The Alternative Site is modest in overall size, with established development located off either side flanks at Thornhill Road. The enclosure tends to be well screened from public view by virtue of high perimeter trees which shelter the site and add a sense of semi-rural character to the scheme.
4.2 The Site lies within close proximity and walking distance to the existing community and local services of Cwmgwili and Cross Hands which will ensure it makes a positive contribution to both national and local sustainable development objectives.
4.3 The Alternative Site has been significantly amended from that put forward as a Candidate Site in 2018, in response to the Council’s Site Assessment Table. A much greater and wider ecological buffer zone has been created so that all the overgrown extending east from a drainage ditch to the common perimeter with the Caeau Lotwen SSSI is preserved as an ecological buffer zone, safeguarding the integrity and nature conservation asset that is that SSSI.
4.4 In view of the above and the information provided within this Statement, it is respectfully requested that the Alternative Site in question be included within limits for a modest residential development.

Include part of candidate site SR/086/003 within the Plan.

We are instructed by Mr. I. Griffiths to a make a formal representation to the “soundness” of
the Second Deposit Draft of the Carmarthenshire Local Development Plan.

Our client made a formal Candidate Site Submission in August 2018, which was referenced
SR/086/003, seeking inclusion of their land for future residential development within the
defined settlement limits of Llangennech within the Replacement Local Development Plan.
The Candidate Site comprises a generally undulated tract of former grazing land set north of
our client’s dwelling known as Cae Hir, and immediately south of the local-authority-built
housing estate of Brynhyfryd, from which it is proposed vehicular access to the Candidate
Site will be derived.
The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our clients’ submission, reasons why the site was not selected for inclusion within the draft
settlement limits of Llangennech, as contained within the Second Deposit Draft.
We note that the submission successfully passed through all two Assessment Stages, being
Stage 1 (site compatible against the location of future growth presented in the Preferred
Strategy), and Stage 2A (Initial Detailed Site Assessment). It however did not proceed
further with the Council having published reasons for non-inclusion, which are reported as
follows:
“There are concerns at the deliverability of the site, most notably from a highway access
point of view. The site will remain outside of development limits (with Cae Hir remaining
within development limits).”
“It
Our client was unrepresented during the Candidate Site stage, and has since instructed this practice to act on his behalf and challenge the non-inclusion of the Candidate Site in the Second Draft of the LDP.
Our clients consider 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, our clients consider that the draft settlement limits for Llangennech, as defined under Policy SD1 “Settlement Limits”, should be amended to include the land as edged in red upon the extract of the Proposals Map for Llangennech as reproduced below in Figure 1. The land should be appropriately allocated for housing under Policy HOM1 “Housing Allocations.”
Figure 1 – Extract from Second Draft Proposals Map with site edged in red
This formal representation letter supplements the following documents which comprise a complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits

1.0 Deliverability of draft Allocation off Brynhyfryd

1.1 The Council consider that the only reason for the Candidate Site off Brynhyfryd for not being included within the draft Plan as a Residential Allocation is that they believe that the access may not be achievable from that cul-de-sac. It is noted from the Council’s Candidate Site records that the extent of actual Candidate Site may be
depicted not as formally submitted by our client. We therefore enclose a revised location plan with site edged in red for ease of identification. Other land in Mr Griffiths’ ownership is edged in blue which includes a buffer area set north of his property at Cae Hir and the Candidate Site proposals.
Figure 2 – Location Plan of Candidate Site

1.2 We have also prepared a more detailed indicative site layout to illustrate how vehicular and pedestrian access could be achieved off Brynhyfryd to cater for an indicative capacity of 9 dwellings. Figure 3 below illustrates this arrangement with a 5.0 metres wide carriageway extending south off he Brynhyfryd hammerhead and entering the field. The new estate road would be equipped with 1.8 metres wide footways off both flanks and would terminate in an adoptable turning head within a central position in the Candidate Site field.
1.3 The proposals under this Representation seek the addition of 9 residential units to the overall housing supply of Llangennech, which forms part of the principal service centre centred upon the Llanelli Cluster as defined within the draft LDP. The road network at Brynhyfryd is perfectly capable of sustaining and catering for the additional volume of traffic associated with only none new dwellings, with the estate’s carriageway constructed of adoptable dimensions to carry two-way traffic with complete pedestrian segregation.
Figure 3 – Indicative Site Layout plan of Representation Site

1.4 The indicative site layout indicates that a mix of two-storey detached and semi-detached dwellings could be brought forward, each equipped with side driveways for off-road parking, together with traditional rear garden space to complement the general theme of established housing in this part of Llangennech.

2.0 Overall Housing Supply at Llangennech within Deposit Draft

2.1 We have therefore examined and researched sites which have been brought forward as Residential Allocations with the Deposit Draft. The Llanelli Cluster aims to provide an additional 3039 residential units over the Plan period to 2033, with Llangennech (Settlement SeC7) providing sites totalling 94 units to that overall Cluster total.

2.2 In Llangennech, great emphasis within the Draft Plan has been placed upon the continued allocation of proposed housing sites still left allocated from the 2014-21 Local Development Plan. Figure 4 below provides an extract from the Second Deposit Draft Schedule of Housing Sites from Policy HOM1.
Figure 4 – Second Deposit Draft Housing Schedule
Sites SeC7/h1 Box Farm, h3 at Golwg yr Afon and h5 at Maesydderwen have remained within the Plan but it is noted that all three suffer from a complete lack of any developer interest and planning permission. Figure 5 provides a reproduction of the 2014-adopted LDP Proposals Map, where all three allocated sites are graphically illustrated. Maesydderwen is allocated as GA2/h54, Box Farm as GA2/h50 and Golwg-Yr-Afon as GA2/h52.
Figure 5 – Adopted LDP Proposals Map for Plan Period 2006-21

2.3 In relation to “Golwg-Yr-Afon” (SeC7/h3) has not altered since the 2014 adopted LDP and remains undeveloped but allocated. No planning permission has ever been sought for residential development on the site. The site was included in the Llanelli Borough Local Plan (1996), Carmarthenshire Unitary Development Plan (2003) and, as mentioned above, within the Local Development Plan (2014).
Consequently, twenty-five years of Development Plan allocations have elapsed without any signs of wholesale delivery of this site, Clearly, there is no historic demand for a site of this scale in this part of the Llangennech area. It is almost certainly a physically challenging site, covered in mature and dense vegetation, with mature trees along its entire eastern perimeter covered and protected by a large Tree Preservation Order. The Google Earth image at Figure 5 below covers the vegetated spread over the site. The site is undoubtedly rich in ecological habitats which may further hinder its delivery. Yet despite these obvious deficiencies, the Council is prepared to allocate the site once again in a new Development Plan?
Figure 5 – Google Earth image (June 2021) of Golwg-Yr-Afon site and extent of tree cover
The decision to retain Golwg-Yr-Afon after a period of 25 years within the LDP is shown to be even more inconsistent, as does not sit with LDP Procedural Guidance which encourages Local Planning Authorities to only re-allocate sites based upon firm evidence of deliverability. The Development Plans Manual (Edition 3) is quite clear with regard to rolling forward allocations and states that allocations “ … rolled forward from a previous plan will require careful justification for inclusion in a revised
Golwg-Yr-Afon residential allocation
plan, aligning with PPW. There will need to be a substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered.”. no evidence has been presented to demonstrate a change in circumstances to indicate the allocation will now be delivered.

2.4 We submit that the draft allocation be omitted from the Plan, and that housing allocation be redistributed to Alternative Sites, such as that proposed off Brynhyfryd. There is clear evidence in Llangennech, Hendy, Fforest and Llanedi that such moderately-sized sites are far more likely to be brought forward and developed in full by regional housebuilders given that construction and development costs are more likely to be viable in relation to house sales and the general housing market in this part of Carmarthenshire.

2.5 In the case of Brynhyfryd and adjoining Pencoed, there are little signs within the immediate locality of properties for second sale, and no evidence of undeveloped land available within this part of the settlement limits, which is a strong indicator of a healthy property market at Llangennech. Consequently, it is a location where housing proposals are deliverable, assisting to meet housing needs in this part of the Llanelli Cluster.

In conclusion, this Representation to the Second Deposit Draft of the Revised LDP has sought to examine the Council’s reasons for non-inclusion of a Candidate Site.
Our clients have illustrated that their indicative proposals to construct circa 9 dwellinghouses will not appear at odds to the prevailing spatial pattern of development in Llangennech. The locality has numerous examples of modern cul-de-sac development being completed at backland locations, which in turn, advocates that the form of development proposed off Brynhyfryd is no different, resulting in it being respectful to the character and setting of the locality.

We respectfully request that this Representation be given careful examination, and consequently the defined settlement limits of this part of Llangennech realigned to include the Representation Site, as a Residential Allocation in the Proposals Map of the adopted Local Development Plan.

Include the site within the Plan

With the Carmarthen Town (Cluster 1) being only area than affects myself I have only focused this
representation on that locality in relation to the 2nd Deposit LDP. I’m in support of the 2nd deposit
LDP proposals, however I do have concerns (certain 'Sound of Testiness' not being met – ie will the
plan deliver) that there are not enough smaller sites to compliment the larger development, for the
reasons giving below.
1. Relies heavily on the larger sites to meet a significant proportion of its housing supply
requirements.
The 2nd deposit LDP relies heavily on the larger sites to meet a significant proportion of its housing
supply requirement during the LDP period. There is a strong case that more smaller sites should
be allocated to minimise the risk for the Local Authority, thus ensuring that supply is maintained
throughout the plan period, in-case these larger sites, in particular the Carmarthen West and
Pibwrlwyd projects do not deliver, due to the scale and complex nature that these large
developments entail.
If we take Carmarthen Town for example the following have been allocated for housing:-
Carmarthen West 700 homes; Pibwrlwyd 245 Homes; Remaining 336 homes. As can be seen the
2 larger developments account for 74% of Carmarthen Town’s housing allocation. As can be seen in
Appendix 7 - Housing Trajectories (Allocations) of the LDP, there is some planning requirements for
both the larger sites in Carmarthen - West Carmarthen & Pibwrlwyd. It should be noted that their
build projection state that they do not come onto site until towards the end of the LDP period.
With this being the case there is little margin for any delay caused by any planning issue, build rate,
or from an economical or financial perspective. Should the Local Authority allocate more smaller
sites then this would reduce this risk for the authority and provide some contingency, ensuring that
supply is maintained throughout the plan period.
A report 'Start to Finish - How Quickly do Large Scale Housing Sites Deliver' (Nov 2016) by Nathaniel
Lichfield & Partner states " allocating more sites rather than less, with a good mix of types and
sizes, and then being realistic about how fast they will deliver so that supply is maintained
throughout the plan period". "There is a growing recognition that large-scale housing
development can and should play a large role in meeting housing need. However, what looks good
on paper needs to deliver in practice. Plans putting forward large sites to meet need must have a
justification for the assumptions they make about how quickly sites can start providing new
homes, and be reasonable about the rate of development. That way, a local authority can decide
how far it needs to complement its large-scale release with other sites – large or small – elsewhere
in its district."
To provide some context I have also extracted some further quotes from this report which can be
found towards the end of this representation.
2. Effects on the Economy having on the release of housing.
The probable recession, slow growth rate, high cost that seems inevitable after the Covid 19
pandemic and Ukraine conflict, will have a significant effect on developers being able to release
housing to meet what supply is required within the LDP period. Not every planning permission
granted will translate into the development of homes. This could mean an entire site does not
come forward, or delivery on a site can be slower than originally envisaged. It is thus not realistic
to assume 100% of planning permission granted in any given location will deliver homes. Planning
permissions can lapse for a number of reasons ie:- landowner cannot get the price for the site that
they want; a developer cannot secure finance or meet the terms of an option; the development
approved is not considered to be financially worthwhile etc. There is a strong case that more
smaller sites should be allocated, to minimise the risk for the Local Authority, thus ensuring that
supply is maintained throughout the plan period. More smaller sites will also benefit the local
economy with smaller contractors / developers being brought on, which will in turn benefit the local
supply chain and the environment.
3. Have current living trends been taken into account?
It is unclear whether the population and household numbers that have been projected in the LDP
have taken into account current living trends ie - young adults still having to live with parents due
to costs and increased percent of older people living alone due to maybe divorce etc. These current
living trends will require further housing allocations being required to try to tackle and overcome
this new issue. The following statistics / statements were published an article written in the
Independent 8th November 2017, which refers to Data released by Office for National Statistics
(ONS): -
‘Data released by the ONS shows that the percentage of young adults living with their
parents in the UK has risen from just over a fifth (21 per cent) in 1996 to 26 per cent in
2017, rising from 2.7 million to 3.4 million in the past two decades.’
‘Concerns over house prices for young adults were raised in research published by
Homeless Charity Shelter in 2014. The study predicted that the proportion of young
adults still living with their parents would pass 50 per cent within a generation unless
radical action was taken to tackle Britain’s housing shortage.
‘‘The ONS data shows that the number of people aged 45 to 64 who lived alone
increased by 53 per cent between 1996 and 2017 – a statistically significant increase.
This is partly due to the increasing population age 45 to 64 years in the UK over this
period, but the increase could also be due to a rise in the proportion of the population
aged 45 to 64 who are divorced or single and never married.’
‘Those aged 65 to 74 years living alone also saw a statistically significant increase of 15
per cent over the two decades. The number living alone aged 75 and over also
increased over the two decades to 2017, by a larger percentage of 24 per cent.’
On merit alone and case for more allocation of smaller sites – Candidate Site SR/021/021 (Land
off Trevaughan Road) to be included within LDP 2018 - 2033
I am writing this representation response, admittedly and primarily due to the reason that the
Candidate Site that I submitted, wasn’t chosen to be included in the new LDP 2018 -2033. I believe
that it there is merit in its own right to include this site going forward, so that it forms part of the
residential allocation within Carmarthenshire LDP 2018 -2033. I would kindly encourage the
Planning Inspector to read the Candidate Site Submission which was submitted and visit this site in
relation to the other sites that have been allocated in the LDP. To add further reasons, should it
be deemed that additional sites are required due to some of the points that I have mentioned in
this representation, I would be grateful if this site could be considered. The site -SR/021/021
(Land off Trevaughan Road) passed all the of the Candidates Sites Assessment Stages (Stages 1, 2a,
2b and 3), however it was not put forward due to the reason “there is sufficient and more suitable
land available”. In the Carmarthen Town area, there were only 2 sites, mine being one of them
that passed all the Candidate Site Assessments but didn’t get through to be allocated.
The candidate site submission document for my site (SR/021/021) was very comprehensive and
proves that a development could be delivered on the site. The candidate site submission
demonstrates that the site is viable and is deliverable for residential purpose. It addresses all the
issues of deliverability such as ecology, highways, drainage, utilities, flooding etc. The candidate
site is solely owned (freehold) by ourselves, with there being no impediment to bring forward this
parcel of land for residential development, and for it to be completed within the LDP period 2018
– 2033.
The ’Site Allocation Assessment – Reasonable Alternatives’ Report by Carmarthenshire County
Council contained in the 2nd Deposit LDP submission marked my site down on 3 aspects, namely:-
(1)no re-use of previously developed land/buildings, (2) within a mineral buffer zone and (3) on
quality agricultural land.
However we would argue the following in relation to those points in that assessment namely:-
(1) No reuse of previously land/building - Part of the application site (towards the north) sits
of the land that has previously been developed. Not only does the site house an existing
shed, but also there are remains of stone walls where once stood a house as evidence of
its existence. The presence of a building can also be confirmed on historical maps which a
copy is shown in the Candidate Site Submission. The possible re-use/ conversion of the
shed / buildings was suggested as part of the Candidate Site Submission. The existing
shed was built in the early 1990's and is constructed out of metal corrugated sheeting which
is supported by a steel portal frame. This building has now deteriorated and could be
considered an eyesore from an aesthetics perspective. This existing shed could be
converted, providing a high quality contemporary architectural approach, using a palette
of quality natural materials. The existing shed could be converted into a Community Hall
which would enhance the local community or into a small enterprise which would
contribute to the authority’s employment objectives.
(2) Within a mineral buffer zone - The site currently lies in a Sand and Gravel Minerals
Safeguarding Zone. However as stated in my Candidate Site Submission if reserves were
proved to be viable any future extraction would need to be at least 250 metres from existing
housing. As such the triangular nature of the site, bounded by existing housing (Derwen
Fechan Housing Development) on one side and with emergency services, fire station etc on
the other, this would restrict works. Therefore the current designation within the LDP
should not present a major constraint given that the site represents a logical extension to
the settlement pattern
(3) On quality Agricultural ground – As part of the Candidate Site Submission we submitted a
Preliminary Ecology Report carried out by Bay Ecology in May 2018. The finding were as
follows :
 The site was comprised of a limited range of habitat types predominantly comprised of an
improved grassland pastoral field bordered by species poor hedgerows and a short treeline.
 In terms of the ecological importance of the site the large improved grassland pastoral field
was of low intrinsic ecological value and represented the most suitable area of the site to
support the development.
With the site being of low ecological value, it is considered that the site is deliverable for
residential development and should not present a major constraint, given that the site
represents a logical extension to the settlement pattern.
The candidate site is right on the outskirts of the current development plan, and the site represents
a logical extension to the settlement pattern, in a sustainable location, adjacent to a key settlement
in a marketable location. With the recent the Charles Church development north of College Road,
and the development of Derwen Fechan directly opposite, the candidate site represents a logical
extension to the settlement pattern.
The recent housing development of Derwen Fechan directly opposite and the presence of the
existing Fire station to the south, would establish that the site is not isolated and is within the built
form. The site is relatively flat and has good containment with established boundaries with its
hedgerow and tree line surrounding the site. The scale and density of the proposed development
shown within the drawings that accompanied the Candidate Site Submission document, reflects
that of existing residential development in the area and is considered to be appropriate, while
addressing the opportunities and constraints of the site.
From a highway and access perspective the land is situated directly off Trevaughan Road so there
is no third party approval required to provide access into the site. It has been demonstrated that
a new road access can be provided into the site allowing for good visibility at the junction. There
are good established links via nearby bus stops, public footpaths and pavement provision to the
Carmarthen Town and the wider areas of the community. In terms of highways and accessibility
it is considered that the site is deliverable for residential development
Existing utilities are present along Trevaughan Road which runs parallel to the sites eastern
boundary, again with no third party approval required (over any other land) to bring these
infrastructure to access into the site.
The candidate site that I put forward is located in close proximity to numerous primary schools but
is also within the 3 mile walking distance of both the English and Welsh Secondary schools. The
site is in walking distance to town with it being only 700 metres away from its centre.
The site offers an opportunity to develop a high quality sustainable neighbourhood, provide a
positive impact upon the Welsh language or any local communities and thus providing a positive
new settlement edge to Carmarthen Town. It is considered that the site can provide a range of
both open market and affordable homes along with high quality open space supporting the wider
Green Infrastructure strategy of Carmarthenshire County Council, creating a highly desirable and
attractive place to live.
In light of the above and to serve future local needs, myself (the land owner and applicant), kindly
requests that the Land off Trevaughan Road, Carmarthen (Candidate Site - SR/021/021) be
designated for Housing Land Allocation, within Carmarthenshire Local Development Plan (2018 -
2033).
Reference Quotes to provide context to this Representation
A resent research report has been written which looked at evidence on speed and rate of delivery
of large scale housing based on a large number of sites across England and Wales (outside London).
The report is 'Start to Finish - How Quickly do Large Scale Housing Sites Deliver' (Nov 2016) by
Nathaniel Lichfield & Partners (Planning Consultancy of the Year 2011 - 2014). Below are a few
extracts of the main findings (in italics) from that report, which provide some context to this
representation:-
"Planned housing trajectories should be realistic, accounting and responding to lapse
rates, lead-in times and sensible build rates. This is likely to mean allocating more sites
rather than less, with a good mix of types and sizes, and then being realistic about
how fast they will deliver so that supply is maintained throughout the plan period.
Because no one site is the same – and with significant variations from the average in
terms of lead-in time and build rates – a sensible approach to evidence and justification
is required."
"Spatial strategies should reflect that building homes is a complex and risky business.
Stronger local markets have higher annual delivery rates, and where there are
variations within districts, this should be factored into spatial strategy choices.
Further, although large sites can deliver more homes per year over a longer time period,
they also have longer lead-in times."
"Large-scale sites can be an attractive proposition for plan-makers. With just one
allocation of several thousand homes, a district can – at least on paper – meet a
significant proportion of its housing requirement over a sustained period."
"But large-scale sites are not a silver bullet. Their scale, complexity and (in some cases)
up-front infrastructure costs means they are not always easy to kick start. And once
up and running, there is a need to be realistic about how quickly they can deliver new
homes. Past decades have seen too many large-scale developments failing to deliver
as quickly as expected, and gaps in housing land supply have opened up as a result."
"This research provides insights to this topic – which has become a perennial discussion
at Local Plan examinations and Section 78 appeals in recent years – by focusing on two
key questions:
 what are realistic lead-in times for large-scale housing developments?; and
 once the scheme starts delivering, what is a realistic annual build rate? "
"On average, larger sites take longer to complete the planning application and lead-in
processes than do smaller sites. This is because they inevitably give rise to complex
planning issues related to both the principle of development and the detail of
implementation."
"Not every planning permission granted will translate into the development of homes.
This could mean an entire site does not come forward, or delivery on a site can be
slower than originally envisaged. It is thus not realistic to assume 100% of planning
permission granted in any given location will deliver homes. Planning permissions can
lapse for a number of reasons:"
 The landowner cannot get the price for the site that they want;
 A developer cannot secure finance or meet the terms of an option;
 The development approved is not considered to be financially worthwhile;
 Pre-commencement conditions take longer than anticipated to discharge;
 There are supply chain constraints hindering a start; or
 An alternative permission is sought for the scheme after approval, perhaps when a
housebuilder seeks to implement a scheme where the first permission was secured by a
land promoter.
"If more homes are to be built, more land needs to be released and more planning
permissions granted. Confidence in the planning system relies on this being achieved
through local plans that must be sufficiently ambitious and robust to meet housing
needs across their housing market areas. But where plans are not coming forward as
they should, there needs to be a fall-back mechanism that can release land for
development when it is required. "
"Spatial strategies should reflect that building homes is a complex and risky business. Stronger
local markets have higher annual delivery rates, and where there are variations within districts,
this should be factored into spatial strategy choices. Further, although large sites can deliver
more homes per year over a longer time period, they also have longer lead-in times. To secure
short-term immediate boosts in supply – as is required in many areas – a good mix of smaller
sites will be necessary. "

Amend the plan to include the site

We are instructed by Mr P. Harries & Mrs J. Sainty to a make a formal representation to the
“soundness” of the Second Deposit Draft of the Carmarthenshire Local Development Plan.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/067/012, seeking inclusion of their land for future residential development within the
defined settlement limits of Gorslas within the Replacement Local Development Plan. The
Candidate Site comprises an undeveloped field enclosure set primarily to the rear of
residential properties which front the eastern flank of Church Road in Gorslas. The site has
an undeveloped plot which lies between detached houses on Church Road which leads
directly to the field at the rear.
We have noted that the frontage plot is included within the draft settlement limits, however
the adjoining, rear field has not been included. This formal Representation relates solely to
the unsuccessful part of the Candidate Site.
The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our clients’ submission, reasons why the site was not selected for inclusion within the draft
settlement limits of Gorslas, as contained within the Second Deposit Draft. We note that the
submission successfully passed through all initial stages, being Stage 1 (site compatible
against the location of future growth presented in the Preferred Strategy) and Stage 2A
(Initial Detailed Site Assessment). However, at Stage 2B (further detailed site assessment)
of the Council’s Assessment, it was concluded that the Candidate Site was not appropriate
to proceed, citing that “There is sufficient and more suitable land available for development
within the area to accommodate its housing need. Development at this location may impact negatively upon the amenity of adjacent residential properties.

Our clients consider 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, our clients consider that the draft settlement limits for Gorslas, as defined under Policy SD1 “Settlement Limits”, should be amended to include the land as edged in red upon the extract of the Proposals Map for Gorslas, as reproduced below in Figure 1. The land should be appropriately allocated for housing under Policy HOM1 “Housing Allocations.”

Figure 1 – Extract from Draft Proposals Map with Representation site edged in red

This formal representation letter supplements the following documents which comprise a complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits

1.0 Overall Housing Supply at Cross Hands / Ammanford with Deposit Draft

1.1 The Council consider that the only reason for the Candidate Site at Church Road not being included within the draft Plan as a Residential Allocation is that they believe that there are sufficient residential sites allocated elsewhere in the settlement. On this basis, it must be accepted that the form of the Candidate Site set to the rear of established properties which front Church Road, together with the proposals to
utilise the existing vehicular access (subject to appropriate widening and junction
alignment) is deemed acceptable, and in accord with the spatial form and character
of the settlement.

1.2 The proposals under this Representation merely seek the addition of circa 6
residential units to the overall housing supply of Gorslas, which forms part of the
principal service centre of Cross Hands, and within the Ammanford / Cross Hands
Cluster as defined within the draft LDP. Figure 2 below provides an extract of the
indicative site layout plan for this Representation site.
Figure 2 – Indicative Site Layout Plan of Representation Site

1.3 The Ammanford / Cross Hands Cluster aims to provide an additional 1267 residential
units over the Plan period to 2033, and thus the addition of an allocated site of only 6
units will not lead to an over-supply of dwellinghouses within the Cluster.

1.4 Only one site is allocated within the draft settlement limits of Gorslas, that being Site
PrC3/h18 “Land adjacent to Brynlluan”. That site is expected to provide for 29 units. It
is considered that the settlement of the scale of Gorslas is highly sustainable given its
close proximity to Cross Hands and its wealth of retail, employment and community
facilities. The addition of only one modest site in the village will not bring enough
housing for the remainder of the new Plan Period. The addition of one further, very
modestly sized site of only 6 units will not place a burden on facilities, not the semi-rural backdrop to the settlement.

1.5 We have examined and researched sites which have been brought forward as Residential Allocations with the Second Deposit Draft. On behalf of clients in this LDP Cluster, we have made formal Representations seeking the omission of the following draft Allocations:
Site PrC3/h4 - Tirychen Farm, Dyffryn Road, Penybanc - for 150 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.

