Include site within the Plan.

This representation objects to the exclusion of this site from the development limits for Ystradowen. Its inclusion would not lead to additional environmental pressure, but instead will foster sustainable growth and allow for a wider choice of housing type within this Tier 3 Sustainable Village. The inclusion of this area of previously developed land would be in keeping and in character with the settlement and will ensure a deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints and its delivery is assured.
A full description of the site's development potential and merits has previously been provided in the candidate site submission, to which reference should be made.
It is considered that this site is both sustainable and deliverable and offers a valuable development option within this Tier 3 Sustainable Village.
The inclusion of this land within revised development limits would be fully supported.

Include site within the development limits for Betws, Ammanford and allocate for housing.

This representation objects to the exclusion of this site from the development
limits for Betws/Ammanford. Its inclusion would not lead to additional
environmental pressure, but instead will foster sustainable growth and allow
for a wider choice of housing type within this Tier 1 Principal Centre. Its
development would be in keeping and in character with the settlement and will
ensure a deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature
conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood
risk, hydrological, ecological, archaeological or land ownership related
constraints and its short term delivery is assured with necessary infrastructure
available.
A full description of the site's development potential and merits has previously
been provided in the candidate site submission, to which reference should be
made.
It is considered that this site is both more sustainable and readily deliverable
than those other larger sites that have been allocated within the locality
(PrC3/h6 and PrC3/h36). A separate objection in respect of these two sites has been submitted.
The inclusion of this land within revised development limits would be fully supported.

Amend Plan to include the site

This representation objects to the exclusion of this site from the development limits for Cwmgwili. Its inclusion would not lead to additional environmental pressure, but instead will foster sustainable growth and allow for a wider choice of housing type within this Tier 3 Sustainable Village. Its development would be in keeping and in character with the settlement and will ensure a deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints and its short term delivery is assured, in contrast to the long standing, yet undeveloped allocation, SuV28/h1.
A full description of the proposed site's development potential and merits has previously been provided in the candidate site submission, to which reference should be made.
It is considered that this site is both sustainable and deliverable and offers a valuable development option, and indeed alternative, within this Tier 3 Sustainable Village.
The inclusion of this land within revised development limits would be fully supported.

Include site in Plan.

This representation objects to the exclusion of this site from the development
limits for Tycroes/Ammanford. Its inclusion would not lead to additional
environmental pressure, but instead will foster sustainable growth and allow
for a wider choice of housing type within this Tier 1 Principal Centre. Its
development would be in keeping and in character with the settlement and will
ensure a deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature
conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood
risk, hydrological, ecological, archaeological or land ownership related
constraints and its short term delivery is assured.
A full description of the site's development potential and merits will be
provided at the appropriate stage.
It is considered that this site is both sustainable and readily.
The inclusion of this land within revised development limits should be fully supported.

Allocate site for housing in the Revised LDP.

Representation Proposal

The Applicants
The following brothers are the joint owners of the site requesting Inclusion in The 2nd Carmarthenshire Deposit Revised LDP 2018 – 2033:- M Adrian Evans, Derek D Evans, Anthony Neil Evans, Paul H Evans. I Neil Evans am the representative of our land for the purpose of this application. The site is formerly part of the previously family owned Pen Parc, which is located within the village of Llanfihangel Ar Arth, and I am “submitting a Representation requesting an Amendment of Allocation of Boundaries” and a “Proposal of Addition of a Site for the above rLDP Plan. Please see the end of this document for the complete Evidence Checklist.

1. Map / Plan of the site boundary:– See maps x 2 attached.

2. Site Reference:– AS/088/007, Representation No:- 4498

3. Name of site and Address:–

‘The Plot’ adjacent to Glyn Hebog and adjoining the playing field/Facilities, on the B4336, (formerly part of ‘Pen Parc’)
Llanfihangel Ar Arth
Carmarthenshire
SA39 9HU

4. Site area in hectares (ha):- Approximately 0.8 hectares


5. Proposed Use of The Site:-

• A much needed sustainably built, environmentally safe, small development with suitable parking and car charging points
• Low cost housing, attractively priced in the lower end housing market
• Low carbon, energy efficient, eco friendly properties
• Aimed at 1st and 2nd time buyers, starter homes, affordable rentals or for downsizing
• Family homes that blend into the setting of the village enjoying the amenities this site offers
• We would like the land to be developed during the medium term

These would be homes suitable for those who want to stay locally but may be forced away from the locality by the current costs of local housing. It is intended the small development will help prevent migration out of the area for those looking for reasonably priced homes, and will address the current lack of inexpensive housing in the vicinity for sale or rent.