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. Clearly, there is no historic demand for a site of this scale in this part of the Ammanford area. More physically challenging sites, such as the re-development of the Betws Colliery site at Betws and Cae Pound at Cross Hands West Tip have come forward long before Tirychen, and yet still the Council is prepared to allocate the site once again in a new Development Plan.
The decision to retain Tirychen Farm after a period of 30 years within the LDP is shown to be inconsistent, as does not sit with LDP Procedural Guidance which encourages Local Planning Authorities to only re-allocate sites based upon firm evidence of deliverability.

1.6 Site PrC3/h22 Land at Pant-y-Blodau in Penygroes for 79 units.
The site was allocated as GA3/h35 in the Adopted 2014 LDP for 90 units. Planning Permission was granted in April 2015, and yet some 8 years later, no work has been undertaken on the site, and the land remains undeveloped. No indication is provided within the Site Assessment Report (January 2023) as to why the Council consider this long-standing allocation to remain in the Plan?

1.7 We submit that the draft allocations at Tirychen and Pantyblodau be omitted from the Plan, and that housing allocations be redistributed to modest Candidate Sites, of up to 10 units such as that proposed at Church Road. There is clear evidence in Gorslas, Cefneithin and Drefach that such modest sites are far more likely to be brought forward and developed in full by regional and small housebuilders given that
construction and development costs are more likely to be viable in relation to house sales and the general housing market in this part of Carmarthenshire.

1.8 In the case of Church Road, there are little signs within the immediate locality of properties for second sale, and no evidence of undeveloped land available within this part of the settlement limits, which is a strong indicator of a healthy property market at Gorslas. Consequently, it is a location where housing proposals are deliverable, assisting to meet housing needs in this part of Cross Hands.

2.0 Proximity to Neighbouring Properties

2.1 This Representation to the Second Deposit Draft of the Revised LDP has sought to examine the Council’s reasons for non-inclusion of a Candidate Site.

Our clients have illustrated that their indicative proposals to construct circa 6 dwellinghouses as a sensitive small development will not appear at odds to the prevailing spatial pattern of development in Gorslas. The Council’s assessment conclusion that “Development at this location may impact negatively upon the amenity of adjacent residential properties” is without foundation, and completely contradictory. The locality has numerous examples of modern cul-de-sac development being completed at backland locations, especially opposite, off the western flank of Church Road, which in turn, advocates that the form of development proposed off the eastern flank of Church Road is no different, resulting in it being respectful to the character and setting of the locality. The indicative site layout plan illustrates that new dwellings can be positioned to remain at a healthy and commensurate habitable distance from existing neighbouring properties backing on to the site from Church Road.

We respectfully request that this Representation be given careful examination, and consequently the defined settlement limits of this part of Gorslas realigned to include the Representation Site, as a Residential Allocation in the Proposals Map of the adopted Local Development Plan.

Allocate the site for housing within the Revised LDP.

We are instructed by Mr. D. Sims & Mr P. Cromwell to a make a formal representation to the
“soundness” of the Second Deposit Draft of the Carmarthenshire Local Development Plan.
Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/135/003, seeking inclusion of their land for future residential development within the
defined settlement limits of Pontargothi within the Replacement Local Development Plan.
The Candidate Site comprises a rectangular-shaped former grazing field set fronting the A40
trunk road, and immediately adjoining the Memorial Hall in Pontargothi. The site is generally
undulated, with a slight fall in gradient away from the road frontage, which is marked with a
well-maintained linear hedgerow, growing off the back edge of a continuous pavement along
this straight section of highway.
The field descends to a well-defined southern hedgerow boundary which separates from
further agricultural land running to the River Towy. It is proposed to develop the grazing field
for a low-density residential development, potentially of single-storey units / bungalows set
over a uniform cul-de-sac type layout.
The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our clients’ submission, reasons why the site was not selected for inclusion within the draft
settlement limits of Pontargothi, as contained within the Deposit Draft. We note that the
submission successfully passed through all three Assessment Stages, being Stage 1 (site
compatible against the location of future growth presented in the Preferred Strategy), and
Stage 2A (Initial Detailed Site Assessment). However, did not progress past Stage 2b
(Further Detailed Site Assessment) with reasons for non-inclusion reported as follows:
“Development would lead to an illogical extension of the urban form. There is sufficient residential land allocated in the settlement. The Site will remain outside of limits.”
Our clients consider 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, our clients consider that the Second draft settlement limits for Pontargothi, as defined under Policy SD1 “Settlement Limits”, should be amended to include the land as edged in red upon the extract of the Proposals Map for Pontargothi, as reproduced below in Figure 1. The land should be appropriately allocated for housing under Policy HOM1 “Housing Allocations.”
Figure 1 – Extract from Pontargothi Proposals Map with site edged in red
This formal representation letter supplements the following documents which comprise a complete submission to the Second Deposit Draft Consultation stage:
- Completed Second Deposit LDP Representation Form
- Completed Sustainability Appraisal form
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits
1.0 Response to Setting of Site within Village Form
1.1 The Council consider that the site will be an “illogical extension to the urban form” of the settlement. Firstly, we must correct Officers that Pontargothi is a rural village which has no “urban form.” The Candidate Site has a frontage with the A40 road and lies immediately adjoining the Memorial Hall and its surfaced car park. The site is linked to the village by virtue of its close proximity on foot via the established pavement along the entire southern flank of the road.
1.2 The site takes a form which can utilise the existing agricultural field access which can be improved through widening and adapted with dedicated junction radii. Visibility standards for emerging vehicles are very good given the presence of a wide pavement along this straight section of highway, which forms part of a 40-mph speed limit, indicative of the built-up nature of the settlement at this point.
1.3 The westward extension of settlement through the development of the Candidate Site would be no different in form from Allocated Site SuV17/h1, located some half a kilometre metres south-west of the Candidate Site at Nantgaredig. That site extends to some 4 acres of level grazing field for several hundred metres back from a road frontage with Station Road. The Candidate Site adopts a similar roadside form, ensuring thst the perimeters of the site are contained with defensible field boundaries, marked by linear hedgerows and tree-lined field boundaries.
1.4 Therefore, we consider that the Council has adopted this rather inconsistent approach on the basis that it only considers that Pontargothi and neighbouring Nantgaredig should grow by very minor proportions over the Plan Period to 2033. However, the village of Pontargothi is significant in scale, containing over 150 dwellinghouses, two public houses and Memorial Hall. It also possesses good public bus service connections to Carmarthen and Llandeilo. In other words, it is sustainable as a place to live and work.
1.5 The Representation Site indicative site layout plan is reproduced below as Figure 2. It illustrates for cul-de-sac form of development with a total of 30 detached and semi-detached bungalows set fronting an internal estate road, which can access the site a principal new junction off the A40. Thus the proposed form of layout and development is complementary in form to adjacent established form of residential layouts seen at the northern flank of neighbouring Nantgaredig between the Primary School and A40 junction.
Figure 2 – Indicative site layout plan of proposed Representation Site
2.0 Overall Housing Supply at Pontargothi, Nantgaredig and
Carmarthen Cluster with Second Deposit Draft
2.1 The proposals under this Representation merely seek the addition of a further 30
residential units to the overall housing supply of Pontargothi within the draft Plan.
Pontargothi is defined as sustainable settlement (SuV18), and lends to the
principal service centre centring upon the Carmarthen Cluster as defined within the
Second draft LDP.
2.2 The Carmarthen Cluster aims to provide an additional 1690 residential units over the
Plan period to 2033, and with Pontargothi contributing only one site, being SuV18/h1
allocated for a total of 15 units. We submit that an allocation of 30 units will not lead
to an over-supply of dwellinghouses within the Cluster.
2.3 Pontargothi is quite unique in terms of its positioning and setting being part of the
Carmarthen Cluster. It is placed at the eastern extremity of the defined area,
bordering the Llandeilo / Llandovery (Towy Valley) Cluster. Nantgaredig and
Pontargothi serve a rural hinterland and are the principal settlements within the
central Towy Estuary between Carmarthen and Llandeilo. Policy HOM1 provides
details of the allocations in the Towy Valley east of Carmarthen and within Cluster 1,
as shown below.
Figure 3 – Policy HOM1 Residential Allocations in Towy Valley and Cluster 1
2.4 We note that the Llanarthne School redevelopment site has already been completed (SuV15/h1), whilst the Capel Site is half completed (SuV16/h1).
2.5 Only one site is allocated in neighbouring Nantgaredig, and that relates to 35 residential units at Station Road (SuV17/h1). It has been the subject of any planning application to develop residential properties, but, however, the determination of that application has been hampered by the continuing embargo placed upon sites which will eventually drain foul water to sewerage treatment plants entering the River Towy. Elevated levels of phosphate in that river are such to be materially affecting its designation as a Special Area of Conservation, and it is alleged that treated foul water flows from public sewerage utilities may be one contributing factor to those excessive phosphate levels in the river.
2.6 This is in contrast the next nearest allocation to Nantgaredig, being the allocated site at Pontargothi, referenced “land adjoining Cresselly Arms” – Site SuV18/h1. It has the benefit of full planning permission for 15 dwellings, and where work has commenced on an access road.
2.7 We have examined and researched sites which have been brought forward as Residential Allocations with the Second Deposit Draft in the Carmarthen Cluster. The Cluster extends in geographic area to Bronwydd, Cynwyl Elfed, Peniel, Rhydargaeau, Alltwalis and Llanpumsaint to the north of the town. It stretches south-west to Llansteffan and Llangain, and east along the River Towy to include Nantgaredig, Pontargothi, Llanarthney and Capel Dewi. It extends along the A48 road as far as Llanddarog and Porthyrhyd. Finally, it stretches south-east along the Towy Estuary to include Cwmffrwd and Ferryside and partly along the Gwendraeth
Valley to Pontyates. The following allocations are noted for their inactivity and undeliverability over the last 8-9 years.
2.8 West Carmarthen (PrC1/MU1) – 700 UNITS
In Carmarthen, great emphasis within the Draft Plan has been placed upon the continued allocation of a large, proposed housing site at West Carmarthen. The site is allocated for 700 residential units as Site PrC1/MU1.
This allocation forms the bulk of a Residential Allocation carried over from the current LDP (2014-21) where the allocation was for 1100 units.
We have calculated that of that 1100 units only a total of 141 were constructed between the Plan Adoption date of December 2014 and start of this Replacement LDP Plan Period of 2018. Since 2018, a further 90 units have been constructed, and we note from Land Registry records that the last completed unit was sold at Maes Macsen in September 2021 (18 months ago).
Therefore, since adoption of the 2014 LDP, only a total of 231 units have been completed, equating to a build rate over that 7-year period of only 33 units per annum. This build rate is considerably lower than the anticipated and much promised delivery of 1100 units in the Plan Period of 2014 to 2021, which would have expected an annual build rate of 157 units. An actual return of 33 units per annum equates to only a 21% build rate return on that anticipated for delivery in the 2014-21 Plan.
Only 39 of those units were built in 2017-18 accordingly to the Joint Housing Land Availability Study 2018. The 2019 Study reveals that only a further 5 units were constructed in 2018-19. The August 2019 Study reports that none were under-construction at that time. During 2020 and 2021 when Covid-19 restrictions were at their peak, more units were constructed than at any other time in that LDP plan period, and therefore we would submit at this point in our formal objection that low build rates cannot be held to be reduced as a consequence of Covid-19 restrictions.
It is equally noteworthy that at a time when the housing market was at its most buoyant in 2022, that the only housebuilder with a track record on the site had ceased construction and sold their last completion (September 2021). We submit that this is testament to the weak marketability of the West Carmarthen Site.
Only 231 units out of 1100 units of the Strategic Site have therefore been completed in the 2014-21 LDP period, which equates to only 21% of that allocated total.
The Replacement LDP seeks to delivery 700 units over a Plan Period from 2018 to 2033. The extract from the Proposals Map for Carmarthen reveals that the figure includes for 90 units constructed between 2018 and 2021, leaving a balance of 610 units envisaged in the remainder of the Plan Period to 2033. That would equate to a build rate of 61 units per annum over a 10-year period. Based upon previous
build rates at this site, such a predicted build rate can be described as overly optimistic, being nearly double that actually achieved on the site to date.
The West Carmarthen draft allocation includes parcels of residential allocations off the flanks of the A40 that were previously allocated within the Carmarthen District Local Plan (1997), and subsequent Carmarthenshire Unitary Development Plan (2003). No progress was made in bringing the sites at Llysonnen Road and Old St. Clears Road forward, and yet it was allocated within the Local Development Plan in 2014. Consequently, twenty-seven years of Development Plan allocations have elapsed without any signs of delivery of the majority of this site.
Clearly, there is no historic demand for a site of this scale in this part of Carmarthen. More physically challenging sites, such as the Roman Park site in Llangunnor by Redrow Homes, and the Mount Pleasant site, also in Llangunnor, by Lovell Homes have come forward, and been fully completed, long before West Carmarthen. Yet still the Council is prepared to allocate the site once again for hundreds of residential units in a new Development Plan.
2.8 Pibwrlwyd (Site PrC1/MU2) – ALLOCATION OF 247 UNITS
We would also question the allocation of land at Pibwrlwyd in Carmarthen, being partly for a residential development of 247 units on the Parc Pibwrlwyd development. The Council published and subsequently adopted Supplementary Planning Guidance on “Pibwrlwyd” in 2014.
Paragraph 3.2 was quite specific in that “The LDP describes the acceptable uses on the site as follows: “The proposed use for the site is for a business park centred around employment uses (Use Classes B1, B2 and B8), with uses associated with, and ancillary to the existing Coleg Sir Gâr.”
A development brief in the form of SPG has been prepared and adopted. This in setting out appropriate uses under Use Classes B1, B2 and B8 for the employment element of the site also explores other compatible uses. Residential use on this site is not considered appropriate.” (self-emphasis)
The Council has seen fit to re-examine the Development Plan status of this Mixed-Use Site and concluded that residential uses should now be brought forward, with a residential capacity of 247 units. No explanation has been provided within the supporting text to LDP policies to warrant a dramatic departure from the adopted SPG.
The site is completely and physically divorced from established housing at Pensarn and Llangunnor. It is physically separated by foot from local schools, community facilities and play facilities by the A40 / A48 trunk road network, with only a dark and insecure pedestrian underpass linking it to the Pensarn Commercial Area.
New housing at this location would accordingly be quite alien in form to the long-established business and education uses at Pibwrlwyd.
2.9 Land off Parc-y-Delyn (PrC1/h4) – ALLOCATED FOR 17 UNITS
This new allocation suffers from including Tree Preservation Orders imposed upon specimens at the proposed vehicle access onto Parc-y-Delyn.
The site also appears covered in rich flora and fauna and could harbour biodiversity interests.
2.10 As referenced at the outset of this Section, there are several satellite settlements about Carmarthen contributing housing allocations to the Cluster Total of 1690 dwellings. However, we have discovered that many allocations have simply and conveniently been “rolled over” from the 2014 adopted LDP, or in some cases even earlier from the 2008 Unitary Development Plan. No explanation, evidence or demonstration of viability or deliverability has been provided within the Site Assessment Table (January 2023) to demonstrate such a widespread practice. The following sites are examples of such dormant sites:
2.11 Cae Camfas, Heol Llanelli, Pontyates (SeC1/h4) – ALLOCATED FOR 8 UNITS
This site in Pontyates was allocated in 2014 in the Local Development Plan, and yet no applications for planning permission have been submitted in the entire 8 years of the Plan Period.
2.12 Gwyn Villa, Llanpumsaint (SuV12/h1) – ALLOCATED FOR 20 UNITS
This site in Llanpumsaint was allocated in 2014 in the Local Development Plan, and yet no applications for planning permission have been submitted in the entire 8 years of the Plan Period.
2.13 Fronheulog, Cynwyl Elfed (SuV1/h1) – ALLOCATED FOR 8 UNITS
This site in Cynwyl Elfed was allocated in 2014 in the Local Development Plan, and also the 2008 UDP, and applications for planning permission have been submitted for only two individual houses in the the entire 15 years of the above combined Plan Periods have been commenced.
2.14 We submit that the above draft allocations at West Carmarthen be significantly reduced in scale, and in the case of Pibwrlwyd and above-named satellite allocations be omitted from the Plan and that housing allocation be redistributed to modest Candidate Sites, of up to 20-30 units such as that proposed at Pontargothi. There is clear evidence in Pontargothi, such as the progress to a detailed scheme at the Cresselly Arms site, that such modest sites are far more likely to be brought forward and developed in full by regional and small housebuilders given that construction and development costs are more likely to be viable in relation to house sales and the general housing market in this part of Carmarthenshire.

3.0 CONCLUSION
In conclusion, this Representation to the Second Deposit Draft of the Revised LDP has sought to examine the Council’s reasons for non-inclusion of all the Candidate Site.

Our clients have illustrated that their indicative proposals to construct a total of 30 bungalows will not appear at odds to the prevailing spatial pattern of development in Pontargothi. The locality has numerous examples of modern cul-de-sac development being completed at backland / edge of settlement locations, which in turn, advocates that the form of development proposed at the land adjoining the Memorial Hall is no different, resulting in it being respectful to the character and setting of the locality.

We respectfully request that this Representation be given careful examination, and consequently the defined settlement limits of this part of Pontargothi realigned to include the whole Representation Site, as a Residential Allocation in the Proposals Map of the adopted Local Development Plan.

Allocate the land for residential use within the RLDP.

1 General Description
1.1 This LDP Representation relates to the potential inclusion of a new
site allocation for residential development in the Carmarthenshire
Revised Local Development Plan 2018 – 2033.
2 LDP Representation
2.1 The statement has been prepared by Ceri Davies BA Hons, Dip UP,
MRTPI, (Director of Ceri Davies Planning Ltd). The statement is
based on information provided by the client and other consultants.
All stated dimensions and distances are approximates and based on
the best information available at the time. Please refer to the
submission plans for detailed information.
2.2 The LDP Representation details include:
• 2
nd Deposit Revised LDP Representation Form
• Integrated Sustainability Appraisal
• Location & Site Plans
• Planning Statement
3 Client Details
3.1 The clients are Owain Ennis of Llaindelyn, Llaindelyn Rd, St Clears,
Carmarthen, SA33 4BB; Anne Birt of Egypt House, Queens Parade,
Tenby, SA70 7EH; Hugh Booth Meller-Haley of Millside Studio,
Llanddowror, Carmarthen, SA33 4HR.
4 The Site
4.1 The site is an irregular shaped piece of land forming part of three
separate field enclosure on the outskirts of St Clears. The fields in
question are currently used for grazing and keeping of horses. The
fields front onto Heol Llaindelyn and lie north-west of St Clears
Roundabout.
4
4.2 Access to the site would be gained directly off Heol Llaindelyn,
which comes off the A477 Trunk Road, via the Old Tenby Road. The
site is bounded by mature hedgerows along its southern and
eastern boundaries.
4.3 The site lies just north of a grouping of dwellings at the western end
of St Clears. There is a residential dwelling directly opposite and a
small cluster of dwellings at the end of Heol Llaindelyn. The location
of the site and its proximity to the settlement of St Clears is
illustrated on the map extract below (Figure i).
Figure i – Location Map

4.3 Whilst the site currently occupies an open countryside location, it
lies in close proximity to a predominantly residential area within the
settlement of St Clears. The proximity of the site to the settlement
is shown on the aerial photograph below (Figure ii).
Figure ii – Aerial Photograph
5
4.4 Vehicular access into the site is currently gained via the existing field
entrances which come directly off the adjacent public highway.
5 The Development
5.1 The aim of this proposal would be to develop the site for residential
purposes. The site would be able to clearly accommodate 5+ plots,
as such would be an additional housing allocation that could
potentially contribute towards the future housing needs for St
Clears.
5.2 The plan extract below (Figure iii) illustrates the scale of the site.
6 Policy Context
6.1 A review of the planning policy context associated with the site and
the proposed development (at national and local level) is provided
within this section of the Statement.
National Planning Policy
6.2 Well-Being of Future Generations (Wales) Act (2015)
6.2.1 The Act places a duty upon public bodies to produce well-being
objectives that contribute to achieving a set of overarching wellbeing goals:
6
• A Prosperous Wales;
• A Resilient Wales;
• A Healthier Wales;
• A More Equal Wales;
• A Wales of Cohesive Communities;
• A Wales of Vibrant Culture and Thriving Welsh Language; and
• A Globally Responsible Wales.
6.2.2 Each public body is then required to take reasonable steps to meet
their objectives in the context of the principle of sustainable
development and whilst following a set of five ways of working.
6.2.3 The 'Resilient Wales' and 'Healthier Wales' goals are the key goals
that open space and greenspace, as part of the planning process will
contribute towards delivering.
6.3 Planning Policy Wales : Edition 11 (February 2021)
6.3.1 Planning Policy Wales (PPW) forms the overarching national
planning policy document for Wales and sets out the land use
planning policies of the Welsh Government. It is supplemented by a
suite 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 main
objective of PPW is to promote place-making and sustainable forms
of development.
6.3.2 The primary objective of PPW is to ensure that the planning system
contributes towards the delivery of sustainable development and
improves the social, economic, environmental and cultural wellbeing of Wales, as required by the Planning (Wales) Act 2015,
the Well-being of Future Generations (Wales) Act 2015 and other
key legislation. PPW and National Development Framework (NDF)
7
set out how the planning system at a national. Regional and local
level can assist in delivering these requirements through strategic
Development Plans(SDPs) and Local development Plans (LDPs).
6.3.3 There are a number of key planning principles indicated within
Planning Policy Wales (PPW) to achieve the right development in
the right place.
6.3.4 Paragraph 1.18 emphasises that the legislation secures a
presumption in favour of sustainable development in accordance
with the development plan, unless material considerations indicate
otherwise. The principles of sustainable development are defined in
the Well-being of Future Generations Act.
6.3.5 Paragraph 1.22 of PPW states that up-to-date development plans
are the basis of the planning system and that these set the context
for rational and consistent decision making, where they have been
prepared in accordance with up to date national planning policies.
6.3.6 These key planning principles are set out with a view to achieve a
number of national sustainable placemaking outcomes, as
explained in paragraphs 2.15-2.20 and outlined in Figure 4. The
national sustainable placemaking outcomes are:
People and Places: Achieving Well-being Through Placemaking
• Growing our economy in a sustainable manner
• Making best use of resources
• Maximising environmental protection and limiting environmental
impact
• Creating and sustaining communities
• Facilitating accessible and healthy environments
6.3.7 Paragraph 2.17 states “In responding to the key principles for the
planning system, the creation of sustainable places and in
recognition of the need to contribute to the well-being of future
generations in Wales through placemaking, development plans and
development proposals must seek to deliver development that
address the national sustainable placemaking outcomes”.
6.3.8 Sustainable development forms a key consideration central to all
policies contained within Planning Policy Wales (PPW). Paragraph
1.2 states: “The primary objective of PPW is to ensure that the
planning system contributes towards the delivery of sustainable
8
development and improves the social, economic, environmental
and cultural well-being of Wales, as required by the Planning
(Wales) Act 2015, the Wellbeing of Future Generations (Wales) Act
2015 and other key legislation.”
6.3.9 Paragraph 2.27 sets out how to assess the sustainable benefits of
development: “Planning authorities should ensure that social,
economic, environmental and cultural benefits are considered in
the decision-making process and assessed in accordance with the
five ways of working to ensure a balanced assessment is carried out
to implement the Well-being of Future Generations Act and the
Sustainable Development Principle. There may be occasions when
one benefit of a development proposal or site allocation outweighs
others, and in such cases robust evidence should be presented to
support these decisions, whilst seeking to maximise contributions
against all the well-being goals.”
6.3.10 Paragraph 2.17 states that “in responding to the key principles for
the planning system, the creation of sustainable places and in
recognition of the need to contribute to the well-being of future
generations in Wales through placemaking, development plans and
development proposals must seek to deliver developments that
address the national sustainable placemaking outcomes.”
6.4 Future Wales: The National Plan 2040
6.4.1 Future Wales – The National Plan 2040 is Wales’ national
development framework which sets out the direction for
development in Wales to 2040. It is a development plan that sets
out a strategy for addressing key national priorities including
sustaining and developing a vibrant economy, achieving
decarbonisation and climate-resilience, developing strong
ecosystems and improving the health and wellbeing of our
communities.
6.4.2 The spatial strategy is a guiding framework which sets out the key
national policies that will guide and encourage development which
supports sustainable growth in both urban and rural areas across
Wales.
Policy 1 – Where Wales will grow
6.4.3 Policy 1 is the overarching policy which sets out where sustainable
growth will take place in Wales. Three National Growth Areas have
9
been established where there will be growth in employment and
housing opportunities and investment in infrastructure. The
National Growth Areas are:
• Cardiff, Newport and the Valleys;
• Swansea Bat and Llanelli; and
• Wrexham and Deeside.
6.3.4 These National Growth Areas are complemented by Regional
Growth Areas, which will grow, develop and offer a variety of public
and commercial services at regional scale. There are Regional
Growth Areas in three regions:
• The South West;
• Mid Wales; and
• The North.
6.3.5 In addition to the above growth areas, there are a mix of smaller
towns and villages and large areas of countryside. The policy states
that ‘development in towns and villages in rural areas will support
local aspirations and need, complementing rather than competing
with efforts to grow our cities and towns.’
Local Planning Policy
6.4 The proximity of the site to the defined settlement development
limits for St Clears in the current Local Development Plan (LDP) is
illustrated in the map extract below, Figure (iv).
Figure iv – Current LDP Proposal Map

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6.5 The proximity of the site to the defined settlement development
limits for St Clears in the 2
nd Deposit Revised Carmarthenshire Local
Development Plan (LDP) is illustrated in the map extract below,
Figure (v).
11
7 Detailed Consideration
7.1 As highlighted in the Integrated Sustainability Appraisal (ISA), it is
asserted that the site is deemed compatible with Strategic Policy
SP3 of the revised LDP which seeks to ensure the provision of
growth and development is directed to sustainable locations in
accordance with the spatial framework.
7.2 Given its proximity to St Clears, which is identified as a Cluster 6,
Tier 2 – Service Centre within the Settlement Framework, ISA
Objective 1 (Sustainable Development) is satisfied in this instance.
7.3 As illustrated on the plan below (Figure vi), the site represents a
sustainable location given its close proximity to St Clears.
Figure vi – Location Plan
7.4 The site clearly relates well to the settlement of St Clears which is
classed as a Service Centre in Strategic Policy SP3 of the LDP.
7.5 Natural Resources Wales Development Advice Maps indicate that
the site does not lie within a Zone C1 or C2 flood area as defined by
the development advice maps referred to in Technical Advice Note
15, Development and Flood Risk (TAN 15), as illustrated in the DAM
extract below (Figure vii).
7.6 TAN15 states that new development should be directed away from
Zone C and towards zone A, otherwise to zone B, where river or
12
coastal flooding will be less of an issue. The site is not considered to
be at risk of flooding during at least the 1 in 1000 year event.
7.7 The development advice maps supplemented by sediment data,
held by the British Geological Survey (BGS), of historical flooding.
The maps adopt a precautionary principle and are based on the best
known information available at the time. It is noted that the NRW
flood maps show the site as being flood free during the Q100 event
and Q1000 event.
Figure vii – DAM Map
7.8 The Flood Map for Planning Wales also indicates that the site is not
at risk from localised or surface water flooding; this is illustrated on
the FMfP extract below (Figure viii).
Figure viii - FMfP
The Site
The Site
13
7.9 The Flood Risk Map demonstratesthat the site falls outside of Flood
Zone 2 and Flood Zone 3, as such falls within and an area deemed
at low flood risk from rivers. The site will not be affected during the
1 in 1000 fluvial (Q1000 event or 0.1% event) and would also be
flood free during the 1 in 100 (Q100) flood event.
7.10 The site does not fall within a C1 or C2 flood risk zone as delineated
by TAN15 DAM flood maps. Neither does it fall within a Flood Zone
2 or Flood Zone 3 as delineated by FMfP (Flood Map for Planning
Wales). As such, ISA Objective 4 (Climatic Factors) and ISA Objective
5 (Water) are both satisfied in this instance.
7.11 The site is not located within or immediately any of the following
designated sites:
• Sites of Special Scientific Interest (SSSI)
• Special Areas of Conservation (SAC)
• Special Protection Areas (SPA)
• National Nature Reserves (NNR)
• Local Nature Reserves (LNR)
• Common Land or registered village green
As such, ISA Objective 2 (Biodiversity) is satisfied in this instance.
7.12 The site is not located within or immediately adjacent to any
Scheduled Monuments. As such, ISA Objective 8 (Cultural Heritage
and Historic Environment) is satisfied in this instance.
7.13 The proposed housing allocation is deemed appropriate at this
location in that it would not impact on any core planning principles.
The development would be sited immediately adjacent and
opposite existing residential dwellings and also in close proximity to
the edge of the existing settlement. The map extract below (Figure
ix) illustrates the existing pattern of development at this part of the
village, and the proximity of the site to the existing built form
14
7.14 Clearly the development would not lead to unacceptable ribbon
development; it would not be deemed tandem development. It
would not lead to unacceptable coalescence of settlements and
given its siting between existing properties it would be classed as a
form of infill, as such, cannot be described as unacceptable sporadic
development or an unacceptable extension to the settlement.
7.15 In addition it would not result in the loss of areas of public open
space and formal recreational land. Given the aforementioned, it is
asserted that the development would not be contrary to general
planning principles.
7.16 The development would sit comfortably at this location without
having any detrimental impact whatsoever on the character or
setting of the settlement. Furthermore, the development would not
have any detrimental impact on any features of the settlement such
as landscapes, townscapes or buildings of importance as a result of
its scale, density and prominence. As such, ISA Objective 8 (Cultural
Heritage and Historic Environment) along with ISA Objective 9
(Landscape) are both satisfied in this instance.
7.17 The proposal will not involve the re-use of suitable previously
developed land, hence, it is acknowledged that the site is a
greenfield site, as such, ISA Objective 7 (Soil) is not entirely satisfied
in this instance. The site has a road frontage boundary that fronts
onto an Heol Llaindelyn. As such, the site is readily accessible from
the existing public highway. The site has a number of existing and
established field entrances with adequate visibility splays, which
allows direct access into the site.
7.18 Heol Llaindelyn is not a through-road, and is a relatively quiet road
which primarily serves 3-4 residential properties. Heol Llaindelyn
does not access directly onto the A477 Trunk Road, but is accessed
via the Old Tenby Road. The junction onto the A477 Trunk Road, also
known as Tenby Road is served by adequate visibility splays.
7.19 The map below (Figure x) illustrates the number of crashes in the
immediate vicinity of the site.
15
Figure x (Source:Crashmap.co.uk)
7.20 Data obtained from Crashmap.co.uk confirms that in the last 10
years, there have been no slight, serious or fatal crash incidents
along Heol Llaindelyn or the Old Tenby Road, and, only one slight
accident on close to the A477 road junction. This would suggest that
there are no highway issues relating to the site or the public road(s)
which serve the site.
7.21 The site lies in close proximity to National Cycle Network Route 4,
which is approximately ½ mile away. This is illustrated on the
Sustrans National Cycle Network Map extract below (Figure xi).
Figure xi (Source Sustrans)
16
7.22 In addition, the site would be very accessible to a number of
footpaths as identified on the Active Travel Network Map,
annotated in green on the plan extract below (Figure xii).
Figure xii – Source: Active Travel Network Map
7.23 The site is readily accessible to a local bus services with the nearest
bus stop less than a 5 minute walk away.
7.24 It is considered the site has suitable access to public transport as
well as identified active travel routes, as such, satisfies the following
ISA Objectives; ISA 3 (Air Quality), ISA 4 (Climatic Factors), ISA 6
(Material Assets), ISA 12 (Health & Well-being), ISA 13 (Education
s& Skills), ISA 15 (Social Fabric).
7.25 Given its location within a field enclosure, the site lies immediately
adjacent to an accessible green space. In addition, the site is very
accessible to a number of identified play areas in the settlement of
St Clears. The nearest play space identified on the LDP Proposals
Map is approximately 600 metres away which represents a
reasonable walking distance. As such, it is considered the site
satisfies ISA Objective 12 (Health & Well-being) and ISA Objective 15
(Social Fabric) .
7.26 The site is within a reasonable walking distance of the service centre
which has a wide range of employment/retail provisions, services
and facilities. Whilst the site clearly occupies a rural location, it
17
represents a very sustainable location given its close proximity to
the service centre.
7.27 It is considered the site is within a reasonable distance of a number
of employment and retail provisions as well as other local services
and facilities, given its proximity to St Clears. As such, the site
satisfies the following ISA Objectives; ISA 6 (Material Assets), ISA 10
(Population), ISA 14 (Economy), ISA 15 (Social Fabric).
7.28 The site represents a sustainable location in terms of its proximity
to nearby nursery schools. The site is also within a reasonable
distance of Whitland Secondary School (7.5km) and St Clears
Primary School (0.5km). As such, ISA Objective 13 (Education &
Skills) is satisfied in this instance.
7.29 The site is not located within or adjacent to a mineral buffer zone,
as such, ISA Objective 6 (Material Assets) is satisfied in this instance.
The site is partly located within a Mineral Safeguarding Area, as
such, ISA Objective 6 (Material Assets) is not entirely satisfied in this
instance. The site is not located within or immediately adjacent to
an a Air Quality Management Area (AQMA), as such, ISA Objective
3 (Air Quality) is satisfied in this instance.
7.30 The site does not contain high carbon e.g. peatlands, as such, ISA
Objective 7 (Soil) is satisfied in this instance. The site does not
contain high quality agricultural land (grades 1,2 or 3A, as identified
within the Agricultural Land Classification Maps). As such, ISA
Objective 7 (Soil) is satisfied in this instance.
7.31 The site is not located within or immediately adjacent to any
Regionally Important Geological or Geomorphological Sites. As
such, ISA Objective 9 (Landscape) is satisfied in this instance.
7.32 The site is located within close proximity to a viable water
connection and is also located within close proximity to other viable
infrastructure requirements such as electricity and main sewer.
7.33 The site is not located within or adjacent to a phosphate sensitive
SAC catchment. A such, As such, the site satisfies the following ISA
Objectives; ISA 2 (Biodiversity), ISA 5 (Water) & ISA 7 (Soil).
7.34 The site by virtue of its scale and location, would not have the
potential to have a detrimental impact on the Welsh Language. As
such, ISA Objective 11 (Welsh Language) is satisfied in this instance.
18
7.35 The traffic movements associated with the development proposal
will be marginal and the development could be accommodated on
the highway network and will not have a detrimental impact on the
free flow of traffic due to the existing volumes of traffic using the
local highway network. There are no access or transport constraints
to prevent the development of the site for residential purposes.
7.36 It is asserted that owing to the nature of the development proposal
i.e. residential, the development has due regard to the existing built
form and also character and appearance of the surrounding area.
Careful consideration has been given to the site selection to ensure
the relationship between the proposed dwellings and existing
development in close proximity is acceptable. It is considered that a
housing site at this location would conform with the character and
appearance of the immediate area in terms of siting and land use.
7.37 It is not disputed that the siting of residential dwellings at this
location would introduce built form at an otherwise undeveloped
site. However, the dwellings would not represent a prominent or
conspicuous form of development. While the proposed
development would inevitably change the character of the site
itself, the proposed changes would not be to the extent that would
result in an unacceptable impact on the surrounding landscape.
7.38 The development would not be readily visible from the wider area;
the mature trees and vegetation along the site boundaries would,
to a degree, mitigate any visual impact.
7.39 Given the aforementioned, it is considered that any resulting
development would not be inappropriate or disproportionate in
scale. It is on this basis that it is considered that the proposal would
represent a sensitive form of development, commensurate with the
existing built form, hence would not adversely affect the spatial
character of the village.
7.40 The development would not have a significant impact on the
amenity of adjacent land uses, properties, residents or the
community. The impact on the amenity of nearby residents has
been fully considered and duly discounted, particularly given the
separation distance between the site and the nearest residential
properties.
7.41 Overall, the proposed development would satisfy PPW’s objective
of achieving sustainable development both by ensuring that the
19
local community has access to sufficient housing and affordable
options whilst also working to facilitate a modal shift to more
sustainable methods of transport and reducing car borne journeys.
8 Summary and Conclusion
8.1 This Planning Statement has been completed on behalf of Owain
Ennis, Anne Birt and Hugh Booth Meller-Haley and provides
planning support for the inclusion of additional land in the revised
Local Development Plan to accommodate potential residential
development adjacent to Heol Llaindelyn, St Clears.
8.2 It has been established that the principle of residential development
is compliant with both national and local policy and represents an
acceptable form of development at this location. The development
would assist with the housing land supply situation in the county.
8.3 While residential development at this location would inevitably
change the character of the site itself, the proposed changes would
not result in an unacceptable impact on the surrounding landscape
nor would they have an adverse impact on the existing neighbouring
development, highway network or local infrastructure.
8.4 In conclusion, it has been demonstrated that there are significant material considerations weighing in favour of the inclusion of this site for residential development in the upcoming revised local development plan.

Include Candidate Site reference SR/159/008 as an allocation in the Plan.

We are instructed by Mr P. & Mrs J. Knight to a make a formal representation to the
“soundness” of the Second Deposit Draft of the Carmarthenshire Local Development Plan.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/159/008, seeking inclusion of their land for future residential development within the
defined settlement limits of Tycroes within the Replacement Local Development Plan. The
Candidate Site comprised two parts, being a former commercial yard, which fronts the
northern flank of Hendre Road, set between established residential properties. The second
part of the Candidate Site was the immediately adjoining former grazing field to the rear of
the frontage yard, with access derived to that field through the frontage yard.
Planning permission has subsequently been granted to construct detached dwellinghouses
across the site frontage with a gap retained to allow for an adoptable access estate road to
reach land at the rear.

We have noted that the former commercial yard of the Candidate Site is included within the
draft settlement limits, however the adjoining, northern field has not been included. This
formal Representation relates solely to the unsuccessful part of the Candidate Site.
The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our clients’ submission, reasons why the site was not selected for inclusion within the draft
settlement limits of Tycroes, as contained within the Second 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) and Stage 2A (Initial Detailed Site Assessment) of the Council’s site assessment.
However, it was rejected at Stage 2B (further detailed site assessment), with reasons for non-inclusion reported as follows:
“Inclusion of the site would result in an illogical extension of the settlement. However, part of the site will be included within the development limits to allow for a smaller development opportunity along the site's frontage.”

Our clients consider 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, our clients consider that the draft settlement limits for Tycroes, as defined under Policy SD1 “Settlement Limits”, should be amended to include the land as edged in red upon the extract of the Proposals Map for Tycroes, as reproduced below in Figure 1. The land should be appropriately allocated for housing under Policy HOM1 “Housing Allocations.”
Figure 1 – Extract from Second Draft Proposals Map with site edged in red
This formal representation letter supplements the following documents which comprise a complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits

1.0 Perception of Illogical Extension to Settlement Limits

1.1 The Council consider that the inclusion of the site within defined settlement limits as a Residential Allocation would be an “illogical extension to the settlement limits.” However, no detailed justification is made for that statement.
In response, our clients would point to various backland-type developments that have evolved over the last 20 years in Tycroes, Capel Hendre and Saron, where modern, cul-de-sac forms of housing have been granted planning permission and completed on former greenfield sites to the rear of traditional, frontage housing.
Three nearby examples are provided below as Figures 2, 3, 4 and 5 being extracts from Google Earth and the Second LDP Draft, and which graphically depict modern housing in a backland setting either built or proposed under this same LDP, namely at Hendre Road, Heol-y-Parc in Cefneithin, Waterloo Road in Penygroes and Parc-y-Mynydd in nearby Saron Road respectively.
Figure 2 – Extract from Google Earth illustrating backland housing
at Hendre Road
Adjacent backland development to Candidate Site
Candidate Site
Figure 3 - Extract from Second Deposit Draft with backland development at Parc-y-Mynydd, Saron
Figure 4 - Extract from Second Deposit Draft proposing backland development at Heol-Y-Parc, Cefneithin
Figure 5 - Extract from Second Deposit Draft illustrating proposed backland development at Waterloo Road, Penygroes

1.2 We therefore consider that the Council has adopted a rather inconsistent approach
in the spatial pattern of allocating and subsequently granting planning
permission of residential development within the settlement between
Ammanford and Cross Hands. Use has continually be made of developing sites
with an initial phase of development across a short frontage to a principal road, such
as that propose at Hendre Road. The welcome re-development of a brownfield
opportunity would logically lead to further phases to the rear, within a field which
remains enveloped by mature woodland. Furthermore, only a single access, in the
form of an estate road carriageway could be developed, as in the case of the aforementioned
Parc-y-Mynydd example, which would allow new residents to continue to
access the excellent community facilities in the locality, such as the nearby Capel
Hendre Industrial Estate, Tycroes and Saron Primary Schools, convenience shops at
Tycroes Square and main bus route that includes Hendre Road.

1.3 The Representation Site indicative site layout plan is reproduced below as Figure 6. It
illustrates for only three detached dwellinghouses set fronting the northern flank of
Hendre Road, and thus also complementary in form to adjacent established forms of
residential development along this highway. A modest cul-de-sac development could
be formed to the rear field.
Figure 6 – Indicative site layout plan of proposed Representation Site

2.0 Overall Housing Supply at Ammanford / Cross Hands with Deposit Draft

2.1 The proposals under this Representation merely seek the addition of circa 13 residential units to the overall housing supply of Ammanford / Cross Hands. Tycroes forms part of the principal service centre centring upon the Ammanford / Cross Hands Cluster as defined within the draft LDP.
The Ammanford / Cross Hands Cluster aims to provide an additional 1257 residential units over the Plan period to 2033, and thus the addition of an allocated site of 13 units will not lead to an over-supply of dwellinghouses within the Cluster.

2.2 We have examined and researched sites which have been brought forward as Residential Allocations with the Deposit Draft. Only two sites are allocated for housing in Tycroes, but in both cases those allocations have already been fully completed. Figure 7 below illustrates those two sites at Fforestfach, off Heol Tycroes, and land off Ffordd y Deri by Pobl Group, adjoining the Rugby Club.
Extract from Policy HOM1 indicating only two sites for housing in Tycroes
Figure 7 – Both allocations in Tycroes are now fully completed before the Replacement LDP is even adopted

2.3 We have examined and researched sites which have been brought forward as Residential Allocations with the Second Deposit Draft. On behalf of clients in this LDP Cluster, we have made formal Representations seeking the omission of the following draft Allocations:
Site PrC3/h4 - Tirychen Farm, Dyffryn Road, Penybanc - for 150 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.
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. Clearly, there is no historic demand for a site of this scale in this part of the Ammanford area. More physically challenging sites, such as the re-development of the Betws Colliery site at Betws and Cae Pound at Cross Hands West Tip have come forward long before Tirychen, and yet still the Council is prepared to allocate the site once again in a new Development Plan.
The decision to retain Tirychen Farm after a period of 30 years within the LDP is shown to be inconsistent, as does not sit with LDP Procedural Guidance which encourages Local Planning Authorities to only re-allocate sites based upon firm evidence of deliverability.

2.4 Site PrC3/h22 Land at Pant-y-Blodau in Penygroes for 79 units.
The site was allocated as GA3/h35 in the Adopted 2014 LDP for 90 units. Planning Permission was granted in April 2015, and yet some 8 years later, no work has been undertaken on the site, and the land remains undeveloped. No indication is provided within the Site Assessment Report (January 2023) as to why the Council consider this long-standing allocation to remain in the Plan?

2.5 We submit that the draft allocations at Tirychen and Pantyblodau be omitted from the Plan, and that housing allocations be redistributed to modest Candidate Sites, of up to 13 units such as that proposed at Hendre Road.

2.6 There is clear evidence in Tycroes, Capel Hendre and Saron that such modest sites are far more likely to be brought forward and developed in full by regional and small housebuilders given that construction and development costs are more likely to be viable in relation to house sales and the general housing market in this part of Carmarthenshire.

2.7 In the case of Hendre Road, there are little signs within the immediate locality of properties for sale, and no evidence of undeveloped land available within this part of the settlement limits, which is a strong indicator of a healthy property market at Tycroes. Consequently, it is a location where housing proposals are deliverable, assisting to meet housing needs in this part of Ammanford / Cross Hands.
In conclusion, this Representation to the Deposit Draft of the Revised LDP has sought to examine the Council’s reasons for non-inclusion of a Candidate Site.

Our clients have illustrated that their indicative proposals to construct circa 13-15 dwellinghouses as a second phase to the former commercial yard re-development will not appear at odds to the prevailing spatial pattern of development in Tycroes and Saron. The locality has numerous examples of modern cul-de-sac development being completed at backland locations, which in turn, advocates that the form of development proposed at Hendre Road is no different, resulting in it being respectful to the character and setting of the locality.

We respectfully request that this Representation be given careful examination, and consequently the defined settlement limits of this part of Tycroes realigned to include the Representation Site, as a Residential Allocation in the Proposals Map of the adopted Local Development Plan.

Allocate the site for housing within the Revised LDP.

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

2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Alternative Site relates to a parcel of land measuring approximately 11 acres in
area in total, edged red on the plan and the photograph below.
Plan A
Photograph 1
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman
2.1.2 As can be seen, the Site consists largely of two parcels of land, both of which consist
of areas of semi-improved grassland, as illustrated below.
Photograph 2 Photograph 3
2.1.3 As can be seen from the above photographs, the site slopes gently downwards in
south to north direction. In addition, all its boundaries are clearly and well defined, the
majority of which are mature tree lines or hedgerows. The exception is the northern
boundary, which is defined by post and wire stock proof fencing that borders with
Cwmamman Road.
2.1.4 Access to the site is currently gained via an existing field entrance off a private
access lane that runs along the western boundary of the site. However, any future
development would gain access directly off Cwmamman Road, due to the excellent
visibility in both directions from this point, as established in a previous planning
appeal for residential development on the site.
2.1.5 Under the provisions of the current Carmarthenshire LDP, part of the Alternative Site
is currently allocated for residential development (shaded brown in Plan B).
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman
Plan B
2.1.6 Following a positive pre-application enquiry with the Authority (LPA Ref. No.
PRE/01244), our Clients (the new owners of the site) are now progressing with a
planning application for the current allocation area. However, due to the level of
demand for new housing in the area, this submission as part of the 2nd Deposit LDP
consultation process therefore seeks allocation of the remainder of the land
ownership for residential development purposes.
2.2 THE ADJOINING SETTLEMENT
2.2.1 As detailed above, the Alternative Site adjoins the existing built form of the settlement
of Glanaman and is in fact bordered by it on much of its three sides. The Site is also
located a short distance from the settlement’s core to the north east and within
walking distance of a number of its community facilities and local services.
2.2.2 Access to further facilities in adjoining settlements and those areas adjoining the
County can then be gained by regular bus services (including numbers 64, 124, 145
and 146), a number of stops for which are within a short walk of the Alternative Site.
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman
The strong sustainable position of the urban area should therefore be given full
consideration when considering potential future growth options.
2.2.3 In terms of planned growth for Glanaman/Garnant, the 2nd Deposit LDP currently
contains only two small housing allocations (amounting to only 20 units) for the Plan
period. This in itself is surprising, considering the sustainable qualities of the
settlement and in particular the current land owners commitment to the development
of the Site in question.
2.2.4 In addition to the above, the proposed Alternative Site lies in close proximity and is
well related to one of the 3 identified Principal Centres within the 2nd Deposit LDP
Within these areas, the majority of the County’s growth (particularly with regards to
housing) is expected to be accommodated within the Plan period. However, having
undertaken a comprehensive review of the proposed allocations put forward by the
2nd Deposit LDP for the Principal Centre in question, it has been identified that a
number have significant questions over their ability to be delivered within the Plan
period, including the following:
Ref. No. Site Name Units
PrC3/h4 Tirychen Farm 150
PrC3/h36 Betws Colliery 60
PrC3/h14 Nantydderwen, Tumble 33
PrC3/h22 Adj. to Pant y Blodau, Penygroes 79
PrC3/h2 Heol Gelynen, Brynamman 8
Table 1
2.2.5 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 March 2023
Land off Cwmamman Road, Glanaman

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 84 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 84 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 Cwmamman Road, Glanaman
3.1.2 As illustrated above, the site is potentially capable of accommodating a mix of unit
sizes and types, with the associated density – 84 units – having therefore taken into
consideration this potential mix. Such a mix would also include a proportion of
affordable units.
3.1.3 With regards then to access, it is proposed that the Alternative Site would be served
be a new access point (following that approved previously) directly off Cwmamman
Road, running along the Site’s northern boundary. The Site would then be served by
a new public highway designed to adoptable standards, as well as a series of private
shared drives where required.
3.1.4 The Alternative Site proposal would also retain and strengthen existing boundary
treatments, as well as accommodating further biodiversity enhancements within a
detailed scheme for the site.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Any development of the Alternative Site for residential units would be served by
mains water, public sewer and electricity, connections to which we understand lie
within or in close proximity to the Site.
3.2.2 With regards then to surface water, it is considered that as a result of on-site
features, there would be a number of options available to any development of the site
in terms of its disposal, ensuring its development adheres to current regulatory
requirements.
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman

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, together then with the provision of mitigation measures where required as
part of any detailed design solution prepared for the Site as part of any future
planning application.
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 Glanaman 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 March 2023
Land off Cwmamman Road, Glanaman
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 Cwmamman Road, Glanaman
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.
4.3.3 Much of the Amman Valley has a history of previous coal mining activity and the area
around the Alternative Site is no exception, as illustrated by the accompanying Coal
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman
Minin Risk Assessment report prepared for the soon to be submitted planning
application. However, as can be seen from the accompanying report, there are no
fundamental attributes associated with the areas mining history that would prevent
the delivery of the Alternative Site.
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman

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 £1,250 per metre (allowing for
ground conditions)
 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 Cwmamman Road, Glanaman
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 84 units, with 16 units being made available on an affordable basis (based
on 16 three bed units).
Costs Cost Per Unit/Metre No. Units/Metres Total
2 Bed Det House (88 sq.
m.) 110000 38 4180000
3 Bed House (115 sq. m.) 143750 30 4312500
3 bed bungalow (120sq m) 150000 5 750000
4 Bed (144 sq m) 180000 11 1980000
Road Construction 1200 800 960000
Utility Connections 5000 84 420000
Professional Fees - 1758548
Sprinklers 3500 84 294000
Parks and Education Cont. 5000 84 420000
Total 5832548
Sales
3 Bed semi(115 sqm) (Aff.) 78380 16 1254080
2 Bed Det House (88 sq.
m.) 165000 38 6270000
3 Bed House (115 sq. m.) 200000 14 2800000
3 bed bungalow (120sq m) 230000 5 1150000
4 Bed (144 sq m) 265000 11 2915000
Total 14389080
Developers Profit Total 2590034.4
Residual Land Value 5966497.6
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
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman
Building Regulations), it is considered that in-principle, the development of the site
would be financially viable.
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 4-5 years from the adoption of the Replacement Local Development
Plan.
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman

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 Cwmamman Road, Glanaman

7.0 CONCLUSION
7.1 Although currently undeveloped, the Alternative Site forms a logical existing element
and extension to an existing settlement, being well related to it and being positioned
at a location within the wider landscape to not form a prominent or logical part of the
surrounding open countryside.
7.2 In addition to the above, the Site lies within close proximity and walking distance of
the existing community services and local facilities of the adjoining settlement, as well
as an element of the larger conurbation of Ammanford to the west. This will then
ensure it makes a positive contribution to both national and local sustainable
development objectives.
7.3 From a wider sense, the Site will also benefit from well served excellent public
transport links to the adjoining larger conurbation of Ammanford and indeed beyond,
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 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 proposed for
allocation in the 2nd Deposit LDP in terms of their suitability and deliverability.
National planning policy however would suggest that in view of the uncertainty in
relation to their delivery, such sites should not form part of the replacement LDP.
7.5 With the Alternative Site having no access, ground condition, flood risk, hydrological,
ecological, archaeological or land ownership related constraints, its delivery if
Alternative Allocation Report March 2023
Land off Cwmamman Road, Glanaman
19
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

We are instructed by Nisa Local Drefach Limited to a make a formal representation to the
“soundness” of the Second Deposit Draft of the Carmarthenshire Local Development Plan.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/049/019, seeking inclusion of their land for future residential development within the
defined settlement limits of Drefach within the Replacement Local Development Plan. The
Site off Heol Caegwyn comprises an industrial warehousing yard which is set at a backland
position off the eastern flank of Heol Caegwyn. The site is odd in that it forms a commercial
property which has residential development set immediately adjoining along the frontage of
Heol Caegwyn, with the rear garden boundaries of those properties sharing a common
boundary of some 113 metres with the industrial yard.
Planning permission has been sought to demolish the warehousing buildings on the site and
construct detached and semi-detached dwellinghouses across the central swath of the yard.
The rear boundary of the yard takes the form of a linear hedgerow established off the
northern boundary of an associated yard, located directly off the rear elevations of the
existing warehousing buildings.
The Candidate Site submission in August 2018 sought to include this rear yard within the
draft settlement limits of the Local Development Plan. However, we note in checking the
Council’s reasoning as to why they have not included this portion of the Maesygwern site
that they have incorrectly plotted the boundaries of the Candidate Site submission. The
above Candidate Site reference is shown as the majority of the warehousing yard, subject to
a current application for planning permission and does not include the rear yard, to which the actual Candidate Site submission focussed upon.