• The site could be serviced via safe and appropriate access points.

• The site is viable i.e.

Dŵr Cymru have confirmed via e-mail that potential connections are available on 2 of the boundaries but now due to Phosphate, outline planning is needed regarding number of taps, bathrooms, etc to calculate capacity and attain permission for connection. And they confirmed that foul flows in this vicinity would drain to the Llanfihangel Ar Arth Waste Water Treatment Works which does not have a Phosphate permit yet.

Western Power had previously confirmed that potential connection was available and supplied a map showing the 11 kV power cables above the sited pole. However, now following a very helpful site meeting, we need to first get outline planning for confirmation of capasity, as it depends on factors like load required per property etc, – for confirmation of connection requirements. See Western Power grid map and email clarification. Advice has now been sought on these queries and outline planning with an architect.


• Superfast Full Fibre Broadband is available at this postcode now.


Site Location

Grid Reference SN 45608,39325. The site is located on the B4336 on a long, flat, straight, stretch of road between two crossroads, the left sided crossroad being the main throughway. Several route options are available to or from here within easy commutable distances, (i.e. for employment, retail, leisure and medical facilities etc, or e.g. alternate routes for adverse weather or diverted traffic:-

• The left crossroads leads directly to Pencader (B4459, 2.5 miles), then to the town of Carmarthen (A485, 13.8 miles).

• The B4336 goes directly to Llandysul (3.6 miles).

• Llandysul leads two main ways West to Newcastle Emlyn (8.3 and 9 miles), or East to Lampeter (13.3 miles) via main route.

• From the right crossroads is the nearby A485 and Llanllwni, Llanybydder and New Inn, with Carmarthen to the South and Lampeter to the North.

Therefore there is:- direct reasonable distance route accesses to amenities e.g.:-

1. Education – Meithrin/Primary, Secondary schools, Colleges and Universities.

2. Medical - Doctors Surgeries, Chemists, Hospitals (NHS and private), Dentists, etc.

3. Employment - Businesses, Local Government, Hywel Dda (NHS), Utility Services, etc

4. Retail - Shops, Towns, Shopping Centres, Garages, Fuel, etc.

5. Health – Leisure Centres, Swimming Pools, Parks, Gyms, Cycle Tracks/Paths, Footpaths, etc

6. Spiritual - Places of Worship, etc.

Consideration Has Been Given To The Following:

Unacceptable Ribbon Development - No - Not ribbon development -The site is a limited development area adjacent to the LDP boundary, next to the playing field, and is a parcel of land, restricted from being a sprawling development. It has historically been accepted as part of the village (formerly part of Pen Parc).

Unacceptable Tandem Development - No - Not possible - The crossroads being one edge of our boundary, Glyn Hebog the opposite end boundary and non related/owned land behind us contains and ensures our development will not sprawl or tandem.

Unacceptable Coalescence - No - Not possible - see tandem comment. Restricted development on all boundaries, utilising the last parcel of land which is sandwiched between Glyn Hebog and Pen Parc crossroads. It is within the village boundary.

Unacceptable Sporadic Development - No - Not sporadic, scattered or random - The site is a continuance from the main crossroads following to Glyn Hebog, which is adjacent to the LDP boundary and our site. It is ideally positioned in front of the playing field and adjoins the crossroads by Pen Parc. A development in this site would reflect the density of the surrounding area. It is also appropriate for the current climate, and addresses the lack of lower end housing, especially now more than ever.