We have noted that the majority of the former commercial yard at Maesygwern continues to be included within the draft settlement limits of the second Draft of the LDP. However the adjoining, northern associated yard has not been included. This formal Representation relates solely to the unsuccessful part of the Candidate Site.
The Council have published a “Site Assessment Table” (January 2023) which provides details of the Council’s analysis of each received Candidate Site submission, and in the case of our clients’ submission, reasons why the site was not selected for inclusion within the draft settlement limits of Tycroes, as contained within the Second 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) and Stage 2A (Initial Detailed Site Assessment) of the Council’s site assessment.
However, it was rejected at Stage 2B (further detailed site assessment), with reasons for non-inclusion reported as follows:
“Site to be included within the development limits to reflect the existing built form. The site will not be allocated for residential use as there are concerns regarding its deliverability.”

Our clients consider 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, our clients consider that the draft settlement limits for Drefach, as defined under Policy SD1 “Settlement Limits”, should be amended to include the land as edged in red upon the extract of the Proposals Map for Drefach, as reproduced below in Figure 1. The land should be appropriately allocated for housing under Policy HOM1 “Housing Allocations.”
Figure 1 – Extract from Second Draft Proposals Map with site edged in red
This formal representation letter supplements the following documents which comprise a complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits

1.0 Non-Inclusion based on Existing Built Form

1.1 The Candidate Site relates to part of an industrial warehousing yard which is set at a backland position off the eastern flank of Heol Caegwyn. The site is odd in that it forms a commercial property which has residential development set immediately adjoining along the frontage of Heol Caegwyn, with the rear garden boundaries of those properties sharing a common boundary of some 113 metres with the industrial yard.

1.2 The warehousing yard occupies a land area of 0.6 hectares (1.5 acres) and has the benefit of two vehicular accesses, both consisting of surfaced tracks lying between established residential properties. The warehousing buildings themselves are inter-connecting but comprise three different phases of industrial sheds constructed at different periods during the use of the land for warehousing. Consequently, each building has a different floorspace, roof span, height and materials differ throughout.

1.3 The Candidate Site sought inclusion of the northern, rear part of the warehousing yard into the settlement limits of the Local Development Plan, with the existing buildings and sheds already included. The settlement limit runs immediately off the rear, northern elevation of those sheds leaving a yard depth of some 24 to 31 metres extending northwards to a well-defined hedgerow and part tree-lined perimeter with neighbouring grazing pasture. That rear yard has been used in the past to externally store plant, machinery and materials, as well as park and manoeuvre vehicles.

1.4 The long rear gardens of Heol Caegwyn properties extend to run parallel with the eastern boundary of the yard, which is marked by a copse of trees. The western side perimeter is marked by a mature hedgerow to open pasture beyond which extends around to the afore-mentioned long, rear perimeter.

1.5 The Candidate Site is actually only 0.3 hectares (0.75 acres) being the remaining rear yard and is identified by being edged in red on the plans below. Plan A illustrates their wider position with the settlement of Drefach, whilst Plan B provides a detailed Ordnance Survey map extract with the site perimeters identified.
Plan A – Setting of Site in wider Drefach context
Detailed OS Plan - Plan B

1.6 The Council consider the warehousing yard as a “site to be included within the development limits to reflect the existing built form.” However, the setting of the limits
does not reflect its existing built form given that it does not include all of the rear yard which forms an integral and fundamental part of the site.

1.7 Google Earth has captured the setting and physical form of the site in that the “defensible” boundary at the site is the rear boundary fence which acts to formally define the transition from brownfield yard to agricultural enclosure and woodland.
Figure 2 - Extract from Google Earth (June 2021) illustrating extent of rear yard and northern boundary with adjoining pasture

1.8 We therefore consider that the Council has adopted a rather inconsistent approach in the spatial pattern of setting development limits. It is abundantly clear that the warehouse as a whole is bounded by established hedgerows and individual trees. To draw an arbituary limit across this yard is unreasonable, and prevents the logical redevelopment of this brownfield site.

1.9 We refer the Council to the consistent and longstanding approach held in National Planning Policy, being the overriding guidance in Planning Policy Wales that new development should also be initially steered to re-developing brownfield sites, before considering greenfield options as alternatives. To exclude the rear yard at Maesygwern is to deny the landowner the opportunity to ensure that all brownfield development is removed and redeveloped as a whole warehousing yard site.

1.10 The Candidate Site submission included a site layout plan, illustrating how the site as a whole could be developed (Figure 4 below). This should be compared to the site layout presented under Planning Permission W/35156. That application has reached a point where all consultees have no objections to the scheme to develop 12 dwellinghouses within the existing and adopted settlement limits (Figure 3).
Figure 3 – site layout plan as presented under Application W/35156
Figure 4 – Site layout plan of Representation Site, which includes whole yard site at Maesygwern

1.10 The above site layout plans illustrate that the warehousing yard could be completed as a whole off a singular access to Heol Caegwyn, and contribute a further 10 dwellinghouse, to bring the site to a combined total of 24 units.

2 Overall Housing Supply at Ammanford / Cross Hands with Deposit Draft

2.1 The proposals under this Representation merely seek the addition of circa 10 residential units to the overall housing supply of Ammanford / Cross Hands. Drefach forms part of the principal service centre centring upon the Ammanford / Cross Hands Cluster as defined within the draft LDP.
The Ammanford / Cross Hands Cluster aims to provide an additional 1257 residential units over the Plan period to 2033, and thus the addition of an allocated site of 10 units will not lead to an over-supply of dwellinghouses within the Cluster.

2.2 We have examined and researched sites which have been brought forward as Residential Allocations with the Deposit Draft. Only three sites are allocated for housing in Drefach, but one at Cae Coch has already been fully completed by Haywood Homes. Figure 5 below illustrates those three sites at Cae Coch, Nantydderwen and Heol Caegwyn.
Figure 5 - Extract from Proposlas Map indicating the three sites for housing
Figure 6 – HOM1 allocations in Drefach

2.3 We have examined and researched sites which have been brought forward as Residential Allocations with the Second Deposit Draft. On behalf of clients in this LDP Cluster, we have made formal Representations seeking the omission of the following draft Allocations:
Site PrC3/h14 - Nantydderwen - for 33 Units.
The Land was allocated Carmarthenshire Unitary Development Plan (2006). No progress was made in bringing the site forward, and yet it was allocated within the Local Development Plan in 2014. Consequently, twenty years of Development Plan allocations have elapsed without any signs of delivery of this site. Clearly, there is no historic demand for a site of this scale in this part of the Drefach area. More physically challenging sites, such as Cae Coch, Cae Pound at Cross Hands and Heol-y-Parc at Cefneithin have come forward despite topographic issues and previous ground contamination, and yet still the Council is prepared to allocate the site once again in a new Development Plan. The land is relatively level with immediate access onto the local highway network.
The decision to retain Nantydderwen after a period of 20 years within the LDP is shown to be inconsistent, as does not sit with LDP Procedural Guidance which encourages Local Planning Authorities to only re-allocate sites based upon firm evidence of deliverability.

2.4 Site PrC3/h22 Land at Pant-y-Blodau in Penygroes for 79 units.
The site was allocated as GA3/h35 in the Adopted 2014 LDP for 90 units. Planning Permission was granted in April 2015, and yet some 8 years later, no work has been undertaken on the site, and the land remains undeveloped. No indication is provided within the Site Assessment Report (January 2023) as to why the Council consider this long-standing allocation to remain in the Plan?

2.5 We submit that the draft allocations at Nantydderwen and Pantyblodau be omitted from the Plan, and that housing allocations be redistributed to modest Candidate Sites, of up to 24 units such as that proposed at Maesygwern at Heol Caegwyn.

2.6 There is clear evidence in Drefach and Cefneithin that such modest sites are far more likely to be brought forward and developed in full by regional and small housebuilders given that construction and development costs are more likely to be viable in relation to house sales and the general housing market in this part of Carmarthenshire.

2.7 In the case of Heol Caegwyn, there are little signs within the immediate locality of properties for sale, and no evidence of undeveloped land available within this part of the settlement limits, which is a strong indicator of a healthy property market at Drefach. Consequently, it is a location where housing proposals are deliverable, assisting to meet housing needs in this part of Ammanford / Cross Hands.

In conclusion, this Representation to the Deposit Draft of the Revised LDP has sought to examine the Council’s reasons for non-inclusion of a Candidate Site.
Our clients have illustrated that their indicative proposals to construct circa 24 dwellinghouses, wit 10 under this Representation as a second phase to the former commercial yard re-development will not appear at odds to the prevailing spatial pattern of development in Drefach. The locality has numerous examples of modern cul-de-sac development being completed at backland locations, which in turn, advocates that the form of development proposed at Maesygwern is no different, resulting in it being respectful to the character and setting of the locality.

We respectfully request that this Representation be given careful examination, and consequently the defined settlement limits of this part of Drefach realigned to include the Representation Site, as a Residential Allocation in the Proposals Map of the adopted Local Development Plan.

Amend the Plan to include the site

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 Plan to include the site

The candidate site referenced above was rejected at stage 2b of the site assesment process for the following reason:

“Whilst there is some linear development within this part of Glandy Cross, development should be centred around the main cluster of dwellings within the settlement”.

In summary, the points / comments raised below set out an objection for the reason given for the refusal and seek the Council to review it’s decision. The points raised covers (1) Linear Development policy and (2) Land Location / Suitability.

Linear / Ribbon Development
Although the response from the Council states its preference is towards cluster builds in this settlement area it can be argued this policy to dissmiss potential linear / ribbon development out of hand lead to missed opportunities and overlook other qualities the site has to offer. Admittedly, the use of he word ‘should’ leaves some ambiguity in their decision.

It seems the Council has assumed the site will develop linear builds along the A478 as a matter of course, similar to the existing dwellings nearby. No build plans have been submitted to date.
The candidate site has potential to accommodate up to 6 / 7 moderate residendtial homes and with inventive planning there is an opportunity to locate some of the builds at the back end of the site to take in the stunning views across the Preseli range. It may be argued a mix of front and back house locations reduces the perceived negative aspects of linear development. For example, shared drives / feeder lanes to reduces number of gateways to the highway. This inturn it minimises the loss of hedgerow and vegetation along the road frontage.

The Council also recognise “ ... some linear development” exists but in fact the majority of the housing is the area is based on linear development with clustered development a more recent trend in the last decade or so.

It is only right that rural areas should still be able to offer individual / standalone dwellings set away from clustered overlooked properties to allow extra privacy and independence from near neighbours.
Clearly there is a demand for housing in the area as has been demonstrated by granting permission for some recent builds at nearby Efailwen (road towards Llangolman) which is outside the LDP boundary.

Land Location / Suitability
It seems there has been little focus on the suitability of the land for inclusion in the revised LDP due to the policy applied above.
The site is a disused settlement and has been for decades. Through lack of maintenance it is covered with dense undergrowth, overgrown shrubs, and small trees that grow out of neglected hedges. It also includes some late 20th Century conifer plantations.
This site is in complete contrast to the two sites at Glandy Cross already adopted for inclusion in the revised LDP. There seems to be an inequality when dismissing disused land in comparison to selecting agriculture green fields. Indeed, the site at the rear of Maesglas reference (Ref SuV55/h1) has been carried over from the previous LDP and still no indication of pending development.
The candidate site is nearby Goodwins Row cottages which (for historic information) was the first linear development in the area dating back to 1836. A plan view of the site can easily lead one to conclude the site to be a natural extension to existing development. Also, the site is only 400 meters away from Glandy Cross junction, the hub of the settlement area.

Any development in this field should not present road safety issues due to speed controls in the areas. The speed limit on this section of the A478 is limited to 40mph. The pending Welsh Government speed limit changes in September 2023 may reduce this further.
The splay of gateway entrances allows clear visibility for up to 400 meters in either road direction which is well within the 90 meters legal limit.
The site currently provides no value within the settlement area and its inclusion in LDP would be seen as a positive step to make it viable.

Include site within the Plan.

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

2.0 SITE CONTEXT
2.1 THE SITE AND CURRENT CONTEXT
2.1.1 The Alternative Site relates to two parcels of land measuring approximately 1.4 acres
in area in total, edged red on the plan and the photograph below.
Plan A
Photograph 1
Alternative Allocation Report April 2023
Land off Llannon Road, Upper Tumble
2.1.2 As can be seen from Photograph 1, the Site currently consists of two parcels of poor
quality agricultural land, with all their boundaries well defined by a mix of mature
hedgerows and stock proof fencing (east and west), together with domestic and
commercial fencing (north and south).
2.1.3 Access to the Site is currently gained via an adjoining agricultural enclosure to its
west. However, any development of the Site would gain access directly off Llannon
Road, which has excellent levels of visibility as illustrated below.
Photograph 2 Photograph 3
2.1.4 Under the provisions of the current Carmarthenshire LDP, the Site presently lies
outside of the defined Development Limits of the settlement of Upper Tumble.
However, as the extract of the Proposals Map below illustrates, the Site (outlined in
red) not only adjoins the current built form of the urban area, but is in fact almost
entirely encapsulated by it.
Alternative Allocation Report April 2023
Land off Llannon Road, Upper Tumble
Plan B
2.1.5 As can be seen, the Alternative Site is therefore well related to the existing defined
Development Limits for Upper Tumble and the settlement’s built form as a whole
when existing development is taken into consideration. Its position and proposed use
therefore represents a natural and logical location for the settlement’s expansion.
2.2 THE ADJOINING SETTLEMENT
2.2.1 As detailed above, the Alternative Site adjoins the existing built form of the settlement
of Upper Tumble. Upper Tumble is a nucleated settlement in form, with its core
positioned just to the north of the Alternative Site. From this then it has evolved and
grown along the three roads of Llety Road, Llannon Road (A476) and the B4310, in a
both linear and in-depth fashion.
2.2.2 In terms of community facilities and local services, the settlement of Upper Tumble
and adjoining Tumble contains a wide range, including dental and doctor surgeries,
primary school, a range of retail units, public houses, takeaway establishments,
community halls and places of worship. The settlement is also well served by a
number of bus services – Nos. 128 and 166 (two bus stops for which are within 200m
of the Site) - providing regular access to the larger settlements of Cross Hands,
Llanelli and Carmarthen. The strong sustainable position of the Alternative Site
should therefore be given full consideration when considering potential future growth
options.
Alternative Allocation Report April 2023
Land off Llannon Road, Upper Tumble
2.2.3 In terms of planned growth for Upper Tumble, the 2nd Deposit LDP classifies the
settlement as forming part of the greater Cross Hands urban area and so categorises
it as a Principal Centre under its proposed Settlement Framework. Within these
areas, the majority of the County’s growth (particularly with regards to housing) is
expected to be accommodated within the Plan period. However, having undertaken a
comprehensive review of the proposed allocations put forward by the 2nd Deposit LDP
for the Principal Centre in question, it has been identified that a number have
significant questions over their ability to be delivered within the Plan period, including
the following:
Ref. No. Site Name Units
PrC3/h4 Tirychen Farm 150
PrC3/h36 Betws Colliery 60
PrC3/h14 Nantydderwen, Tumble 33
PrC3/h22 Adj. to Pant y Blodau, Penygroes 79
PrC3/h2 Heol Gelynen, Brynamman 8
Table 1
2.2.4 As a result of the above, separate objections have been made in relation to the above
allocations and it is therefore important that alternative more deliverable sites should
be identified, to ensure the Plan can be regarded as being ‘sound’.
Alternative Allocation Report April 2023
Land off Llannon Road, Upper Tumble

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 D
Alternative Allocation Report April 2023
Land off Llannon Road, Upper Tumble
3.1.2 As illustrated above, the site is potentially capable of accommodating a mix of unit
sizes and types, with the associated density – 20 units – having therefore taken into
consideration this potential mix. The form of development for the Alternative Site is
also capable of following the current development pattern established by similar
developments along Llannon Road, such as Troed y Bryn, Llys Ifan and Banc y Gors,
therefore maximising the use of 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 Llannon Road. As can be seen in the
Photographs at Section 2, the required level of visibility is achievable in both
directions.
3.1.4 The Alternative Site proposal can retain and enhance existing boundary treatments,
as well as accommodating further biodiversity enhancements within a detailed
scheme for the Site.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Any development of the Alternative Site for residential units would be served by
mains water, public sewer and electricity, connections to which we understand lie
within or in close proximity to the Site.
3.2.2 With regards then to surface water, it is considered that as a result of on-site
features, there would be a number of options available to any development of the site
in terms of its disposal, ensuring its development adheres to current regulatory
requirements.
Alternative Allocation Report April 2023
Land off Llannon Road, Upper Tumble

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 E below provides an extract of those records applied to
the Upper Tumble locality, with the red star denoting the position of the Alternative
Site.
Plan E
4.1.3 As can be seen from the above, the Alternative Site does not form part of and neither
is it near any national or local designations. Although a number are within 2-4km of
the site, due to the intervening distance and topography, the development of the
Alternative Site will not have any detrimental impact on these features.
Alternative Allocation Report April 2023
Land off Llannon Road, Upper Tumble
4.2 HISTORICAL ASSETS
4.2.1 Below is an extract from the ‘Archwilio’ website that represents a resource for the
Historic Environment Records of Wales, with the Alternative Site indicated by a red
star.
Plan F
4.2.2 As can be seen, neither the Alternative Site nor immediately adjoining element of the
settlement includes any Scheduled Ancient Monuments, Listed Buildings or
Conservation Area’s. As a result, the development of the Site would not have any
detrimental impact on the setting or interest of any nearby historical asset.
4.3 ENVIRONMENTAL CONSTRAINTS
4.3.1 The Candidate Site is not categorised as being at risk of flooding in terms of the
Development Advice Maps or those produced by Natural Resources Wales, as
illustrated by the plans below (Alternative Site indicated by the red star).
Alternative Allocation Report April 2023
Land off Llannon Road, Upper Tumble
Plan G
(Development Advice Maps)
Plan H
(Flood Maps for Planning)
4.3.2 Due to its greenfield nature, the Candidate Site has no ground contamination related
constraints.
Alternative Allocation Report April 2023
Land off Llannon Road, Upper Tumble

5.0 VIABILITY
5.0.1 As part of the preparation of any development plan, it is vital to ensure that
allocations within it are both viable and deliverable. To not make efforts to explore
both these aspects is to then risk that the Plan may be unsound and so in turn fail to
meet its own targets or objectives.
5.0.2 Although detailed viability appraisals are difficult to prepare at this stage of the Plan’s
preparation due to the absence of, for example, such things as full engineering
details, it is possible to undertake such appraisals at a strategic or in-principle level.
The following therefore represents such a process and is fit-for-purpose in providing
confidence with regards to both the viability and deliverability of the Alternative Site at
this stage, but it should be noted, that more detailed analysis at a planning
application stage may result in some variance.
5.1 VIABILITY APPRAISAL
5.1.1 The following provides an indication of the viability of delivering the proposed 6 units
on the Alternative Site in question. It is based very much on its greenfield status and
uses figures and costings previously accepted by the local authority through its
determination of planning applications and other works. The following appraisal is
therefore based on the assumptions set out below in order to provide a residual value
for the scheme, prior to ascertaining an indicative land value.
Costs
 Dwelling construction costs are based on £1,150 per metre
 Adoptable road construction cost based on £1200 per metre
 Connections for all utilities include water, foul water and electric
 Developer’s Profit based on RICS guidelines (18%)
 Professional Fees include planning application fee, associated professional
fees, estate agency fees (1%) and LABC Warranty fee.
Alternative Allocation Report April 2023
Land off Llannon Road, Upper Tumble
Sales
 Sale Prices based on LPAs Affordable Housing SPG, market research and
ACG figures where relevant.
5.1.2 Using the above, the following represents a strategic viability appraisal for the
proposed 20 units, with 3 units being made available on an affordable basis (based
on 3 three bed units).
Costs Cost Per Unit/Metre No. Units/Metres Total
3 Bed Det. (110 sqm) 126500 2 253000
3 Bed Semi (90 sqm) 103500 12 1242000
2 Bed Link (70 sq m) 80500 6 483000
Utility Connections 5000 20 100000
Road and Access 1200 150 180000
Professional Fees - 92632
Sprinklers 3500 20 70000
Parks and Education
Cont. 5000 20 100000
Total 2520632
Sales
3 Bed Semi (130 sqm)
(Aff) 77762 3 233286
3 Bed Det. (160 sqm) 260000 2 520000
3 Bed Semi (130 sqm) 210000 9 1890000
2 Bed Link (90 sq m) 150000 6 900000
Total 3543286
Developers Profit Total 637791.48
Residual Land Value 384862.52
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 Llannon Road, Upper Tumble
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.
Alternative Allocation Report April 2023
Land off Llannon Road, Upper Tumble

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 Llannon Road, Upper Tumble

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. As has been demonstrated by this report, the Site in fact represents a
logical infill site within the existing urban form of Upper Tumble.
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. This
will then ensure it makes a positive contribution to both national and local sustainable
development objectives.
7.3 From a wider sense, the Site will also benefit from well served excellent public
transport links to the adjoining larger conurbation of Cross Hands and indeed Llanelli
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.
7.4 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 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.
7.5 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 off Llannon Road, Upper Tumble
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.

No change to the Plan.

Objection to potential LDP – Land off Cwmamman Road, Glanamman
Grid reference 266436:213116
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.

No change to the Plan.

Land off Cwmamman Road, Glanamman, Ammanford, Carmarthenshire, SA182AF

Grid Reference 266436 213116

I wish to support the omission of this site from the 2nd Deposit Revised Carmarthenshire Local Development Plan 2018-2033 – Proposals Plan and the deletion of the current PolicyT3/8/h1.

This land is currently allocated in the Carmarthenshire Local Development Plan 2006-2021 for residential development (Policy T3/8/h1).

This allocation followed an appeal decision in May 2011 despite the refusal by Carmarthenshire County Council in October 2010 to grant planning permission for residential development.

Since the grant of planning consent, some 12 years ago, the developer has failed to develop the site for housing probably because the appeal decision made it clear that before development could commence a full intrusive mining legacy site survey should be carried out and details of any required remediation works and building measures submitted and approved in writing by the local planning authority, including an implementation timetable.

In all, the developer was required to comply with 13 conditions the most important of which was that the development should commence before May 2016. To our knowledge the developer has not sought approval to meet any of the conditions and instead has simply land banked the site which is against government policy.

Amend the Plan to include the site

1.0 I NTRODUCTION
1.1 Mr J. Davies (the Land Owner) have instructed Evans Banks Planning Limited to prepare and submit an Alternative Site Supporting Statement for the inclusion within defined settlement limits of land part of Penywaun Farm, Cwmgarw Road, Upper Brynamman, Carmarthenshire for the purposes of residential development in the forthcoming Replacement Carmarthenshire Local Development Plan.
1.2 This Statement has been prepared in line with the Authority’s published documents entitled Revised Carmarthenshire Local Development Plan: Guidance Note and Revised Carmarthenshire Local Development Plan: Candidate Site Assessment Methodology. The contents of this Statement therefore address the set criteria, determining the issues and each qualifying point raised within these documents.
Consideration has also been given to ensuring that this formal submission complies with the guidance and requirements of Planning Policy Wales (Edition 11), in relation to the preparation of development plans and the allocation of land for residential purposes as part of that preparation process.
1.3 The contents of this Statement therefore provide a comprehensive case for the inclusion of the land for residential development purposes within the defined settlement limits of Brynamman, and it should also be read in conjunction with the accompanying supporting information and indicative site layout plan.
1.4 This site did form part of a much larger Candidate Site formally presented to the Council in August 2018, and referenced SR/015/007. Consideration has subsequently been given by our client as to the extent of site sought under the LDP process, following the conclusions of the Council in their Site Assessment Table (January 2023). The Council consider that “A small part of the site comprises frontage land between two existing properties and will remain within development limits. Development of the remainder of the site would lead to an unacceptable extension to the settlement. Sufficient residential opportunities exist within the
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies
settlement.” This Statement seeks to examine that conclusion, and analyses the Alternative Site put forward and claim by the Council that “sufficient residential opportunities exist within the settlement.”
2.0 SITE CONTEXT
2.1 THE SITE
2.1.1 The Alternative Site relates to a parcel of undeveloped agricultural pasture which is set off the southern flank of Cwmgarw Road, being the A4068 Road within the eastern edge of the village of Upper Brynamman. The field parcel is irregular in shape and extends to a gross area of 1.3 acres (0.53 hectares). The northern part of the field is separated from the adjacent highway by a copse of semi-mature and younger trees, but there remains an access track and agricultural gateway to the enclosure, which is grazed with sheep. It has a continuous boundary around its perimeter consisting of hedgerows and mature trees, with the western perimeter flanking the Penywaun Farmhouse, and its associated domestic curtilage.
2.1.2 Grazing fields extend to the south and south-west, with individual properties at No.’s 181 and 185 Cwmgarw Road being set off long, unmade access tracks off Cwmgarw Road, marking the eastern side of the Alternative Site. Penywaun Farm is actually also functioning as a transport haulage yard, set immediately off the rear of that dwelling. The yard is triangular in shape and level, accommodating a range of workshop outbuildings, swaths of hard surfacing and open storage. To the west of that yard lies the former Remploy Industrial Workshops and yard, which now accommodates a range of employment uses.
2.1.3 The southern flank of the A4068 Road comprises of more established, older residential properties set fronting that highway, and set back to allow front curtilages to the highway edge. This is in complete contrast to the northern flank where the setting is completely open to moorland and common grazing rights, ascending for
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies
several dozen square miles north over the Black Mountain, and falling within the Brecon Beacons National Park.
2.1.4 The parcel of land is identified in red by Plan A, which illustrates its wider position within the settlement of Brynamman and shows the existing consolidated form of modest industrial estate and frontage development to the A4068 Road. Plan B provides a detailed Ordnance Survey map extract with the site perimeters identified.
Plan A – wider setting of Brynamman with site highlighted
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies
Plan B – detailed OS Plan of Alternative Site
2.1.5 Photographs of the Alternative Site are reproduced below, showing its current March 2023 condition and form. The Alternative Site is relatively level, and is well grazed to the extent that no overgrowth vegetation is visible. All mature perimeter trees appear in good health which warrant retention. A wide overgrown verge lies off the back edge of highway.
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies
Photo 1 – view of level field from gateway entrance
Photo 2 – view of western perimeter and Penywaun Farmhouse
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies
Photo 3 – view to left (west) from existing access onto A4068 road illustrating excellent visibility and wide apron to highway
Photo 4 – view to right (east) from existing access onto A4068 road illustrating excellent visibility
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies
2.2 SETTLEMENT SUSTAINABILITY AND SITE SETTING WITHIN THE CURRENT ADOPTED LOCAL DEVELOPMENT PLAN & SECOND DEPOSIT DRAFT (FEBRUARY 2023)
2.2.1 Under the provisions of the current adopted Carmarthenshire Local Development Plan, the proposed land adjoins the Settlement Limit of Brynamman. The site is shown edged in red at Plan C below:
Plan C – Second Deposit Draft of Brynamman
2.2.2 As can be seen, the Alternative Site adjoins and is well related to the draft defined Development Limits of Brynamman. At present the development limits are drawn tightly about the existing settlement form at Cwmgarw Road. The Alternative Site seeks to mirror the development depth of the existing employment site on the same, southern side of the A4068, but a buffer zone can be provided between existing employment and proposed residential developments in land in the client’s ownership.
2.2.3 Upper Brynamman has good accessibility to the nearby settlements of Lower Brynamman and Gwaun Cae Gurwen, and towns of Pontardawe to the south and Ammanford to the west, and its links via the A4068 Cwmgarw Road to Ystalyfera and Ystradgynlais.
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies
2.2.4 In terms of the Penywaun Site, it is located within easy driving ad walking distance of all community facilities and local services present provided within the Upper and Lower Brynamman settlements. Access to further facilities in the town of Pontardawe to the south and Ammanford to the west can be gained by regular bus services where stops are located near the site frontage upon the A4068 road.
2.2.5 Transition from Adopted Local Development Plan (2006-21) – Allocation Status
In terms of planned growth, the proposed Alternative Site is located within the identified T3/9 Brynamman Local Service Centre within the current LDP, adopted in December 2014. Brynamman is regarded by the Council as sustainable settlement Within these areas, a Local Service Centre is regarded as accommodating a range of services providing a modest degree of sustainability to the local community.
2.2.6 A number of the housing allocations were presented within the LDP but have yet to be delivered after 8 years since the Plan’s adoption. Plan D below provides an extract from the 2014 Proposals Map for Brynamman.
In considering, the formulation of a new Plan, the Council have appeared to drastically reduced the number of residential allocations in the Local Service Centre, from a total of five in the adopted plan as shown below to only ONE in the new Replacement LDP. Plan E illustrates the remarkable contrast.
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies
Plan D – adopted 2014 LDP Extract for Brynamman illustrating five residential allocations
Plan E – Second Draft Plan for Brynamman with only one residential allocation
2.2.7 The net result is that despite the Local Service Centre continuing to have good provision of community facilities, local services and public transport connections to Ystradgynlais and Ammanford, its ability to grow and capitalised on these sustainable attributes has been prevented through a lack of delivery of existing allocations. More deliverable residential opportunities are required. The deliverability of the remainder
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies
of the longstanding allocations are clearly in doubt, so, in order to re-address this deficit in provision and capitalise on the sustainability of the Sustainable Community, more deliverable residential allocations are required.
2.2.8 Second Deposit Draft LDP (February 2023)
The Council published a Deposit Draft in February 2023, which is now subject of public consultation. Within the Second Deposit Draft, only one site is allocated for housing provision within Brynamman, and this was also included within the settlement limits in the 2014 adopted Plan.
Table 1 – 2023 Second Deposit Draft Allocation
2.2.9 It is noted that Heol Gelynen is only allocated for 8 units, which is a remarkable reduction in housing supply availability from the 2014 plan where the five allocated sites added up to a village total of 107 units. New Second Draft settlement limits have been re-drawn to exclude large allocations, whilst any smaller sites have remained in settlement limits but been de-allocated. The Council’s claim in their Assessment Table of January 2023 that “sufficient residential opportunities exist within the settlement” is completely incorrect in that all 107 units allocated in the 2014 adopted Plan have been omitted and only one small site as referred to above has been added. In short, there are no worthwhile residential opportunities in Brynamman identified in the new Second Draft of the LDP.
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies
2.3 Settlement Facilities
2.3.1 The Alternative Site lies upon the A4068 Ystradgynlais to Ammanford main highway. Public bus stops are located only two minutes’ walk from the Alternative Site at Cwmgarw Road. Main public bus services call at these stops, particularly the 64 service (Ystradgynlais to Ammanford) which calls at Cwmgarw Road.
2.3.2 It lies less than a one-minute walk from the former Remploy Industrial Estate. A selection of small convenience shops, public houses and community facilities are located near the Black Mountain Centre, set upon the junction of Cwmgarw Road with Mountain Road, some 10-15 minutes’ walk west from the site.
Brynamman Primary School is a two-minute drive away at New Road.
2.3.3 Pontardawe and Ystradgynlais town centres are located a short 15 minutes’ drive away with its associated comparison shops, high street banks, public houses/cafes, offices, industrial estate, library, and leisure/recreation facilities. Ammanford town centre is slightly further by road or bus at about 20 minutes’ drive time, but from where the Heart of Wales Rail Line can be accessed.
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies

3.0
3.0 THE PROPOSAL
3.0.1 This Statement is accompanied by an indicative layout for a potential residential scheme that could be development on the site. It should be emphasised that the accompanying layout is for illustrative purposes only, and that other design solutions for the site could be reached. Notwithstanding this, the accompanying layout drawing has taken into account all potential assets and constraints of the site and demonstrates that it can deliver 11 units in a deliverable and sustainable manner.
3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Alternative Site be allocated in the forthcoming replacement LDP for the purposes of a combined total of 11 residential units. As detailed above, the accompanying illustrative layout demonstrates that the site can accommodate this number in a deliverable and sustainable manner. Plan E illustrates the indicative site layout for the Alternative Site, as edged in red, extending off the A4068 highway.
Plan E – Site Layout
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies
3.1.2 As illustrated above, the site is capable of accommodating detached and semi-detached houses to replicate and being reflective to the existing form of the development to the west along Cwmgarw Road.
3.1.3 With regards to access, it is proposed that the Alternative Site would be served by an improvements and widening of the existing access track adjoining the A4068 highway. Vehicle speeds are consistent with the 40mph speed limit, and thus visibility splays of 2.4m x 59m can easily be achieved where the accesses adjoin the A4068 road.
3.1.4 The Alternative Site proposals can fully retain all existing boundary treatments being established tree perimeter and hedgerows about the existing house at Penywaun Farm and shared boundaries with No’s 181 and 185 to the east and south-east.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Development of the Alternative Site for residential units would be served by mains water, public sewer and electricity connections.
3.2.2 A new estate road is proposed within the development. This will be equipped with roadside gullies and drainage which aid discharge run-off from the carriageway. The proposed accesses to the site could connect to the existing highways drainage.
3.2.3 The Alternative Site comprises of agricultural pasture. There are no areas of significant marshy grassland or water-logging evident, and therefore at first inspection, it appears that the site benefits from good ground percolation of rainwater.
3.2.4 Soakaways would be the most sustainable means of disposing of surface water from individual properties. If required, attenuation measures can be deployed on site to control surface water run-off during extreme storm events, which could also allow for additional capacity, making allowances for climate change. Such features can be soft engineered in the form of attenuations basins and / or swales, thus adhering to the principle of Sustainable Urban Drainage Systems (SUDS).
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies

4.0
4.0 EENVIRONMENTAL NVIRONMENTAL CCONSIDERATIONSONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 The Alternative Site has been assessed against data held on the “Data Map Wales” website which details statutory and non-statutory National and Local sites of ecological importance. Plan F below provides an extract of those records applied to the Brynamman locality. The red star denotes the position of the Alternative Site.
Plan F – Extract from Data Map Wales detailing any known ecological interests
4.1.2 The records reveal that the Alternative Site does not include or adjoin any national or local nature conservation designation. Any biodiversity assets that may be present or adjoining the Penywaun Site have been given full consideration with regards to exploring its potential for residential development. This has included the proposed retention and management of existing boundary trees. It is envisaged that the entirety
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies
of mature tree lines could be retained and managed further for uninterrupted biodiversity gain.
4.1.3 It is considered that any statutory and non-statutory designations are significantly distant from the site, which will ensure that its development would have no detrimental impact upon them.
4.2 HISTORICAL ASSETS
4.2.1 The Alternative Site has been assessed for any proximity to known and designated Historic Assets, using the “Cof Cymru – National Historic Assets of Wales” from CADW’s website. An extract from Cof Cymru Assets map for Brynamman is reproduced below as Plan G. The red star denotes the position of the Penywaun Site.
Plan G – Extract from Cof Cymru Historic Assets website
4.2.2 The extract reveals there to be no Listed Buildings nor Scheduled Ancient Monuments in the locality.
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies
ENVIRONMENTAL CONSTRAINTS
Potential for Risk from Flooding
4.3.1 The Alternative Site has been assessed against the Flood Map for Planning, prepared by Natural Resources Wales, and as referred to within the Welsh Government’s revised / draft “Technical Advice Note 15: Development and Flood Risk”. An extract from the Flood Map for Planning is reproduced below as Plan H, with the site denoted by a red star.
Plan H – Extract from NRW’s Flood Map for Planning
4.3.2 The above plan extract revels that no part of the Alternative Site lies within the designated flood zone of the River Amman, and thus the potential development of the site is not at risk from fluvial flooding.
4.3.3 An examination has also been made of NRW records relating to potential surface water flooding, as shown by purple tone in the above plan. The red star again denotes the positioning of the Alternative Site and reveals there to be no potential for pooling of surface water upon the site.
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies
Past and Present Potential for Ground Contamination and Coal Mining Activity
4.3.4 The Candidate Site comprises a modest former agricultural field. Due to its greenfield nature and agricultural use, the field as no history of known past ground contamination related constraints.
Plan I – Coal Authority Map indicating former mining legacy
4.3.5 The records of The Coal Authority have been examined and reveal the history of coal mining in this part of the County. Whilst there are underlying seams of coal under Cwmgarw Road, there are no mine entries near the site, as indicated above at Plan I by a red star.
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies

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 aspects inherently poses risks that the Plan may be unsound and so in turn fails 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
5.1 VIABILITY APPRAISAL
5.1.1 The following provides an indication of the viability of delivering the proposed 11 units on the Alternative Site in question. It is based very much on its greenfield status and uses values 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 land value for the scheme.
Costs
• Dwelling construction costs are based on an absolute minimum of £1300 per metre given that bespoke four bed detached houses (140 sq.m.) and three-bed semi-detached houses (90 sq.m.), with a medium grade of internal finishing.
• Estate road carriageway costs are placed at £1200 per linear metre
• Connections for all utilities include water, foul water and electric.
• Developer’s Profit based on minimum RICS guidelines (18%)
• Professional Fees include planning application fee, associated professional fees, estate agency fees (1%) and LABC Warranty fee.
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies
Sales Values
• Sale Prices based on LPAs “Affordable Housing” Supplementary Planning Guidance, market research and Welsh Government “Acceptable Cost Guidance” figures where relevant.
5.1.2 Using the above, the following represents a strategic viability appraisal for the proposed 11 units, based on an affordable housing level being a 10% contribution of the total number of dwellinghouses proposed.
Costs
Cost Per Unit/Metre
No. Units/Metres
Total
Four Bed Houses
182,000
7
832,000
Three Bed Semi-detached
117,000
4
468,000
Road Construction
1200
120
144,000
Utility Connections
5000
11
55,000
Professional Fees
-
-
90,000
Sprinklers
3500
11
38,000
Parks and Education
5000
11
55,000
Contribution
Total
1,682,000
Sales
Four Bed (Open M’kt)
250,000
7
1,750,000
Three Bed (Op M’kt)
190,000
3
570,000
Three Bed (Affordable)
91,000
1
91,000
Total Sales
2,411,000
Developers Profit
Total
434,000
Residual Land Value
295,000
Table 2
5.1.3 Based on the above figures, it is considered that in-principle, the development of the site would be financially viable. The residual land value of £295,000 for a site consisting of 11 dwellings over a 1.3-acre sized site is consistent with evidence gathered over recent years by the District Valuer in examining residential site transactions within Carmarthenshire. The DV discovered land values on completed
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies
and on-going sites to be averaging £245,000 per net residential acre of land, based on 2020 values.
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, with a developer secured, it is envisaged that the site could be capable of being completed within 2 years from the adoption of the Replacement Local Development Plan. Cwmgarw Road remains an attractive part of Brynamman given its panoramic views over the Black Mountain and National Park. Road, benefitting from its semi-rural location, but easy access to Ystradgynlais and Ammanford by road and the nearby schools, shops, services and community facilities.
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies

6.0 NATIONAL PLANNING POLICY CONSIDERATIONS
6.1 In the preparation of any development plan, consideration must be given to national planning policy and guidance. At present, this takes the form of Planning Policy Wales and a series of Technical Advice Notes (TAN) that deal with a variety of topic areas.
6.2 With regards to residential development, or housing, the overarching requirements and principle guidance set by national policy can be found at Paragraph 9.2.3, which reads as follows:
“Local planning authorities must ensure that sufficient land is genuinely available or will become available to provide a 5-year supply of land for housing judged against the general objectives and the scale and location of development provided for in the development plan. This means that sites must be free, or readily freed, from planning, physical and ownership constraints, and economically feasible for development, so as to create and support sustainable communities where people want to live. There must be sufficient sites suitable for the full range of housing types.”
6.3 At present, Carmarthenshire County Council’s housing supply figure is below the required 5-year level therefore, it is imperative that this is addressed as quickly as possible to avoid further deterioration of communities and the facilities and services they have to offer.
6.4 Dealing specifically with the Alternative Site subject of this Report, it is evident that its inclusion within the Replacement LDP would adhere to the requirements of PPW, in that it is free from any planning, physical, or ownership constraint. In addition, as shown in Section 5 of this statement, the site is also economically viable in deliverability terms.
Alternative Site Supporting Statement March 2023
Land Part of Penywaun Farm, Cwmgarw Rd., Upper Brynamman Mr J. Davies

7.0 CONCLUSION
7.1 The Alternative Site is modest in overall size, with established dwellinghouses located off either side flanks at Cwmgarw Road. The enclosure tends to be well screened from public view by virtue of high perimeter trees which shelter the site, and add a sense of semi-rural character to the scheme.
7.2 The Site lies within close proximity and walking distance to the existing community and local services of Brynamman 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 nearby settlements, specifically the town of Ystradgynlais and Ammanford, together with other locations within and adjoining the County. In tandem to this, the development of the Site will in turn ensure a deliverable source of future housing for the Sustainable Community in which it lies, which has seen both allocated sites fully developed leading to an under supply 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 recognises the suitability and deliverability of modest sites if it is to continue to realise the contribution villages such as Brynamman make to the housing land supply.
7.4 With the Alternative Site having no access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership constraints, its delivery if included within settlement limits is assured. Combined therefore with its locational characteristics, the Site in question represents a sustainable alternative for future housing development.
7.5 In view of the above and the information provided within this Statement, it is respectfully requested that the Alternative Site in question be included within limits for a modest residential development.

We are pleased to have had the opportunity to comment on the ‘Carmarthenshire County Council Second
Deposit Revised Local Development Plan.’ We support the general vision, and approach of the LDP but suggest that some flexibility and room for judgement must be retained to allow for the continued vitality of some of the more rural parts of the county.
“Llwyndu” Land at Milo should be allocated for development to provide some confidence that local housing needs will be met. However, failing that the site is capable of providing a reasonable ‘windfall’ development
as infill.
As has been demonstrated above, the site (SR/114/001) constitutes a suitable and sustainable form of development within the settlement of Milo.

Overall, it is considered that the site (SR/114/001) constitutes the only suitable and sustainable Candidate
Site within Milo for residential development. The site is capable of mirroring the linear form of development
that exists along the main road through Milo, and would therefore be a logical means of increasing housing
within this sustainable community (as promoted through proposed Policy SP3 Local Development Plan).

This representation is made in response to the ‘Carmarthenshire County Council Second Deposit Revised
Local Development Plan’ (“the LDP”) consultation and is submitted on behalf of Mr James George.
Mr George owns “Llwyndu” Land at Milo, Llandybie (‘the site’) which has been considered in the Candidate
Sites Register Assessment for potential inclusion within the LDP. The site can be seen, outlined in red, on
the plan found at Appendix 1.
It is respectfully suggested that the site should be allocated in the LDP, to provide confidence that houses
can be delivered to meet local needs in Milo. Alternatively, the site is capable of meeting the criteria set out
in the proposed policy framework of the LDP to allow its development for new homes, so long as some
flexibility and judgment can be applied.
THE SCALE OF PROPOSED GROWTH
We support the ambition and principle of the LDP, and specifically the targets set out in Policy SP1:
Strategic Policy - SP1: Strategic Growth
The LDP will provide for the future growth of a sustainable economy and housing
requirement through the provision of:
a. 9,704 new homes to meet the identified housing requirement of 8,822.
b. A minimum of 71.21ha of allocated employment land.
The focus on regeneration and growth reflects the Council's core strategic ambitions with
development distributed in a sustainable manner consistent with the spatial strategy and
settlement framework.
It is clear that the Council has taken seriously its responsibility to support he delivery of the homes and jobs
which are needed in Carmarthenshire. The targets appear aspirational, but realistic. What should not be
overlooked in these strategic targets however is the very real need to support the more rural parts of the
community and meeting their needs.
Sites like “Llwyndu” Land at Milo, Llandybie provide a valuable opportunity to deliver new homes in a rural
hinterland which supports an overall network of social and economic growth. This growth is set out in the
LDP, and the site could be delivered through an allocation, or as a windfall – and either way, it would
contribute to the overall housing target set by the Council.
MILO AS A LOCATION FOR GROWTH
Introduced in chapter 10 of the LDP is the concept of “Clusters” and Milo falls within the settlements grouped
in “Cluster 3: Amman and Upper Gwendraeth.”
We note with interest the way in which Cluster 3 is described in the LDP. In particular, we note the following
elements of the spatial portrait, and that the cluster:
“…is characterised by a series of interrelated settlements; [and]
…has grown as a centre with a focus for investment in jobs, homes, and services.”
And specifically, that:
“Ammanford …plays an important service centre role by providing localised retail, employment,
education, and leisure facilities.”
We also note that:
Cross Hands as a former mining community has developed over recent decades through its position
on the A48 strategic transport route.
Regarding Cross Hands, it is exciting to see a range of significant economic growth is planned to include:
• PrC3/E1 – Employment allocation of some 8.31 Ha
• PrC3/E3 - 4.76 Ha extension to business park
• SG2/3 – reserved expansion area for large scale employment uses.
This growth will also be accompanied by:
TRA1: Transport and Highways Infrastructural Improvements
Transport routes, improvements and associated infrastructural facilities which deliver the objectives
and priorities of the Joint Transport Plan for South West Wales (2015 – 2020) will be supported.
The improvements to the highway infrastructure as part of the Cross Hands Economic Link Road will
be safeguarded with the route identified on the proposals map.
Proposals which maintain and enhance an integrated sustainable transport network will also be
supported where they accord with the policies and provisions of this Plan. Development proposals
which do not prejudice the efficient implementation of any identified improvement or scheme will be
permitted.
Land at Milo, Llandybie is approximately 4 miles from Cross Hands via the A476 and the new Cross Hands
relief road, avoiding additional traffic on the congestion pinch points of the Cross Hands roundabout and
Gorslas.
These points suggest that each settlement in the cluster has a role to play in supporting the successful social
and economic activity in the area, and that the services and facilities of the larger settlements, support a
hinterland of slightly dispersed but nonetheless connected communities.
To maintain this success, and to ensure the continued vitality of the more rural communities it is vital that
development is allowed to happen at all tiers (and sizes) of settlement in the cluster.
We note that potential development in Milo is proposed to be manged primarily through two policies: SP3:
Sustainable Distribution, and HOM3: Homes in Rural Villages.
Therefore, taking each of these policies in turn:
STRATEGIC POLICY – SP3: SUSTAINABLE DISTRIBUTION – SETTLEMENT FRAMEWORK
We generally support the principle of this policy. Settlement hierarchies are a well-recognised way of
managing growth and directing it to the most sustainable locations, and it is important that the role of smaller
settlements such as Milo is not over looked, and that the needs of people who live in these more rural
locations are also met.
We note that Milo is listed as a “Tier 4 – Rural Villages (No development limits).” On the face of it, given the
size of Milo this is reasonable, and the fact that the village is a well-connected part of the ‘cluster’ is also
recognised.
Furthermore, we read with interest in the supporting text to Policy SP3 that in “Rural Villages (No
Development Limits)” the following scale of development will be acceptable:
• Small sites – housing through infill or logical extensions/rounding off.
• Small Scale Rural Exceptions Schemes for Affordable Housing
We respectfully suggest that Land at Milo, Llandybie represents a small infill site as presented in the
supporting text to Policy SP3. The site should be allocated as such in the LDP to provide confidence that it
will be delivered in the plan period to help meet both the strategic needs of Carmarthenshire and specifically
the local housing needs in “Cluster 3: Amman and Upper Gwendraeth” and Milo.
HOM3: HOMES IN RURAL VILLAGES
Should the Council decide that Land at Milo, Llandybie does not need to be allocated for development, the
site has the potential to be delivered as ‘windfall,’ broadly in conformity with proposed Policy HOM3.
There are, however, some element of this proposed policy which are somewhat arbitrary, and we suggest
that some flexibility and planning judgement is allowed, to ensure the most appropriate development
opportunities are delivered, and the most efficient use is made of land.
In particular we note that proposed Policy HOM3, suggests the following:
In those settlements identified as rural villages under Policy SP3, proposals for 1 to 4 dwellings will be
permitted for the following:
• minor infill of a small gap between the existing built form; or,
• logical extensions and/or rounding off of the development pattern that fits in with the character of the
village form and landscape; or
• conversion or the sub-division of large dwellings.
Such proposals will be subject to other detailed planning considerations set out within LDP policies.
As we have explained in response to proposed Policy SP3, and is elaborated upon in our site specific
comments - Land at Milo, Llandybie is a sensible and logical infill site. However, because the most logical
infill is for 6 new homes the potential to develop the site would – in principle – be contrary to proposed Policy
HOM3, but the 1 to 4 dwellings requirement is entirely arbitrary and does not appear to be justified in the
supporting text to the policy, or in any supporting evidence.
We suggest therefore that the reference to 1 to 4 dwellings is removed from the policy text, and this would
have a limited effect on how the policy operates. There is still sufficient scope for a ‘case by case’
assessment of the acceptability of infill sites, and for some flexibility to be applied where perhaps 6 houses
might be more appropriate and in character with a site’s surrounds, but equally importantly it makes an
efficient use of land.
The final paragraph of proposed Policy HOM3 is also arbitrary and not justified in evidence that we have
been able to identify. The following part of the pollciy is not necessary, and should be removed:
Proposals which exceed the 10% cap above the number of existing homes in the settlement, as at
the LDP base date, will not be permitted except where they conform to Policy AHOM1 in relation to
the provision of affordable homes.
By way of an example, there are currently 50 homes in Milo, and Land at Milo, Llandybie can deliver 6 infill
homes, but this would be apparently contrary to proposed policy HOM3 (by a factor of a single house) for no
reason other than it breaches an arbitrary 10% cap. This risks both the viability of schemes, and the efficient
use of land.
“LLWYNDU” LAND AT MILO, LLANDYBIE
Turning to the site which we are proposing should be allocated for development. This submission
commends to the Council, Land at Milo, Llandybie (‘the site’) which has been considered in the Candidate
Sites Register Assessment for potential inclusion within the LDP.
The site address is as follows:
Llwyndu
Milo
Llandybie
Ammanford
SA18 3NQ
The site has been assessed by the Council and the site reference is SR/114/001. The assessment of the
site states
“The site may comply with the provisions of the Preferred Strategy, however each individual site will
require assessment at application stage to ensure it complies with the relevant specific policy. In
respect of this settlement, the Preferred Strategy identifies it as a Tier 4 with no development limits”
We support the general assessment of the site and suggest that it should be allocated for development to
provide confidence in its delivery.
However, should the Council disagree with this position, we remain confident that the site is acceptable, and
achievable as infill development.
Site Context
The site comprises 4.64 acres of agricultural fields within the settlement of Milo, which is identified in Policy
proposed policy SP3 as a sustainable community. A site location plan, which was submitted with our initial
submissions to the candidate sites register is included again for completeness (Appendix 1).
The site benefits from an existing access with good visibility onto the main road running through Milo, as
shown in Figure 1 below.
Figure 1 – Access to the site from the main road through Milo (Google Street View - 2011)
The site is bound by agricultural fields to the south west, residential properties to the south east and a chapel
to the North West. The site is bounded by the road to the north east, whilst two and three storey residential
properties lie on the opposite side of the road.
There are two listed buildings to the north of the site: Capel Milo (ID: 22200) and Hen Gapel Milo (ID:
22199).
The village of Milo contains around 50 homes. Milo is approximately 4.5 miles north of Ammanford, which is
recognised as a growth area in proposed Policy SP3 and the heart of a cluster or network of connected
communities. Milo is approximately 5 miles south west of Llandeilo which is also identified as a service
centre. There is a bus service from Milo to Llandeilo.
Proposed Development
It is considered that the site could be developed along the road following the existing linear patter of built
form in Milo. In this case, it is considered that the site could comfortably accommodate approximately six
dwellings and utilise the existing access, as shown in Figure 1 above. Such development would mirror the
existing settlement and would constitute ‘infill’ development, as supported in proposed Policies SP3 and
HOM3.
As highlighted within our initial submission, an alternative option is to develop the whole of the site, again
utilising the existing access, which could accommodate approximately 15 dwellings, thus triggering the need
for affordable housing which would provide additional benefits to the locality.
Two broad indicative layouts were provided within our initial submission and have been included again for
completeness (see Appendix 2).
The site also lies within a sustainable location within Milo itself, located approximately 140m to the local bus
stops from the existing access into the site shown in Figure 1 above.