Unacceptable Extension To The Settlement - No - Not an unacceptable extension because the site is central to the village and the development is justified:-

1) in being historically within the settlement (formerly being part of Pen Parc).
2) in being situated between and adjoining both Glyn Hebog and the village playing field.
3) in being a central parcel of land, restricted from sprawling out by existing property to the West, road
frontage B4336, a road to the East, with the playing field and land owned by others to the South. Therefore this would be a contained, suitable use of settlement land, no longer used for agriculture that can be utilised to ease the lack of lower priced housing in this part of Carmarthenshire.

4) because this area, including our site is already served by Public Infrastructure, such as:- water and
waste water, electricity and broadband, mobile phone signal. There is also street lighting and other utilities.

5) is within the village 30mph speed limit area with signage.
6) our site could provide the opportunity to connect the playing field to the Village more safely for the
Community, whilst providing much needed family homes.

7) in being within easy walking distance for public transport, leisure activities and local businesses.

Loss of Areas of Public Open Space and Formal Recreational Land: - No, this is private land and will not cause the loss of any public open space and formal recreational land.

The Outdoor Sports Facility, (PSD7), ‘The Playing Field, (See Map 1)

Regarding the playing field which is used widely by the local community, we hope this opportunity could provide and enhance safer access to the playing field, which is an Outdoor Sports Facility, (PSD7), for both present and future generations to enjoy.

This “will help children live healthier lifestyles” and also enhance social interaction. I.e. the playing field acts as a meeting arena for a diversity of fresh new families to integrate with the whole community via play and sport activity, which improves physical and mental health and also general well being in a refreshing open environment.

This site has an achievable goal for connecting, strengthening or accommodating both local housing, the village and the Tertiary Community. Also whilst doing so, via local education and social interaction etc the use of The Welsh Language will grow and strengthen.

The playing field entrance is serviced by up to 3 parking spaces located near the cross roads by Pen Parc. There is no footpath/pavement at all around the cross roads junction, nor along the B4336 which fronts our proposed land for Inclusion. Should Inclusion for our land be granted we would be happy to discuss options for the planning stage for the creation of a safer route for foot/cycle access to the playing field going through the development. Therefore providing local independent park users access without increasing vehicle usage. The village is serviced by buses for the further community to access these amenities. The playing field is already used for sports days and events and has a catering portacabin which the village hall - formerly the old school - makes use of.

We are requesting Inclusion in the Carmarthenshire 2nd Deposit Revised LDP re Ammendment to the Boundary for Housing Allocation and also Allocation of a New Site. If successful we would look to do an outline planning applicaton to achieve the above. We would endeavour then to sell the plot to a small to medium building company who will comply obviously with the Carmarthenshire 2nd Deposit Revised LDP 2018-2033, but importantly, who will care about and listen to the village locals and community and their housing needs especially, at the lower end of the market, not large detached houses. The building company could help bolster and energise and vitalise the existing playing field for the whole community. Seating is already in situ for relaxing parents and grandparents, and residents old and new. This would broaden opportunities for meeting people and making friends for all ages, using the facilities to encourage and strengthen, and in time, increase the use of The Welsh Language.


Please see our Supporting Evidence, Maps etc. The attachments are listed below:-


1) The Representation
2) ISA Assessment
3) Supporting Statement
4) Site Maps x 2 - Representation No:- 4498, Site No:- AS/088/007
5) Dŵr Cymru - 1 x Information request e-mail - 1 x Water Mains Map, 1 x Public Sewerage System Map,
6) Western Power - E-mail re Potential Connection & Confirmation – 1 x Grid map
7) Broadband Superfast Full Fibre already In Llanfihangel Ar Arth, SA39 9HU
8) Flooding Maps x 2,
9) Highway Issues - Collision Maps x 2
10) Bus Routes – Maps and Times Supplied for Public Use, the School Buses and Connections - no time table supplied.
11) Welsh Language – Graphs x 2
12) Teir 3, Cluster 4 Table and Cluster Map
13) Constraints Map
14) Green Spaces, Play Areas within reasonable distances x 4 maps
15) Agricultural Land Quality Map x 2

Amend Plan to include the site.