CONCLUSION
We are pleased to have had the opportunity to comment on the ‘Carmarthenshire County Council Second
Deposit Revised Local Development Plan.’ We support the general vision, and approach of the LDP but
suggest that some flexibility and room for judgement must be retained to allow for the continued vitality of
some of the more rural parts of the county.
“Llwyndu” Land at Milo should be allocated for development to provide some confidence that local housing
needs will be met. However, failing that the site is capable of providing a reasonable ‘windfall’ development
as infill.
As has been demonstrated above, the site (SR/114/001) constitutes a suitable and sustainable form of
development within the settlement of Milo.
Overall, it is considered that the site (SR/114/001) constitutes the only suitable and sustainable Candidate
Site within Milo for residential development. The site is capable of mirroring the linear form of development
that exists along the main road through Milo, and would therefore be a logical means of increasing housing
within this sustainable community (as promoted through proposed Policy SP3 Local Development Plan).
I trust the information provided in this submission is sufficient. Should you require any further information,
please do not hesitate to contact me.

Include site in the Plan

1.0 I NTRODUCTION
1.1 Mr W. B. James (the Land Owner) have instructed Evans Banks Planning Limited to prepare and submit an Alternative Site Supporting Statement for the inclusion within defined settlement limits of land adjoining Llandybie Primary School, Llandybie, Ammanford for the purposes of residential development in the forthcoming Replacement Carmarthenshire Local Development Plan.
1.2 This Statement has been prepared in line with the Authority’s published documents entitled Revised Carmarthenshire Local Development Plan: Guidance Note and Revised Carmarthenshire Local Development Plan: Candidate Site Assessment Methodology. The contents of this Statement therefore address the set criteria, determining the issues and each qualifying point raised within these documents.
Consideration has also been given to ensuring that this formal submission complies with the guidance and requirements of Planning Policy Wales (Edition 11), in relation to the preparation of development plans and the allocation of land for residential purposes as part of that preparation process.
1.3 The contents of this Statement therefore provide a comprehensive case for the inclusion of the land for residential development purposes within the defined settlement limits of Llandybie, and it should also be read in conjunction with the accompanying supporting information and indicative site layout plan.

2.0 SITE CONTEXT
2.1 THE SITE
2.1.1 The Alternative Site relates to a parcel of undeveloped agricultural pasture which is set off the western flank of the access road which leads to Llandybie Primary School. That access road has a junction onto the A483 Llandeilo Road, set a position at the village centre. The field parcel is irregular in shape and extends to a gross area of 4.8 acres (1.95 hectares).
2.1.2 The northern / north-eastern perimeter of the field shares a common boundary with residential properties which front the western flank of Llandeilo Road, whilst the road frontage with the School Road extends for some 70 metres and is marked by a post and rail fence with metal agricultural gated access at a mid-point. To the south of the field lies the grounds of the Primary School, with its range of brick-built classrooms, together with ancillary outbuildings in a horse-shoe arrangement orientated east, with a tarmac surfaced yard in the foreground. The School Road terminates at the school gates, and allows parents and visitors to turn vehicles about in a turning area. A line of leylandii trees separate the school buildings from the Alternative Site.
2.1.3 Grazing fields extend to the west and south-west and take a similar form to the Alternative Site being semi-improved pasture, which are well-defined with well managed mature hedgerow perimeters and of varying acreages. Individual and mature deciduous trees are sporadically found within the western hedgerow boundary, however a more concentrated copse is found off a short, northern perimeter, which separates the field from a minor road which runs north-west for several hundred metres to junction onto Pentregwenlais Road
2.1.4 The opposite flank of the School Road contains an undeveloped strip of land which is tree-lined and separate the access road from more modern residential properties which back onto the land from Parc-y-Llan. A sloping further open enclosure lies further south, separating the school grounds from that modern cul-de-sac.
2.1.5 The parcel of land is identified in red by Plan A, which illustrates its wider position within the settlement of Llandybie and shows the existing consolidated form of frontage development to the A483 Road. Plan B provides a detailed Ordnance Survey map extract with the site perimeters identified.
Plan A – wider setting of Llandybie with site highlighted
Plan B – detailed OS Plan of Alternative Site
2.1.6 Photographs of the Alternative Site are reproduced below, showing its current March 2023 condition and form. The Alternative Site is undulating in form and profile and is well grazed to the extent that no overgrowth vegetation is visible. All mature perimeter trees appear in good health which warrant retention. A wide verge lies off the back edge of highway, and a continuous footway / pavement runs along the entire road length from Llandeilo Road to the school entrance. Plan C is an extract from Google Earth where such physical features are clearly evident.
Plan C – Google Earth view of site (April 2021)
Photo 1 – view of lower-level field from school road
Photo 2 – view of western hedgerow perimeter and general level plateau of field
Photo 3 – view south to the school grounds
Photo 4 – view to right / south-east at junction with A483 road with wide visibility and separation distance to junction opposite into village centre
Photo 4 – view to left / north-west at junction with A483 road with wide visibility extending for well over 150 metres along Trunk Road from a 2.4 metres setback
2.2 SETTLEMENT SUSTAINABILITY AND SITE SETTING WITHIN THE CURRENT ADOPTED LOCAL DEVELOPMENT PLAN & SECOND DEPOSIT DRAFT (FEBRUARY 2023)
2.2.1 Under the provisions of the current adopted Carmarthenshire Local Development Plan (2014), the field enclosure adjoins the Settlement Limit of Llandybie. The site is shown edged in red at Plan C below, with the extract for the 2023 published Second Deposit Draft of the LDP shown at Plan D, with the site edged in red. It is immediately apparent that the settlement limits have not changed in the transition to a new draft Plan, with the limits wrapping about the primary school buildings and forming about the access road to encircle the rear garden perimeters of Llandeilo Road properties. However, it is noted that over half the Alternative Site’s perimeter is shared with built development, with the open, western perimeter very well defined by established field boundary features.
Plan D – 2014 Adopted LDP Proposals Map for Llandybie
Plan E – Second Deposit Draft (2023) of northern Llandybie
The Alternative Site adjoins and is well related to the draft defined Development Limits of Llandybie. The Alternative Site seeks to develop off the school access road, with proposals sharing a common boundary with Llandeilo Road properties.
2.2.2 Llandybie has good accessibility to the nearby towns of Llandeilo to the north and Ammanford to the south, and its links via the A483 Trunk Road to the M4 at Pont Abraham, and north to converge with the A40 north of Llandeilo.
2.2.3 In terms of the Alternative Site, it is located within easy walking distance of all community facilities and local services present provided within the Llandybie settlement. Access to further facilities in the town of Ammanford to the south can be gained by regular bus services where stops are located near the site frontage upon the A483 road.
2.2.4 Transition from Adopted Local Development Plan (2006-21) – Allocation Status
In terms of planned growth, the proposed Alternative Site at Llandybie is located within the identified Ammanford / Cross Hands Growth Area within the current LDP, adopted in December 2014. Llandybie is regarded by the Council as sustainable settlement given its accommodating of a range of services providing a modest degree of sustainability to the local community.
2.2.5 A number of the housing allocations were presented within the LDP but have yet to be delivered after 8 years since the Plan’s adoption. Plan F below provides an extract from the 2014 Proposals Map for Llandybie. In the formulation of a new Plan, the Council have appeared to repeat the from a total of four sites from the adopted plan into the new Replacement LDP. Plan G illustrates the Second Draft Plan.
Plan F – 2014 LDP Extract for Llandybie illustrating four residential allocations
Plan G – Second Draft Plan for Llandybie with similar residential allocations
2.2.6 The net result is that despite Llandybie continuing to have good provision of community facilities, local services and public transport connections to Llandeilo and Ammanford, its ability to grow and capitalised on these sustainable attributes has been prevented through a lack of delivery of existing allocations. More deliverable residential opportunities are required. The deliverability of the remainder of the longstanding allocations are clearly in doubt, so, in order to re-address this deficit in provision and capitalise on the sustainability of the Sustainable Community, more deliverable residential allocations are required.
2.2.7 Second Deposit Draft LDP (February 2023)
The Council published a Deposit Draft in February 2023, which is now subject of public consultation. Within the Second Deposit Draft, four sites are allocated for housing provision within Llandybie, as was also included within the settlement limits in the 2014 adopted Plan.
Table 1 – 2023 Second Deposit Draft Allocation
2.2.9 It is noted that Llys-y-Nant is virtually completed, as is Land north of Maespiode with its 8 units. Clos Felingoed is being developed by a local housing association, after full planning permission has been granted in 2022.
The large site at Maespiode for 45 units (PrC3/h20) remains undeveloped despite being the subject of a full planning permission, submitted in March 2022 (PL/03750). It is noted that the application has yet to be determined.
2.2.10 The Council’s Housing Growth Strategy targets Ammanford as the focal town in the Ammanford / Cross Hands Principal Growth Cluster. Llandybie forms part of the principal service centre centring upon the Ammanford Cluster as defined within the Second draft LDP. The new Draft Proposals Map reveals that the Council have allocated a total of 8 sites at Ammanford as shown below.
Table 2 – Ammanford draft allocations under Policy HOM1
2.2.11 The above eight alocated sites proposed for Ammanford reveal a combined total of 292 units, howeve upon analysis it is clear Wind Street, Llys Dolgader, Gwynfryn and Yr Hen Felin have already been constructed, totalling 49 dwellings.
2.2.12 Of the other four Ammanford allocations, it is immediately noteworthy that they are predominately “roll-overs” from earlier Development Plans with those sites showing
no commitment whatsoever to commit to the implementation of a planning application. We would comment on the two largest of those sites as follows:
Site PrC3/h4 - Tirychen Farm, Dyffryn Road, Penybanc - for 150 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.
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. Clearly, there is no historic demand for a site of this scale in this part of the Ammanford area. More physically challenging sites, such as the re-development of the Betws Colliery site at Betws and Cae Pound at Cross Hands West Tip have come forward long before Tirychen, and yet still the Council is prepared to allocate the site once again in a new Development Plan.
The decision to retain Tirychen Farm after a period of 30 years within the LDP is shown to be inconsistent, as does not sit with LDP Procedural Guidance which encourages Local Planning Authorities to only re-allocate sites based upon firm evidence of deliverability.
Plan H – wider view of Ammanford draft Proposals Map
2.2.13 Site Prc3/H36 - Betws Colliery – for 66 units
Outline planning permission was first granted for residential development on the allocation as far back as 2005 (Application E/09584), with reserved matters being granted in 2011 (Application E/24724). A Non-Material Amendment (Application PL/04568) has been granted in September 2022 for the ‘Removal of chimneys and raising the height of window sills’.
The site was allocated in the Carmarthenshire Local Development Plan (2014) as part of a larger allocation (GA3/h9), and Allocation PDB27 of the Carmarthenshire Unitary Development Plan (2006), which included the land south of Ffordd y Glowyr, which has been developed.
However, the northern element continues to be allocated for 66 units in the Second Draft LDP. This is despite having almost 20 years of support for the principle of residential development at the historic allocation from the Council, with not a single housing unit has been delivered to date.
2.2.14 The above analysis serves to demonstrate that the Council’s strategy for housing growth in the Ammanford Cluster is questionable and open to considerable criticism in rolling over allocations from the last LDP period without any realistic prospect of those allocations being brought forward for development and delivery.
2.3 Settlement Facilities
2.3.1 The Alternative Site lies just off the A483 Llandeilo to Ammanford main highway. Public bus stops are located only two minutes’ walk from the Alternative Site at Llandeilo Road. Main public bus services call at these stops, particularly:
X13 service (Llandeilo to Swansea) which calls at Llandeilo Road en-route to Ammanford, Pontardulais, Penllergaer, Fforestfach and Swansea City Centre.
Bus service 103 operates between Llandeilo and Ammanford.
Service 165 also runs between Ammanford and Cross Hands.
2.3.2 The Alternative Site lies less than a one-minute walk from the primary school. A selection of small convenience shops, supermarket, public houses and community facilities are located at High Street, and upon its junction with Llandeilo Road.
2.3.3 Llandeilo and Ammanford town centres are located a short 10- and 5-minutes’ drive / bus journey away respectively with its associated comparison shops, high street banks, public houses/cafes, offices, industrial estates, library, and leisure/recreation facilities.
2.3.4 Llandybie lies upon the Heart of Wales Rail Line, and the station can be accessed at Heol-y-Brenin, being less than a five minutes’ walk from the Alternative site.

3.0
3.0 TTHE HE PPROPROPOSOSALAL
3.0.1 This Statement is accompanied by an indicative layout for a potential residential scheme that could be development on the site. It should be emphasised that the accompanying layout is for illustrative purposes only, and that other design solutions for the site could be reached. Notwithstanding this, the accompanying layout drawing has taken into account all potential assets and constraints of the site and demonstrates that it can deliver 54 units in a deliverable and sustainable manner.
3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Alternative Site be allocated in the forthcoming Replacement LDP for the purposes of a combined total of 54 residential units. As detailed above, the accompanying illustrative layout demonstrates that the site can accommodate this number in a deliverable and sustainable manner. Plan I illustrates the indicative site layout for the Alternative Site, as edged in red, extending off School Road, with potential for improvements to the junction with the A483 highway.
Plan I – Site Layout
3.1.2 As illustrated above, the site is capable of accommodating detached and semi-detached houses to replicate and being reflective to the existing form of new, modern development to the east at Llys-y-Nant and south at Maespiode.
3.1.3 With regards to access, it is proposed that the Alternative Site would be served by an improvements and widening of the existing access road, and onto a junction with the A483 highway. Vehicle speeds are consistent with the 20mph speed limit, and thus visibility splays of 2.4m x 45m can easily be achieved where the junction adjoins the A483 road. Photographs 4 and 5 above illustrate that visibility splays to those distances can already be achieved in both directions.
3.1.4 The Alternative Site proposals can fully retain all existing boundary treatments being established tree perimeter and hedgerows about the existing houses at Llandeilo Road and shared boundaries with the School, with open, western boundary retained in situ.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Development of the Alternative Site for residential units would be served by mains water, gas, public sewer and electricity connections.
3.2.2 A new estate road is proposed within the development. This will be equipped with roadside gullies and drainage which aid discharge run-off from the carriageway. The proposed accesses to the site could connect to the existing highways drainage.
3.2.3 The Alternative Site comprises of agricultural pasture. There are no areas of significant marshy grassland or water-logging evident, and therefore at first inspection, it appears that the site benefits from good ground percolation of rainwater.
3.2.4 Soakaways would be the most sustainable means of disposing of surface water from individual properties. If required, attenuation measures can be deployed on site to control surface water run-off during extreme storm events, which could also allow for additional capacity, making allowances for climate change. Such features can be soft engineered in the form of attenuations basins and / or swales, thus adhering to the principle of Sustainable Urban Drainage Systems (SUDS).

4.0
4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 The Alternative Site has been assessed against data held on the “Data Map Wales” website which details statutory and non-statutory National and Local sites of ecological importance. Plan J below provides an extract of those records applied to the Llandybie locality. The red star denotes the position of the Alternative Site.
Plan J – Extract from Data Map Wales detailing any known ecological interests
4.1.2 The records reveal that the Alternative Site does not include or adjoin any national or local nature conservation designation. The Cernydd Carmel SSSI lies over one kilometre north-west of the site, and thus at a very safe distance as to not be affected by any development proposals at the site.
4.1.3 Any biodiversity assets that may be present or adjoining the Alternative Site have been given full consideration with regards to exploring its potential for residential
development. This has included the proposed retention and management of existing boundary trees. It is envisaged that the entirety of mature tree and hedgerow lines could be retained and managed further for uninterrupted biodiversity gain.
4.1.4 It is considered that any statutory and non-statutory designations are significantly distant from the site, which will ensure that its development would have no detrimental impact upon them.
4.2 HISTORICAL ASSETS
4.2.1 The Alternative Site has been assessed for any proximity to known and designated Historic Assets, using the “Cof Cymru – National Historic Assets of Wales” from CADW’s website. An extract from Cof Cymru Assets map for Llandybie is reproduced below as Plan K. The red star denotes the position of the Alternative Site.
Plan K – Extract from Cof Cymru Historic Assets website
4.2.2 The extract reveals there to be no Scheduled Ancient Monuments in the locality, whilst Listed Buildings are concentrated off the eastern side of Llandeilo Road, where it merges with High Street.
4.3 ENVIRONMENTAL CONSTRAINTS
Potential for Risk from Flooding
4.3.1 The Alternative Site has been assessed against the Flood Map for Planning, prepared by Natural Resources Wales, and as referred to within the Welsh Government’s revised / draft “Technical Advice Note 15: Development and Flood Risk”. An extract from the Flood Map for Planning is reproduced below as Plan L, with the site denoted by a red star.
Plan L – Extract from NRW’s Flood Map for Planning
4.3.2 The above plan extract revels that no part of the Alternative Site lies within the designated flood zone of the River Marlais and Nant Gwinau, and thus the potential development of the site is not at risk from fluvial flooding.
4.3.3 An examination has also been made of NRW records relating to potential surface water flooding, as shown by purple tone in the above plan. The red star again denotes the positioning of the Alternative Site and reveals there to be no potential for pooling of surface water upon the site.
Past and Present Potential for Ground Contamination and Coal Mining Activity
4.3.4 The Alternative Site comprises a modest former agricultural field. Due to its greenfield nature and agricultural use, the field as no history of known past ground contamination related constraints.
Plan M – Coal Authority Map indicating former mining legacy
4.3.5 The records of The Coal Authority have been examined and reveal the history of coal mining in this part of the County. Whilst there are underlying seams of coal under Llandeilo Road, there are no mine entries near the site, as indicated above at Plan M by a red star.

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 aspects inherently poses risks that the Plan may be unsound and so in turn fails 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
5.1 VIABILITY APPRAISAL
5.1.1 The following provides an indication of the viability of delivering the proposed 54 units on the Alternative Site in question. It is based very much on its greenfield status and uses values 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 land value for the scheme.
Costs
• Dwelling construction costs are based on an absolute minimum of £1300 per metre given that bespoke four bed detached houses (140 sq.m.) and three-bed semi-detached houses (90 sq.m.), with a medium grade of internal finishing.
• Estate road carriageway costs are placed at £1200 per linear metre
• Connections for all utilities include water, foul water and electric.
• Developer’s Profit based on minimum RICS guidelines (18%)
• Professional Fees include planning application fee, associated professional fees, estate agency fees (1%) and LABC Warranty fee.
Sales Values
• Sale Prices based on LPAs “Affordable Housing” Supplementary Planning Guidance, market research and Welsh Government “Acceptable Cost Guidance” figures where relevant.
5.1.2 Using the above, the following represents a strategic viability appraisal for the proposed 54 units, based on an affordable housing level being a 10% contribution of the total number of dwellinghouses proposed.
Costs
Cost Per Unit/Metre
No. Units/Metres
Total
Four Bed Houses
182,000
24
4,368,000
Three Bed Semi-detached
117,000
30
3,510,000
Road Construction
1200
375
450,000
Utility Connections
5000
54
270,000
Professional Fees
-
-
190,000
Sprinklers
3500
54
189,000
Parks and Education
5000
54
270,000
Contribution
Total
9,247,000
Sales
Four Bed (Open M’kt)
285,000
24
6,840,000
Three Bed (Op M’kt)
225,000
24
5,540,000
Three Bed (Affordable)
91,000
6
546,000
Total Sales
12,926,000
Developers Profit
Total
2,327,000
Residual Land Value
1,352,000
Table 3
5.1.3 Based on the above figures, it is considered that in-principle, the development of the site would be financially viable. The residual land value of £1,350,000 for a site consisting of 54 dwellings over a 4.8-acre sized site is consistent with evidence gathered over recent years by the District Valuer in examining residential site transactions within Carmarthenshire. The DV discovered land values on completed and on-going sites to be averaging £245,000 per net residential acre of land, based on 2020 values.
Alternative Site Supporting Statement March 2023
Land adjoining Llandybie Primary School, Llandybie Mr W.B. James
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, with a developer secured, it is envisaged that the site could be capable of being completed within 2 years from the adoption of the Replacement Local Development Plan. Llandeilo Road remains an attractive part of Llandybie given its panoramic views over surrounding countryside, benefitting from its semi-rural location, but easy access to Llandeilo and Ammanford by road and the nearby schools, shops, services and community facilities.
6.0 NATIONAL PLANNING POLICY CONSIDERATIONS
6.1 In the preparation of any development plan, consideration must be given to national planning policy and guidance. At present, this takes the form of Planning Policy Wales and a series of Technical Advice Notes (TAN) that deal with a variety of topic areas.
6.2 With regards to residential development, or housing, the overarching requirements and principle guidance set by national policy can be found at PPW, which reads as follows:
“Local planning authorities must ensure that sufficient land is genuinely available or will become available to provide a 5-year supply of land for housing judged against the general objectives and the scale and location of development provided for in the development plan. This means that sites must be free, or readily freed, from planning, physical and ownership constraints, and economically feasible for development, so as to create and support sustainable communities where people want to live. There must be sufficient sites suitable for the full range of housing types.”
6.3 At present, Carmarthenshire County Council’s housing supply figure is below the required 5-year level therefore, it is imperative that this is addressed as quickly as possible to avoid further deterioration of communities and the facilities and services they have to offer.
6.4 Dealing specifically with the Alternative Site subject of this Report, it is evident that its inclusion within the Replacement LDP would adhere to the requirements of PPW, in that it is free from any planning, physical, or ownership constraint. In addition, as shown in Section 5 of this statement, the site is also economically viable in deliverability terms.
7.0 CONCLUSION
7.1 The Alternative Site is moderate in overall size, with established dwellinghouses located off half of its eastern and north-eastern perimeters at Llandeilo Road. The enclosure tends to be well screened from public view by virtue of high perimeter trees which shelter the site and add a sense of semi-rural character to the scheme.
7.2 The Site lies within close proximity and walking distance to the existing community and local services of Llandybie 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 nearby settlements, specifically the towns of Llandeilo and Ammanford, together with other locations within and adjoining the County. In tandem to this, the development of the Site will in turn ensure a deliverable source of future housing for the Sustainable Community in which it lies, which has seen both allocated sites fully developed leading to an under supply 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 recognises the suitability and deliverability of modest
sites if it is to continue to realise the contribution villages such as Llandybie make to the housing land supply.
7.4 With the Alternative Site having no access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership constraints, its delivery if included within settlement limits is assured. Combined therefore with its locational characteristics, the Site in question represents a sustainable alternative for future housing development.
7.5 In view of the above and the information provided within this Statement, it is respectfully requested that the Alternative Site in question be included within limits for a moderately-sized residential development.

Include site within the Plan.

1.0 I NTRODUCTION
1.1 Mr W. B. James (the Land Owner) have instructed Evans Banks Planning Limited to prepare and submit an Alternative Site Supporting Statement for the inclusion within defined settlement limits of land off Llandeilo Road, Llandybie, Ammanford for the purposes of residential development in the forthcoming Replacement Carmarthenshire Local Development Plan.
1.2 This Statement has been prepared in line with the Authority’s published documents entitled Revised Carmarthenshire Local Development Plan: Guidance Note and Revised Carmarthenshire Local Development Plan: Candidate Site Assessment Methodology. The contents of this Statement therefore address the set criteria, determining the issues and each qualifying point raised within these documents.
Consideration has also been given to ensuring that this formal submission complies with the guidance and requirements of Planning Policy Wales (Edition 11), in relation to the preparation of development plans and the allocation of land for residential purposes as part of that preparation process.
1.3 The contents of this Statement therefore provide a comprehensive case for the inclusion of the land for residential development purposes within the defined settlement limits of Llandybie, and it should also be read in conjunction with the accompanying supporting information and indicative site layout plan.

2.0 SITE CONTEXT
2.1 THE SITE
2.1.1 The Alternative Site relates to a parcel of undeveloped agricultural pasture which is set off the eastern flank of the A483 Llandeilo Road, immediately adjoining a continuous frontage of semi-detached dwellinghouses which are orientated to face that main highway. The field parcel is triangular in shape and extends to a gross area of 0.94 acres (0.38 hectares).
2.1.2 The southern perimeter of the field shares a common boundary with residential properties which front the eastern flank of Llandeilo Road, whilst the road frontage of the site is largely open, with a shallow hedgerow across the back of grassed verge. The road frontage extends for some 75 metres and whilst the initial couple of metres comprises a wide grassed verge, the actual grazing field itself lies some two metres in ground level below the passing trunk road. To the rear east of the field lies a public cemetery which extends off the rear of all residential properties fronting Llandeilo Road. The cemetery continues east to adjoin Llandybie Parish Church.
2.1.3 Grazing fields extend to the north and north-east and take a similar form to the Alternative Site being semi-improved pasture, which are well-defined with well managed mature tree and hedgerow perimeters and of varying acreages. A continuous line of mature deciduous trees forms the northern boundary and extends eastwards to the banks of the Afon Marlais.
2.1.4 The opposite flank of the Llandeilo Road contains a range of individual residential properties set above the road level, exhibiting a arrange of dwelling forms and designs, together with traditional and more established semi-detached houses.
2.1.5 The parcel of land is identified in red by Plan A, which illustrates its wider position within the settlement of Llandybie and shows the existing consolidated form of frontage development to the A483 Road. Plan B provides a detailed Ordnance Survey map extract with the site perimeters identified.
Plan A – wider setting of Llandybie with site highlighted
Plan B – detailed OS Plan of Alternative Site
2.1.6 Photographs of the Alternative Site are reproduced below, showing its current March 2023 condition and form. The Alternative Site is relatively level in form and profile, being set some two metres below adjacent road level. It is well grazed to the extent that no overgrowth vegetation is visible. All mature perimeter trees appear in good health which warrant retention. A wide verge lies off the back edge of highway, and a continuous footway / pavement runs along the entire road length. Plan C is an extract from Google Earth where such physical features are clearly evident.
Plan C – Google Earth view of site (April 2021)
Photo 1 – view of field from Llandeilo Road showing boundary with No 70
Photo 2 – view of eastern fenced perimeter and cemetery beyond
Photo 3 – view north along Llandeilo Road with site set off end of continuous row of properties
Photo 4 – view to left / south-east at potential access point with A483 road with wide visibility and public pavement along its entire frontage
Photo 5 – view to left / north at potential access point with A483 road with wide visibility extending for well over 100 metres along Trunk Road
2.2 SETTLEMENT SUSTAINABILITY AND SITE SETTING WITHIN THE CURRENT ADOPTED LOCAL DEVELOPMENT PLAN & SECOND DEPOSIT DRAFT (FEBRUARY 2023)
2.2.1 Under the provisions of the current adopted Carmarthenshire Local Development Plan (2014), the field enclosure adjoins the Settlement Limit of Llandybie. The site is shown edged in red at Plan C below, with the extract for the 2023 published Second Deposit Draft of the LDP shown at Plan D, with the site edged in red. It is immediately apparent that the settlement limits have not changed in the transition to a new draft Plan, with the limits wrapping about the primary school buildings and forming about the access road to encircle the rear garden perimeters of Llandeilo Road properties. However, it is noted that over half the Alternative Site’s perimeter is shared with built development, with the open, western perimeter very well defined by established field boundary features.
Plan D – 2014 Adopted LDP Proposals Map for Llandybie
Plan E – Second Deposit Draft (2023) of northern Llandybie
2.2.2 As can be seen, the Alternative Site adjoins and is well related to the draft defined Development Limits of Llandybie. The Alternative Site seeks to develop off a common residential boundary with Llandeilo Road properties, and the backland cemetery, and directly opposite established dwellinghouses at Llandeilo Road.
2.2.3 Llandybie has good accessibility to the nearby towns of Llandeilo to the north and Ammanford to the south, and its links via the A483 Trunk Road to the M4 at Pont Abraham, and north to converge with the A40 north of Llandeilo.
2.2.4 In terms of the Alternative Site, it is located within easy walking distance of all community facilities and local services present provided within the Llandybie settlement. Access to further facilities in the town of Ammanford to the south can be gained by regular bus services where stops are located near the site frontage upon the A483 road.
2.2.5 Transition from Adopted Local Development Plan (2006-21) – Allocation Status
In terms of planned growth, the proposed Alternative Site at Llandybie is located within the identified Ammanford / Cross Hands Growth Area within the current LDP, adopted in December 2014. Llandybie is regarded by the Council as sustainable settlement given its accommodating of a range of services providing a modest degree of sustainability to the local community.
2.2.6 A number of the housing allocations were presented within the LDP but have yet to be delivered after 8 years since the Plan’s adoption. Plan F below provides an extract from the 2014 Proposals Map for Llandybie. In the formulation of a new Plan, the Council have appeared to repeat the from a total of four sites from the adopted plan into the new Replacement LDP. Plan G illustrates the Second Draft Plan.
Plan F – 2014 LDP Extract for Llandybie illustrating four residential allocations
Plan G – Second Draft Plan for Llandybie with similar residential allocations
2.2.7 The net result is that despite Llandybie continuing to have good provision of community facilities, local services and public transport connections to Llandeilo and Ammanford, its ability to grow and capitalised on these sustainable attributes has been prevented through a lack of delivery of existing allocations. More deliverable residential opportunities are required. The deliverability of the remainder of the longstanding allocations are clearly in doubt, so, in order to re-address this deficit in provision and capitalise on the sustainability of the Sustainable Community, more deliverable residential allocations are required.
2.2.8 Second Deposit Draft LDP (February 2023)
The Council published a Deposit Draft in February 2023, which is now subject of public consultation. Within the Second Deposit Draft, four sites are allocated for housing provision within Llandybie, as was also included within the settlement limits in the 2014 adopted Plan.
Table 1 – 2023 Second Deposit Draft Allocation
2.2.9 It is noted that Llys-y-Nant is virtually completed, as is Land north of Maespiode with its 8 units. Clos Felingoed is being developed by a local housing association, after full planning permission has been granted in 2022.
The large site at Maespiode for 45 units (PrC3/h20) remains undeveloped despite being the subject of a full planning permission, submitted in March 2022 (PL/03750). It is noted that the application has yet to be determined.
2.2.10 The Council’s Housing Growth Strategy targets Ammanford as the focal town in the Ammanford / Cross Hands Principal Growth Cluster. Llandybie forms part of the principal service centre centring upon the Ammanford Cluster as defined within the Second draft LDP. The new Draft Proposals Map reveals that the Council have allocated a total of 8 sites at Ammanford as shown below.
Table 2 – Ammanford draft allocations under Policy HOM1
2.2.11 The above eight alocated sites proposed for Ammanford reveal a combined total of 292 units, howeve upon analysis it is clear Wind Street, Llys Dolgader, Gwynfryn and Yr Hen Felin have already been constructed, totalling 49 dwellings.
2.2.12 Of the other four Ammanford allocations, it is immediately noteworthy that they are predominately “roll-overs” from earlier Development Plans with those sites showing no commitment whatsoever to commit to the implementation of a planning application. We would comment on the two largest of those sites as follows:
Site PrC3/h4 - Tirychen Farm, Dyffryn Road, Penybanc - for 150 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.
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. Clearly, there is no historic demand for a site of this scale in this part of the Ammanford area. More physically challenging sites, such as the re-development of the Betws Colliery site at Betws and Cae Pound at Cross Hands West Tip have come forward long before Tirychen, and yet still the Council is prepared to allocate the site once again in a new Development Plan.
The decision to retain Tirychen Farm after a period of 30 years within the LDP is shown to be inconsistent, as does not sit with LDP Procedural Guidance which encourages Local Planning Authorities to only re-allocate sites based upon firm evidence of deliverability.
Plan H – wider view of Ammanford draft Proposals Map
2.2.13 Site Prc3/H36 - Betws Colliery – for 66 units
Outline planning permission was first granted for residential development on the allocation as far back as 2005 (Application E/09584), with reserved matters being granted in 2011 (Application E/24724). A Non-Material Amendment (Application PL/04568) has been granted in September 2022 for the ‘Removal of chimneys and raising the height of window sills’.
The site was allocated in the Carmarthenshire Local Development Plan (2014) as part of a larger allocation (GA3/h9), and Allocation PDB27 of the Carmarthenshire Unitary Development Plan (2006), which included the land south of Ffordd y Glowyr, which has been developed.
However, the northern element continues to be allocated for 66 units in the Second Draft LDP. This is despite having almost 20 years of support for the principle of residential development at the historic allocation from the Council, with not a single housing unit has been delivered to date.
2.2.14 The above analysis serves to demonstrate that the Council’s strategy for housing growth in the Ammanford Cluster is questionable and open to considerable criticism in rolling over allocations from the last LDP period without any realistic prospect of those allocations being brought forward for development and delivery.
2.3 Settlement Facilities
2.3.1 The Alternative Site lies just off the A483 Llandeilo to Ammanford main highway. Public bus stops are located only 2-3 minutes’ walk from the Alternative Site at Llandeilo Road to Llandybie Square. Main public bus services call at these stops, particularly:
X13 service (Llandeilo to Swansea) which calls at Llandeilo Road en-route to Ammanford, Pontardulais, Penllergaer, Fforestfach and Swansea City Centre.
Bus service 103 operates between Llandeilo and Ammanford.
Service 165 also runs between Ammanford and Cross Hands.
2.3.2 The Alternative Site lies less than a three-minutes’ walk from the primary school. A selection of small convenience shops, supermarket, public houses and community facilities are located at High Street, and upon its junction with Llandeilo Road.
2.3.3 Llandeilo and Ammanford town centres are located a short 10- and 5-minutes’ drive / bus journey away respectively with its associated comparison shops, high street banks, public houses/cafes, offices, industrial estates, library, and leisure/recreation facilities.
2.3.4 Llandybie lies upon the Heart of Wales Rail Line, and the station can be accessed at Heol-y-Brenin, being less than a ten minutes’ walk from the Alternative site.

3.0
3.0 THE PROPOSAL
3.0.1 This Statement is accompanied by an indicative layout for a potential residential scheme that could be development on the site. It should be emphasised that the accompanying layout is for illustrative purposes only, and that other design solutions for the site could be reached. Notwithstanding this, the accompanying layout drawing has taken into account all potential assets and constraints of the site and demonstrates that it can deliver 14 units in a deliverable and sustainable manner.
3.1 DEVELOPMENT OVERVIEW
3.1.1 It is proposed that the Alternative Site be allocated in the forthcoming Replacement LDP for the purposes of a combined total of 14 residential units. As detailed above, the accompanying illustrative layout demonstrates that the site can accommodate this number in a deliverable and sustainable manner. Plan I illustrates the indicative site layout for the Alternative Site, as edged in red, extending off School Road, with a new access junction set at a mid-point in the site frontage and descending into the site. Proposed frontage properties could face the main road, but be served off rear parking courtyards accessed off the internal estate road.
Plan I – Site Layout
3.1.2 As illustrated above, the site is capable of accommodating detached, linked and semi-detached houses to replicate and being reflective to the existing form of new, modern development to the east at Llys-y-Nant and south at Maespiode.
3.1.3 With regards to access, it is proposed that the Alternative Site would be served by improvements and widening of the existing access road, and onto a junction with the A483 highway. Vehicle speeds are consistent with the 20mph speed limit, and thus visibility splays of 2.4m x 45m to the south and 90 metres to the north can easily be achieved where the junction adjoins the A483 road. Photographs 4 and 5 above illustrate that visibility splays to those distances can already be achieved in both directions. The Applicant also owns the adjoining northern field enclosure and is able to control the extent of the northern visibility splay through reduction in ground vegetation and having no man-made obstructions in place.
3.1.4 The Alternative Site proposals can fully retain all existing boundary treatments being established tree perimeter and hedgerows to the northern perimeter, and about the existing houses at Llandeilo Road.
3.2 INFRASTRUCTURE CONSIDERATIONS
3.2.1 Development of the Alternative Site for residential units would be served by mains water, gas, public sewer and electricity connections.
3.2.2 A new estate road is proposed within the development. This will be equipped with roadside gullies and drainage which aid discharge run-off from the carriageway. The drainage of the proposed access road to the site could eventually connect to the River Marlais, after passing through appropriate oil interceptors.
3.2.3 The Alternative Site comprises of agricultural pasture. There are no areas of significant marshy grassland or water-logging evident, and therefore at first inspection, it appears that the site benefits from good ground percolation of rainwater.
3.2.4 Soakaways would be the most sustainable means of disposing of surface water from individual properties. If required, attenuation measures can be deployed on site to control surface water run-off during extreme storm events, which could also allow for additional capacity, making allowances for climate change. Such features can be soft engineered in the form of attenuations basins and / or swales, thus adhering to the principle of Sustainable Urban Drainage Systems (SUDS).

4.0
4.0 ENVIRONMENTAL CONSIDERATIONS
4.1 ECOLOGICAL ATTRIBUTES
4.1.1 The Alternative Site has been assessed against data held on the “Data Map Wales” website which details statutory and non-statutory National and Local sites of ecological importance. Plan J below provides an extract of those records applied to the Llandybie locality. The red star denotes the position of the Alternative Site.
Plan J – Extract from Data Map Wales detailing any known ecological interests
4.1.2 The records reveal that the Alternative Site does not include or adjoin any national or local nature conservation designation. The Cernydd Carmel SSSI lies over one kilometre north-west of the site, and thus at a very safe distance as to not be affected by any development proposals at the site.
4.1.3 Any biodiversity assets that may be present or adjoining the Alternative Site have been given full consideration with regards to exploring its potential for residential
development. This has included the proposed retention and management of existing boundary trees. It is envisaged that the entirety of mature tree and hedgerow lines could be retained and managed further for uninterrupted biodiversity gain.
4.1.4 It is considered that any statutory and non-statutory designations are significantly distant from the site, which will ensure that its development would have no detrimental impact upon them.
4.2 HISTORICAL ASSETS
4.2.1 The Alternative Site has been assessed for any proximity to known and designated Historic Assets, using the “Cof Cymru – National Historic Assets of Wales” from CADW’s website. An extract from Cof Cymru Assets map for Llandybie is reproduced below as Plan K. The red star denotes the position of the Alternative Site.
Plan K – Extract from Cof Cymru Historic Assets website
4.2.2 The extract reveals there to be no Scheduled Ancient Monuments in the locality, whilst Listed Buildings are concentrated south of the site off Llandeilo Road, where it merges with High Street.
4.3 ENVIRONMENTAL CONSTRAINTS
Potential for Risk from Flooding
4.3.1 The Alternative Site has been assessed against the Flood Map for Planning, prepared by Natural Resources Wales, and as referred to within the Welsh Government’s revised / draft “Technical Advice Note 15: Development and Flood Risk”. An extract from the Flood Map for Planning is reproduced below as Plan L, with the site denoted by a red star.
Plan L – Extract from NRW’s Flood Map for Planning
4.3.2 The above plan extract revels that no part of the Alternative Site lies within the designated flood zone of the River Marlais and Nant Gwinau, and thus the potential development of the site is not at risk from fluvial flooding.
4.3.3 An examination has also been made of NRW records relating to potential surface water flooding, as shown by purple tone in the above plan. The red star again denotes the positioning of the Alternative Site and reveals there to be no potential for pooling of surface water upon the site.
Past and Present Potential for Ground Contamination and Coal Mining Activity
4.3.4 The Alternative Site comprises a modest former agricultural field. Due to its greenfield nature and agricultural use, the field as no history of known past ground contamination related constraints.
Plan M – Coal Authority Map indicating former mining legacy
4.3.5 The records of The Coal Authority have been examined and reveal the history of coal mining in this part of the County. Whilst there are underlying seams of coal under Llandeilo Road, there are no mine entries near the site, as indicated above at Plan M by a red star.

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 aspects inherently poses risks that the Plan may be unsound and so in turn fails 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
5.1 VIABILITY APPRAISAL
5.1.1 The following provides an indication of the viability of delivering the proposed 14 units on the Alternative Site in question. It is based very much on its greenfield status and uses values 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 land value for the scheme.
Costs
• Dwelling construction costs are based on an absolute minimum of £1300 per metre given that bespoke four bed detached houses (160 sq.m.) 3-bed detached at 120 sqm., 2 bed linked houses at 70 sq.m., and three-bed semi-detached houses (90 sq.m.), with a medium grade of internal finishing.
• Estate road carriageway costs are placed at £1200 per linear metre
• Connections for all utilities include water, foul water and electric.
• Developer’s Profit based on minimum RICS guidelines (18%)
• Professional Fees include planning application fee, associated professional fees, estate agency fees (1%) and LABC Warranty fee.
Sales Values
• Sale Prices based on LPAs “Affordable Housing” Supplementary Planning Guidance, market research and Welsh Government “Acceptable Cost Guidance” figures where relevant.
5.1.2 Using the above, the following represents a strategic viability appraisal for the proposed 14 units, based on an affordable housing level being a 10% contribution of the total number of dwellinghouses proposed.
Costs
Cost Per Unit/Metre
No. Units/Metres
Total
Four Bed Houses
208,000
2
416,000
Three Bed Houses
156,000
2
312,000
Three Bed Semi-detached
117,000
4
468,000
Two Bed Linked
91,000
6
546,000
Road Construction
1200
70
84,000
Utility Connections
5000
14
70,000
Professional Fees
-
-
95,000
Sprinklers
3500
14
49,000
Parks and Education
5000
14
70,000
Contribution
Total
2,110,000
Sales
Four Bed (Open M’kt)
295,000
2
590,000
Three Bed (Open M’t)
240,000
2
480,000
Three Bed semi (Open
225,000
4
900,000
Two Bed (Open M’kt)
185,000
4
740,000
Two Bed (Affordable)
78,000
2
156,000
Total Sales
2,866,000
Developers Profit
Total
516,000
Residual Land Value
240,000
Table 3
5.1.3 Based on the above figures, it is considered that in-principle, the development of the site would be financially viable. The residual land value of £240,000 for a site consisting of 14 dwellings over a 0.94-acre sized site is consistent with evidence gathered over recent years by the District Valuer in examining residential site transactions within Carmarthenshire. The DV discovered land values on completed and on-going sites to be averaging £245,000 per net residential acre of land, based on 2020 values.
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, with a developer secured, it is envisaged that the site could be capable of being completed within 2 years from the adoption of the Replacement Local Development Plan. Llandeilo Road remains an attractive part of Llandybie given its panoramic views over surrounding countryside, benefitting from its semi-rural location, but easy access to Llandeilo and Ammanford by road and the nearby schools, shops, services and community facilities.
6.0 NATIONAL PLANNING POLICY CONSIDERATIONS
6.1 In the preparation of any development plan, consideration must be given to national planning policy and guidance. At present, this takes the form of Planning Policy Wales and a series of Technical Advice Notes (TAN) that deal with a variety of topic areas.
6.2 With regards to residential development, or housing, the overarching requirements and principal guidance set by national policy can be found at PPW, which reads as follows:
“Local planning authorities must ensure that sufficient land is genuinely available or will become available to provide a 5-year supply of land for housing judged against the general objectives and the scale and location of development provided for in the development plan. This means that sites must be free, or readily freed, from planning, physical and ownership constraints, and economically feasible for development, so as to create and support sustainable communities where people want to live. There must be sufficient sites suitable for the full range of housing types.”
6.3 At present, Carmarthenshire County Council’s housing supply figure is below the required 5-year level therefore, it is imperative that this is addressed as quickly as possible to avoid further deterioration of communities and the facilities and services they have to offer.
6.4 Dealing specifically with the Alternative Site subject of this Report, it is evident that its inclusion within the Replacement LDP would adhere to the requirements of PPW, in that it is free from any planning, physical, or ownership constraint. In addition, as shown in Section 5 of this statement, the site is also economically viable in deliverability terms.
7.0 CONCLUSION
7.1 The Alternative Site is very modest in overall size, with established dwellinghouses located off its immediate southern perimeter, and located directly opposite off Llandeilo Road. The enclosure tends to be well screened from public view by virtue of high perimeter trees which shelter the site along the northern perimeter, and add a sense of semi-rural character to the scheme.
7.2 The Site lies within close proximity and walking distance to the existing community and local services of Llandybie 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 nearby settlements, specifically the towns of Llandeilo and Ammanford, together with other locations within and adjoining the County. In tandem to this, the development of the Site will in turn ensure a deliverable source of future housing for the Sustainable Community in which it lies, which has seen both allocated sites fully developed leading to an under supply 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 recognises the suitability and deliverability of modest
sites if it is to continue to realise the contribution villages such as Llandybie make to the housing land supply.
7.4 With the Alternative Site having no access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership constraints, its delivery if included within settlement limits is assured. Combined therefore with its locational characteristics, the Site in question represents a sustainable alternative for future housing development.
7.5 In view of the above and the information provided within this Statement, it is respectfully requested that the Alternative Site in question be included within limits for a modestly sized residential development.

Amend Plan

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

Submissions by Carys Jones - dealt with in another representation

Include site within Plan

REF: REPRESENTATION TO THE DEPOSIT REVEISED DEVELOPMENT PLAN OF
CARMARTHENSHIRE COUNTY COUNCIL OF A PROPOSED SITE AT LAND TO THE REAR OF TY
IORWETH, DREFACH FELINDRE, LLANDYSUL, SIR GAR, SA44 5YD.

This submission is made in response to the latest consultation of the deposit revised
development plan of Carmarthenshire County Council. This representation is made seeking
the inclusion of this site within the LDP. Details of the site are as follows;

- Address – Land to the rear of Ty Iorweth, Drefach Felindre, Llandysul, Sir Gar, SA44
5Yd.
- Site area - 0.922ha.
- The proposal is for up to 9 residential dwellings.

The sites site plan is attached. Red line indicated the proposed site for the dwellings and
associated access road. Blue line is land within ownership.

Also find attached the integrated sustainability appraisal.
The application site is currently low grade agricultural land. The site is well located within
the settlement adjacent to the built form and not in a prominent location. The site is in
walking distance to a range of local facilities and public transport.

The site is put forward due to the lack of sites currently put forward within the settlement.
It is noted that only one residential allocation (other than for windfall sites within the
development boundary) has been allocated within the settlement, and it is highlighted that
development has already commenced in this site. Therefore there are no new allocated
sites proposed. It is strongly felt that this will leave an under provision in terms of the 5 year
land supply in the area during the plan period, which will have a negative impact on the
local economy, services such as schools and socially due to a lack of opportunity for people
to purchase and develop their own homes.

The site has a range of positive attributes to include
- Good road and pedestrian access,
- Sustainably located,
- Reasonably level and therefore economical to develop,
- Deliverable in the plan period,
- Close proximity to local school and facilities,
- Services such as mains water and sewerage on/or adjacent to the site,
- Broad national and local planning policy compliance.

We believe that the site warrants allocation in the LDP and we respectfully request its
inclusion.
If you require any additional information relating to this application, please do not hesitate
to get in touch.

Include Candidate Site reference SR/078/004 within the Revised Local Development Plan.

We are instructed by Mr O. Evans to a 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/078/004, seeking inclusion of their land for future residential development within the
defined settlement limits of Llanddarog within the Replacement Local Development Plan.

The Candidate Site comprises an irregular-shaped former grazing field set to the immediate
rear of a detached property, known as Haulfan and its side garden fronting the principal
highway in Llanddarog. The residential estate of Brynhyfryd forms a common perimeter with
the entire western boundary of the Candidate Site. Three detached bungalows which front
the unclassified road to Penllwynio Farm have rear gardens which form the continuous
eastern perimeter with the Site.

We have noted that approximately half of the Candidate Site is included within the draft
settlement limits as Residential Allocation SuV19/h2, apparently capable of accommodating
10 residential units according to the housing schedule listed under Policy HOM1 of the Plan.
However, the southern half of the field has not been included. This formal Representation
relates solely to the unsuccessful part of the Candidate Site.
The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our clients’ submission, reasons why the site was not selected for inclusion within the draft
settlement limits of Llanddarog, as contained within the Deposit Draft. We note that the
submission successfully passed through all three Assessment Stages, being 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) of the Council’s site assessment.
It therefore crucially was adjudged acceptable in all technical aspects of formal assessment, but was only partially rejected at the final selection stage, with reasons for non-inclusion reported as follows:
Part of the site will be allocated for residential development. Site to be allocated with reference SuV19/h2
Our clients consider 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, our clients consider that the Second Deposit draft settlement limits for Llanddarog, as defined under Policy SD1 “Settlement Limits”, should be amended to include the land as edged in red upon the extract of the Proposals Map for Llanddarog, as reproduced below in Figure 1. The land should be appropriately allocated for housing under Policy HOM1 “Housing Allocations.”

Figure 1 – Extract from Proposals Map with Representation site edged in red

This formal representation letter supplements the following documents which comprise a complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form

Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits
1.0 Allocation of only Half Candidate Site
1.1 The Council have not provided any reasoning for the allocation of only half the Candidate Site. The new settlement limit, as shown in Figure 1 above, does not follow any defensible boundary, such as a hedgerow, treeline or even dividing fence across the enclosure. Its positioning is therefore physically illogical in the context of adding new housing to this part of Llanddarog. Google Earth provides an illustration of the physical features of this part of Llanddarog and is reproduced in Figure 2 below.

Figure 2 – Google Earth (April 2021) – illustrating the cultivated form of the Candidate Site

1.2 We therefore consider that the Council has adopted this rather inconsistent approach on the basis that it only considers that Llanddarog should grow by very minor proportions over the Plan Period to 2033. However, the village is significant in scale, containing over one hundred dwellinghouses, primary school, two public houses, post office and village hall. It also possesses good public bus service connections to Carmarthen and Llanelli. In other words, it is highly sustainable as a place to live and work.
1.3 The Representation Site indicative site layout plan is reproduced below as Figure 3.
It illustrates for cul-de-sac form of development with a total of 29 detached and semi-detached dwellinghouses and bungalows set fronting an internal estate road, which can access the site via an access through the side garden aea of Haulfan, where
Draft Housing Allocation SuV19/h2
Candidate Site
three detached properties can be formed fronting the main Llanddarog highway. The
the proposed form of layout and development is complementary in form to adjacent
established form of residential layout at Brynhyfryd.
1.4 The draft Allocation for only 10 units indicates that the same single access would be
used, and still allow for three detached dwellings to the road frontage, and thus only 7
units to the rear field. However, contour levels within thris rear field are fairly
consistent, meanig that any short or long distance views from the south at this field
would gain an appreciation of new housing falling against a backdrop of established
properties at Brynhyfryd and Penllwynio Road, regardless of the number and extent
of the site in land area. The proposals do not encroach the proposed site so far
south into open countryside that it extends beyond the physical confines of the
two flanks of residential development set off either side.
1.5 We submit that the Candidate Site encompasses the entire rear, eastern boundary of
Brynhyfryd properties and thus complemented that entire development in depth and
form. The proposed draft allocation in only proposing half that area fails to respect
that character, and in commiting to allocate land beyond the previous LDP settlement
limits, our clients cannot understand the physical logic in not extending the draft
allocation over the entire field.

Figure 3 – Indicative site layout plan of proposed Representation Site

2.0 Overall Housing Supply at Llanddarog & Carmarthen Cluster
2.1 The proposals under this Representation merely seek the addition of a further 19 residential units to the overall housing supply of Llanddarog, to add to the 10 units already allocated within the Second draft Plan. Llanddarog is defined as sustainable settlement, (SuV19), and lends to the principal service centre centring upon the Carmarthen Cluster as defined within the Second draft LDP.
2.2 The Carmarthen Cluster aims to provide an additional 1690 residential units over the Plan period 2018- 2033, and thus the addition of an additional 19 units to an already allocated site at Llanddarog to reach a combined total of 29, units will not lead to an over-supply of dwellinghouses within the Cluster.
2.3 Llanddarog is quite unique in terms of its positioning and setting being part of the Carmarthen Cluster. It is placed at the south-eastern extremity of the defined area, bordering the Cross Hands / Ammanford Cluster. Llanddarog together with Porthyrhyd serves a rural hinderland and are the principal settlements off the A48 Trunk Road between Carmarthen and Cross Hands. Consequently, there are few other defined settlements in this part of the County which contain specific residential allocations. Policy HOM1 provides details of the two allocations in Llanddarog and only one at Porthyrhyd, as shown below.
Figure 4 – Policy HOM1 Residential Allocations at Llanddarog & Porthyrhyd
2.4 Only one other site is allocated in Llanddarog that relates to 16 residential units (SuV19/h1) at “Land opposite the Village Hall” It benefits from Approval of Reserved Matters for a mix of three and four bed two-storey houses about a cul-de-sac layout. We note the Applicant is currently seeking relaxation to the extant Section 106 Agreement imposed upon the permission to reduce the number of Affordable Houses on the site from 3 to 2 in number.
2.5 Porthyrhyd is rather broadly equal in village scale to Llanddarog, and yet in the Second Draft Plan only one small site for 6 units is allocated at Llwynhenry Farm (SuV20/h1).
2.6 We have therefore examined and researched sites which have been brought forward as Residential Allocations with the Second Deposit Draft in the Carmarthen Cluster. The Cluster extends in geographic area to Bronwydd, Cynwyl Elfed, Peniel, Rhydargaeau, Alltwalis and Llanpumsaint to the north of the town. It stretches south-west to Llansteffan and Llangain, and east along the River Towy to include Nantgaredig, Pontargothi, Llanarthney and Capel Dewi. It extends along the A48 road as far as Llanddarog and Porthyrhyd. Finally, it stretches south-east along the Towy Estuary to include Cwmffrwd and Ferryside and partly along the Gwendraeth Valley to Pontyates. The following allocations are noted for their inactivity and undeliverability over the last 8-9 years.
2.7 West Carmarthen (PrC1/MU1) – 700 UNITS
In Carmarthen, great emphasis within the Draft Plan has been placed upon the continued allocation of a large, proposed housing site at West Carmarthen. The site is allocated for 700 residential units as Site PrC1/MU1.
This allocation forms the bulk of a Residential Allocation carried over from the current LDP (2014-21) where the allocation was for 1100 units.
We have calculated that of that 1100 units only a total of 141 were constructed between the Plan Adoption date of December 2014 and start of this Replacement LDP Plan Period of 2018. Since 2018, a further 90 units have been constructed, and we note from Land Registry records that the last completed unit was sold at Maes Macsen in September 2021 (18 months ago).
Therefore, since adoption of the 2014 LDP, only a total of 231 units have been completed, equating to a build rate over that 7-year period of only 33 units per annum. This build rate is considerably lower than the anticipated and much promised delivery of 1100 units in the Plan Period of 2014 to 2021, which would have expected an annual build rate of 157 units. An actual return of 33 units per annum equates to only a 21% build rate return on that anticipated for delivery in the 2014-21 Plan.
Only 39 of those units were built in 2017-18 accordingly to the Joint Housing Land Availability Study 2018. The 2019 Study reveals that only a further 5 units were constructed in 2018-19. The August 2019 Study reports that none were under-construction at that time. During 2020 and 2021 when Covid-19 restrictions were at their peak, more units were constructed than at any other time in that LDP plan period, and therefore we would submit at this point in our formal objection that low build rates cannot be held to be reduced as a consequence of Covid-19 restrictions.
It is equally noteworthy that at a time when the housing market was at its most buoyant in 2022, that the only housebuilder with a track record on the site had ceased construction and sold their last completion (September 2021). We submit that this is testament to the weak marketability of the West Carmarthen Site.
Only 231 units out of 1100 units of the Strategic Site have therefore been completed in the 2014-21 LDP period, which equates to only 21% of that allocated total.
The Replacement LDP seeks to delivery 700 units over a Plan Period from 2018 to 2033. The extract from the Proposals Map for Carmarthen reveals that the figure includes for 90 units constructed between 2018 and 2021, leaving a balance of 610 units envisaged in the remainder of the Plan Period to 2033. That would equate to a build rate of 61 units per annum over a 10-year period. Based upon previous build rates at this site, such a predicted build rate can be described as overly optimistic, being nearly double that actually achieved on the site to date.
The West Carmarthen draft allocation includes parcels of residential allocations off the flanks of the A40 that were previously allocated within the Carmarthen District Local Plan (1997), and subsequent Carmarthenshire Unitary Development Plan (2003). No progress was made in bringing the sites at Llysonnen Road and Old St. Clears Road forward, and yet it was allocated within the Local Development Plan in 2014. Consequently, twenty-seven years of Development Plan allocations have elapsed without any signs of delivery of the majority of this site.
Clearly, there is no historic demand for a site of this scale in this part of Carmarthen. More physically challenging sites, such as the Roman Park site in Llangunnor by Redrow Homes, and the Mount Pleasant site, also in Llangunnor, by Lovell Homes have come forward, and been fully completed, long before West Carmarthen. Yet still the Council is prepared to allocate the site once again for hundreds of residential units in a new Development Plan.
2.7 Pibwrlwyd (Site PrC1/MU2) – ALLOCATION OF 247 UNITS
We would also question the allocation of land at Pibwrlwyd in Carmarthen, being partly for a residential development of 247 units on the Parc Pibwrlwyd development. The Council published and subsequently adopted Supplementary Planning Guidance on “Pibwrlwyd” in 2014.
Paragraph 3.2 was quite specific in that “The LDP describes the acceptable uses on the site as follows: “The proposed use for the site is for a business park centred around employment uses (Use Classes B1, B2 and B8), with uses associated with, and ancillary to the existing Coleg Sir Gâr.”
A development brief in the form of SPG has been prepared and adopted. This in setting out appropriate uses under Use Classes B1, B2 and B8 for the employment element of the site also explores other compatible uses. Residential use on this site is not considered appropriate.” (self-emphasis)
The Council has seen fit to re-examine the Development Plan status of this Mixed-Use Site and concluded that residential uses should now be brought forward, with a residential capacity of 247 units. No explanation has been provided within the supporting text to LDP policies to warrant a dramatic departure from the adopted SPG.
The site is completely and physically divorced from established housing at Pensarn and Llangunnor. It is physically separated by foot from local schools, community facilities and play facilities by the A40 / A48 trunk road network, with only a dark and insecure pedestrian underpass linking it to the Pensarn Commercial Area.
New housing at this location would accordingly be quite alien in form to the long-established business and education uses at Pibwrlwyd.
2.8 Land off Parc-y-Delyn (PrC1/h4) – ALLOCATED FOR 17 UNITS
This new allocation suffers from including Tree Preservation Orders imposed upon specimens at the proposed vehicle access onto Parc-y-Delyn.
The site also appears covered in rich flora and fauna and could harbour biodiversity interests.
2.9 As referenced at the outset of this Section, there are several satellite settlements about Carmarthen contributing housing allocations to the Cluster Total of 1690 dwellings. However, we have discovered that many allocations have simply and conveniently been “rolled over” from the 2014 adopted LDP, or in some cases even earlier from the 2008 Unitary Development Plan. No explanation, evidence or demonstration of viability or deliverability has been provided within the Site Assessment Table (January 2023) to demonstrate such a widespread practice. The following sites are examples of such dormant sites:
Cae Camfas, Heol Llanelli, Pontyates (SeC1/h4) – ALLOCATED FOR 8 UNITS
This site in Pontyates was allocated in 2014 in the Local Development Plan, and yet no applications for planning permission have been submitted in the entire 8 years of the Plan Period.
2.10 Gwyn Villa, Llanpumsaint (SuV12/h1) – ALLOCATED FOR 20 UNITS
This site in Llanpumsaint was allocated in 2014 in the Local Development Plan, and yet no applications for planning permission have been submitted in the entire 8 years of the Plan Period.
2.11 Fronheulog, Cynwyl Elfed (SuV1/h1) – ALLOCATED FOR 8 UNITS
This site in Cynwyl Elfed was allocated in 2014 in the Local Development Plan, and also the 2008 UDP, and applications for planning permission have been submitted for only two individual houses in the the entire 15 years of the above combined Plan Periods have been commenced.
2.12 We submit that the above draft allocations at West Carmarthen be significantly reduced in scale, and in the case of Pibwrlwyd and above-named satellite allocations be omitted from the Plan and that housing allocation be redistributed to modest Candidate Sites, of up to 20-30 units such as that proposed at Penllwynio Farm. There is clear evidence in Llanddarog, such as the progress to a detailed scheme at the Village Hall site, that such modest sites are far more likely to be brought forward and developed in full by regional and small housebuilders given that construction and
development costs are more likely to be viable in relation to house sales and the general housing market in this part of Carmarthenshire.
2.13 In the case of Penllwynio Farm, there are little signs within the immediate locality of properties for second sale, and no evidence of undeveloped land available within this part of the settlement limits, which is a strong indicator of a healthy property market at Llanddarog. Consequently, it is a location where housing proposals are deliverable, assisting to meet housing needs in this part of the Carmarthen Cluster.

CONCLUSION
In conclusion, this Representation to the Second Deposit Draft of the Revised LDP has sought to examine the Council’s reasons for non-inclusion of all the Candidate Site.
Our clients have illustrated that their indicative proposals to construct a total of 29 dwellinghouses will not appear at odds to the prevailing spatial pattern of development in Llanddarog. The locality has numerous examples of modern cul-de-sac development being completed at backland / edge of settlement locations, which in turn, advocates that the form of development proposed at Penllwynio Farm is no different, resulting in it being respectful to the character and setting of the locality. The Council have already acknowledged that a backland site is suitable at this location in Llanddarog, our clients merely suggest that it be enlarged to encompass all the level field to a parallel position with the Brynhyfryd estate.

We respectfully request that this Representation be given careful examination, and consequently the defined settlement limits of this part of Llanddarog realigned to include the whole Representation Site, as a Residential Allocation in the Proposals Map of the adopted Local Development Plan.

Include the site as a residential allocation within the LDP.

INTRODUCTION
1.1 Evans Banks Planning has been instructed by Jones Brothers (Henllan) Limited to prepare and submit an Alternative Site Supporting Statement for the allocation of land part of Wern Fraith Farm, Porthyrhyd for the purposes of residential development in the Replacement Carmarthenshire Local Development Plan.
1.2 This Statement has been prepared in line with the Authority’s published documents entitled Revised Carmarthenshire Local Development Plan: Guidance Note and Revised Carmarthenshire Local Development Plan: Candidate Site Assessment Methodology. The contents of this Statement therefore address the set criteria, determining issues and each qualifying point raised within these documents
Consideration has also been given to ensuring that this formal submission complies with the guidance and requirements of Planning Policy Wales (Edition 11), in relation to the preparation of development plans and the allocation of land for residential purposes as part of that preparation process.
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 supporting information and site layout plan.
1.4 RECENT BACKGROUND TO ALTERNATIVE SITE SUBMISSION
Our clients are in the advanced stage of purchasing the freehold of the site, which is allocated for Residential Development (as Site Sc33/h3) in the current adopted Carmarthenshire Local Development Plan (2008-21). Jones Bros (Henllan) Limited have also advanced matters to preparing an application for full planning permission, which has underwent a formal Pre-Application Enquiry before the Local Planning Authority in 2021 (referenced PRE/00495). The application proposals have also proceeded through a formal and statutory period of Pre-Application Consultation for the construction of 42 dwellinghouses in November – December 2022.
1.5 The draft planning application proposals have recently undergone extensive and formal discussions and meetings with Officers of the Council’s SAB Drainage Section, in order to establish their preferred methods and means of disposing of surface water from the site. This has necessitated further, but relatively minor, changes to the application proposals. This has generated the need for a second Pre-Application Consultation exercise, which took place over February and March 2023.
1.6 That very recent consultation exercise did not generate any formal objections from statutory consultees, such as the Council’s Highways Division, Natural Resources Wales, Welsh Water, CADW, Coal Authority and Welsh Government Trunk Roads
Alternative Site Supporting Statement March 2023
Land part of Wern Fraith Farm, Porthyrhyd Jones Bros. (Henllan) Ltd.
Agency. The planning application is subsequently pending formal validation with the Local Planning Authority.
1.7 The site was not subject to a formal Candidate Site submission in August 2018 on account of already allocated status in the adopted LDP (2008-21).
We have noted that the Council in preparation of the Second Deposit Draft of the LDP prepared a “Site Assessment Table” (January 2023). It provides details of the Council’s analysis of each received Candidate Site submission and also residential and employment allocations from the adopted 2014 LDP.
We note that in the case of Residential Allocation SC33/h3 at Wern Fraith it successfully passed through Stage 1 (site compatible against the location of future growth presented in the Preferred Strategy) and Stage 2A (Initial Detailed Site Assessment) of the Council’s site assessment.
However, it was rejected at Stage 2B (further detailed site assessment), with reasons for non-inclusion reported as follows:
“Allocation to be removed. There are concerns regarding the deliverability of the site.”
1.8 This Report seeks to address the issues raised and provide justification and solutions to illustrate to the Council that its misgivings over deliverability are premature, and that it is our clients’ firm intent to obtain planning permission as expeditiously as possible, and to implement and construct the site in the very early stages of the Replacement LDP Plan Period.
Alternative Site Supporting Statement March 2023
Land part of Wern Fraith Farm, Porthyrhyd Jones Bros. (Henllan) Ltd.

2
2.0.0 SITE CONTEXT
2.1 The Alternative Site comprises the significant part of a large undulating to gently sloping grazing field enclosure, which is some 1.62 hectares (4 acres) in size. The entire field lies immediately off the northern flank of a minor road classified as the C2068, which junctions off the B4310 near the centre of the village of Porthyrhyd. The enclosure is actively farmed, cultivated with a silage crop, and is well maintained. The Wern Fraith farmhouse and associated outbuildings are set off the western perimeter of the field enclosure, with mix of boundary mature trees and established hedgerow.
2.2 The carriageway of C2068 Road has a relatively straight alignment from its wide junction off the B4310 main road. A detached dwelling known as “Rhydyfro” separates the south-eastern corner of the application site from the main road junction, with the road frontage of the actual subject field extending westwards for a length of some 90 metres. The roadside frontage is marked by a post and wire fence, which has become overgrown with unmaintained hedgerow and scrub vegetation. A drainage ditch separates the fence line from a wide grassed highway verge, and the tarmac public carriageway.
2.3 Two detached dwellings are to be found off the northern flank of the road at this point, clustered near the farmyard. “Bwthyn-y-Dryw” is a bungalow, with detached garage to its side curtilage, and Wern Fraith Lodge is an established two-storey dwelling adjacent to the farm entrance. Both properties have rear garden perimeters shared with the subject site. Modern detached bungalows and dormer bungalows are to be found directly opposite the site frontage, set back in generous curtilages, with detached garaging.
The eastern perimeter of the site is formed by a linear stone wall, rising to some 1.8 metres in height and forming the boundary of a Chapel with compacted graveyard. That chapel and graveyard front on to the B4310, with further semi-detached, two-storey properties extending north along that main road frontage.
2.4 The agricultural field extends further north running parallel with the rear garden boundaries of frontage properties on the B road, to a northern-most field hedgerow. Further agricultural fields are to be found adjoining to the north-west and west of the northern part of the site.
2.5 Figure 1 illustrates a wider OS Map of the village to highlight the position of Wern Fraith in relation to the village centre, whilst Figure 2 provides a “Google Earth” image of the site, with the above features identified. Figure 3 below depicts an Ordnance Survey map extract with the potential application site edged in red.
Alternative Site Supporting Statement March 2023
Land part of Wern Fraith Farm, Porthyrhyd Jones Bros. (Henllan) Ltd.
Figure 1 – OS Explorer Map with Application Site identified
Figure 2 – Google Earth image – April 2021
Alternative Site
Alternative Site Supporting Statement March 2023
Land part of Wern Fraith Farm, Porthyrhyd Jones Bros. (Henllan) Ltd.
Figure 3 – Ordnance Survey Map Extract with site edged in red
2.2 SETTLEMENT SUSTAINABILITY AND SITE SETTING WITHIN CURRENT LOCAL DEVELOPMENT PLAN
2.2.1 Under the provisions of the current Carmarthenshire Local Development Plan, the site part of Wern Fraith is known as “R/O Ysgoldy, Bethlehem” falls within the defined Settlement Limits of Porthyrhud and allocated as Site SC33/h3. Figure 4 below provides an extract of the Proposals Map of Porthyrhyd. Policy H1 of the adopted Plan suggests that an indicative capacity for the Wern Fraith site could be around 27 units.
Alternative Site Supporting Statement March 2023
Land part of Wern Fraith Farm, Porthyrhyd Jones Bros. (Henllan) Ltd.
Figure 4 – Extract from Adopted LDP Proposals Map of Porthyrhyd (2014)
2.2.2 Within the Second Draft of the Deposit LDP for the Plan Period 2018-2033, the settlement limits of this part of Porthyrhyd have changed to exclude the site, as shown in Figure 5 below.
Figure 5 – Second Draft of Proposals Map (2023) at Porthyrhyd
Alternative Site Supporting Statement March 2023
Land part of Wern Fraith Farm, Porthyrhyd Jones Bros. (Henllan) Ltd.
2.2.3 A notable change between the adopted and emerging LDP Plans is that Sustainable Community 33, which did combine Porthyrhyd with Llanddarog has now been segregated in the new Second Deposit Draft, so far Porthyrhyd is now set alone as SuV20 and Llanddarog as SuV19. When combined in the adopted-2014 LDP the Council allocated the following sites:
Figure 6 – Allocated Residential Sites in SC33
2.2.4 Housing Land Availability in Porthyrhyd and Llanddarog
It is clear that proposed residential land opportunities in Porthyrhyd and Llanddarog have been rationalised since the current LDP was adopted in 2014. The Second Deposit Draft itemises at Policy HOM1 that only three sites are allocated for residential development in the two settlements. Figure 7 below itemises the three new allocations. The former allocated site at Derwen Deg has been completed, and the former proposed site at Is-y-Llan has been omitted.
Figure 7 – HOM1 Draft Residential Allocations in Porthyrhyd & Llanddarog
2.2.5 At Porthyrhyd, only one small residential allocation is proposed, that being SuV20/h1 at Llwynhenry Farm, and capable of only providing 6 dwellinghouses. At nearby Llanddarog, two sites are proposed for allocation, with the one at “Land opposite Village Hall” (SuV19/h1) being carried over from the adopted LDP. It benefits from Approval of Reserved Matters for a mix of three and four bed two-storey houses about a cul-de-sac layout. We note the Applicant is currently seeking relaxation to the extant Section 106 Agreement imposed upon the permission of 16 houses, to reduce the number of Affordable Houses on the site from 3 to 2 in number.
Alternative Site Supporting Statement March 2023
Land part of Wern Fraith Farm, Porthyrhyd Jones Bros. (Henllan) Ltd.
2.2.6 The allocation at “Land adjacent and rear of Haulfryn” (SuV19/h2) is a new allocation in the Second Deposit Draft for only 10 units and appears to have replaced the “Is-y-Llan” allocation from the 2014 adopted Plan.
2.3 Settlement Facilities
2.3.1 The adopted 2014 LDP and Second Deposit Draft Plans both recognise the sustainable nature of Porthyrhyd, and in particular that the site at Wern Fraith continues to be accessible on foot and cycle to the locality’s community and public transport facilities.
2.3.2 The site at Wern Fraith lies within a 5-minute walking distance of Porthyrhyd’s two public houses, “The Abadam Arms” and “Prince of Wales”, together with the Spar convenience store, post office and “Y Neuadd Fach” community hall, equipped with children’s playground and sports field. All lie within the village centre at the junction with the Porthyrhyd to Nantgaredig Road. That road continues north to underpass the A48 trunk road en-route to the National Botanic Garden for Wales at Middleton Hall.
2.3.3 This section of B4310 Road lies upon a primary public bus route, with Services 129 and 166 running to Drefach, Tumble and Llanelli. Foelgastell, Cefneithin & Cross Hands to the east, and Llanddarog and Carmarthen to the north-west.
2.3.4 Ysgol Gyfen Maes-y-Gwendraeth is located a short road distance from Porthyrhyd via public and school transport.
2.3.5 National Cycle Route 47 – Llanelli to National Botanic Gardens – includes the section of the B road which passes the C road junction in Porthyrhyd.
2.3.6 Nearby Cross Hands provides a whole range of large food supermarkets, comparison shops and industrial estates, whilst Carmarthen town centre some 8 miles to the west provides a greater range of retail, employment and administrative facilities.
Alternative Site Supporting Statement March 2023
Land part of Wern Fraith Farm, Porthyrhyd Jones Bros. (Henllan) Ltd.

3.0 THE PROPOSAL
3.1 As part of the requirements for the promotion of sites for residential development, this Statement is accompanied by a fully engineered site layout for a potential residential scheme totalling 42 dwellinghouses and residential apartments that can be developed on the site. It demonstrates that the site is capable of accommodating this number in a deliverable and sustainable manner with single access point off the C class road, being only 90 metres west of its junction with the B4310 Drefach to Llanddarog Road.
Figure 8 below sets out the proposed site arrangement, which is subject to an application for full planning permission in 2023.
Figure 8 – Proposed Site layout plan
3.2 The new junction with be designed with 6.0 metres wide radii set back off a widened C2068 road carriageway, which will also be proposed to be provided with a new 2.0
Alternative Site Supporting Statement March 2023
Land part of Wern Fraith Farm, Porthyrhyd Jones Bros. (Henllan) Ltd.
metres wide footway across the entire northern flank of the minor road, linking to the existing pavement about the B road junction. The C Road will be widened to 5.5 metres, with the new site junction equipped with visibility splays in excess of National Standards, enabling motorists to have full sight of vehicles over 100 metres distance away at the road junction, and looking west past the Wern Fraith farmyard.
3.3 The lower part of the field, parallel with the roadside fence and hedge line is shown with the Natural Resources Wales’ Development Advice Map as susceptible to surface water flooding. Figure 9 below provides an extract from the DAM map and the area of water pooling is shown. Investigations at the site have revealed that excess water from the roadside drainage ditch is overbanking during inclement weather causing it to flow onto the agricultural field. When groundwaters recede the excess surface water returns to the ditch and flows away. The ditch is also connected to the road drainage system off the B410 road junction, which culverts into the ditch close to the adjoining property at Rhydyfro. The culvert has not been subject to regular maintenance, and thus causes the overtopping of the drainage ditch into the adjoining field. The proposed scheme seeks to relive such matters with a SAB-adoptable scheme to provide efficient attenuation measures, as shown in the engineering layout at Figure 10 overleaf. Attenuation basins will be formed to the foreground and part rear of the site, with new underground apparatus channelling surface water away to the north.
Figure 9 – NRW DAM Map for Porthyrhyd, illustrating extent of surface water ingression onto the site frontage
Alternative Site Supporting Statement March 2023
Land part of Wern Fraith Farm, Porthyrhyd Jones Bros. (Henllan) Ltd.
Figure 10 – Engineering proposals for site of 42 Residential Units
3.4 Infrastructure Considerations
Development of the Alternative Site for 42 residential units would be served by mains water, gas, public sewer and electricity connections, which lie within the respective stretch of public carriageway. Extensive pre-application consultation has taken place with Welsh Water, Wales & West Utilities and Western Power Distribution to confirm sufficient supply, and there are no local capacity difficulties reported in catering for the number of new units proposed at the site.
3.5 Ecological Considerations
The site has undergone through a Preliminary Ecological Appraisal, undertaken by Licenced Ecologists. No flora or fauna of national or regional important was discovered. The site has been investigated for evidence of any on-site or nearby habitats for protected species, and none have been discovered. The site is a well-managed parcel of semi-improved grassland from which the landowner has taken a silage cut every season. All perimeter trees can be retained and allowed to flourish.
Alternative Site Supporting Statement March 2023
Land part of Wern Fraith Farm, Porthyrhyd Jones Bros. (Henllan) Ltd.

4.0 DELIVERABILITY
4.1 In terms of deliverability, it should be firstly noted that the development of the site is financially viable. The site is subject to final completion by our clients from the presiding farm ownership. Jones Brothers (Henllan) Limited possess the financial capital to purchase the site, absorb the costs of securing full planning permission, and to construct and complete the entire development of 42 dwellinghouses and residential apartments. The scheme as presented will provide for 69% Affordable Housing, being over twice as required affordable provision. The scheme is being delivered in association with Pobl Group, with a total of 19 social rented and 10 low-cost home ownership dwellings and apartments will be provided across the site. The remaining 13 dwellinghouses will be privately sold. A financial contribution will also be made to Education Improvements in the locality of the site in accord with current adopted Supplementary Planning Guidance.
4.2 In terms of a delivery timescale, with Jones Bros. (Henllan) Limited’s ownership secured, it is envisaged that the site could be capable of being completed within two years from the award of full planning permission, which in accord with the Replacement Local Development Plan would be within years 6 and 7 (2024-25) of the Plan Period.
4.3 Porthyrhyd remains an attractive part of the semi-rural landscape set alongside the A48 trunk road corridor between Carmarthen and Cross Hands. It benefits from strong marketability as a result of that semi-rural location, and undoubted easy access to Carmarthen and Cross Hands by road, with nearby schools, shops, services and community facilities.
4.4 The presence of modern, detached houses located near the site is testament to this market need and the desire for home buyers to seek out such forms of high-quality residential development.
4.5 The deliverability of the site has been partly hampered through no fault of the landowners, nor prospective purchasers. A technical solution has had to be found to resolving the third-party blockage of the existing culvert under the B4310 highway, which has caused partial surface water flooding across a small section of the site’s roadside frontage. Extensive discussions with the Council’s Engineers, both within Highways and SAB Divisions, has resulted in a mutually acceptable solution being arrived at and presented for formal approval in newly prepared applications for planning permission and SAB Consent. Such successful conclusions have “unlocked” the immediate delivery of the site, and it can now be implemented subject to approval of those applications.
Alternative Site Supporting Statement March 2023
Land part of Wern Fraith Farm, Porthyrhyd Jones Bros. (Henllan) Ltd.

5.0 CONCLUSION
5.1 The Alternative Site consists of part of a grazing field set within a long frontage off a minor road, close to an established junction with the B4310 road at Porthyrhyd. Its formal allocation for residential development within the Carmarthenshire Local Development Plan (2008-21) is undisputed, and yet the site has not come forward until now with firm and comprehensive application proposals.
5.2 The Alternative Site forms a logical extension to the existing settlement, being well related to established residential development off its whole eastern and western perimeters, and further housing development to the opposite, southern flank of the minor road. The Site is capable of being accessed off the existing public road carriageway, which will be extensively widened and provided with a new footway where one is currently absent. The Alternative Site’s delivery will accordingly benefit all road users along this stretch of public highway, improving road safety.
5.3 The precise location is such that the strong defensible boundaries of boundary hedgerows and trees off the western perimeters provide a natural and part physical screen from views within the wider landscape. The development of the site would take place against the backdrop of residential properties to the immediate foreground. Accordingly, the development of the site would remain more akin in character to the built-up form of Porthyrhyd, than open pasture to the north and far west beyond the Wern Fraith farmyard.
5.4 In addition to the above, the site lies within close proximity and walking distance of the existing community services and local facilities of Porthyrhyd, particularly the post office and convenience shop, public houses and village hall and children’s playground. It is accessible by road in less than 10 minutes to the locality’s Primary and Secondary Schools. Therefore, in accord with National Planning Policy, the delivery of the Alternative Site will ensure it makes a positive contribution to both national and local sustainable development objectives.
5.5 With the Alternative Site having no access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints, its delivery if further allocated is assured. Combined therefore with its locational characteristics, the Site in question represents a sustainable candidate for future housing development.
5.6 In view of the above and information provided in this Statement, it is respectfully requested that the Alternative Site in question be allocated for a modest residential development.