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:
• 2nd Deposit Revised LDP Representation Form
• Integrated Sustainability Appraisal
• Location & Site Plans
• Planning Statement
3 Client Details
3.1 The clients are Elfyn & Menna Thomas of Foxhole Farm, St Clears,
Carmarthen, SA33 4NE.
4 The Site
4.1 The site is an irregular shaped piece of land forming a field enclosure
immediately adjacent to the village of Rhydargaeau. The field in
question is currently used for grazing. The field fronts onto an
unclassified road and backs onto the rear curtilages of residential
dwellings along its southern and eastern boundaries.
4.2 Access to the site would be gained directly off the adjacent highway,
which comes off the A485 Trunk Road. The site is bounded by
mature hedgerows along the majority of its field boundaries.
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4.3 The site lies immediately west of a group of dwellings at the southern end of the village of Rhydargaeau. The location of the site and its proximity to the settlement of Rhydargaeau 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 immediately adjacent to a predominantly residential area within the settlement of Rhydargaeau. The proximity of the site to the southern part of the settlement is clearly shown on the aerial photograph below (Figure ii).
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Figure ii – Aerial Photograph
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 Rhydargaeau and the surrounding area.
5.2 The plan extract below (Figure iii) illustrates the scale of the site.
Figure iii
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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 well-being goals:
• 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
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improves the social, economic, environmental and cultural well-being 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) 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”.
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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 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.
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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 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 Rhydargaeau in the current Local Development Plan (LDP) is illustrated in the map extract below, Figure (iv).
Figure iv
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6.5 The proximity of the site to the defined settlement development limits for Rhydargaeau in the 2nd Deposit Revised Carmarthenshire Local Development Plan (LDP) is illustrated in the map extract below, Figure (v).
Figure v
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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 Rhydargaeau, which is identified as a Cluster 1, Tier 3 – Sustainable Village within the Settlement Framework, together with the fact that it is only 3 miles north of Carmarthen, ISA Objective 1 (Sustainable Development) is satisfied in this instance.
7.3 As illustrated on the plan below (Figure vi), the site is directly related to the identified settlement of Rhydargaeau, therefore, represents a sustainable location.
7.4 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).
Figure vi – Location Plan
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7.5 TAN15 states that new development should be directed away from Zone C and towards zone A, otherwise to zone B, where river or 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.
7.6 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
7.7 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).
The Site
The Site
The Site
Figure viii - FMfP
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7.8 The Flood Risk Map demonstrates that 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.
7.9 The site does not fall within a C1 or C2 flood risk zone as delineated by TAN15 DAM flood maps. A section of the eastern boundary does fall within a Flood Zone 2/Flood Zone 3 as delineated by FMfP (Flood Map for Planning Wales). As such, ISA Objective 4 (Climatic Factors) and ISA Objective 5 (Water) is not entirely satisfied in this instance.
7.10 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.
7.11 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.
7.12 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 to existing residential dwellings and also in close proximity to the edge of the existing settlement. The previous map extracts clearly illustrate the existing pattern of development at this part of the village, and the proximity of the site to the existing built form
7.13 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.
7.14 In addition it would not result in the loss of areas of public open space and formal recreational land. Given the aforementioned, it is
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asserted that the development would not be contrary to general planning principles.
7.15 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.
7.16 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 unclassified road. As such, the site is readily accessible from the existing public highway. The site has an existing and established field entrances with adequate visibility splays, which allows direct access into the site.
7.17 The adjacent highway is a relatively quiet road which primarily serves Trallwn Farm and 8-9 residential properties. The junction onto the A485 is served by adequate visibility splays.
7.18 The map below (Figure ix) illustrates the number of crashes in the immediate vicinity of the site.
Figure ix (Source:Crashmap.co.uk)
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7.19 Data obtained from Crashmap.co.uk confirms that in the last 10 years, there have been no slight, serious or fatal crash incidents along the adjacent highway or at the A485 road junction. This would suggest that there are no highway issues relating to the site or the public road(s) which serve the site.
7.20 The site lies in close proximity to National Cycle Network Route 47, which is approximately 3km away. This is illustrated on the Sustrans National Cycle Network Map extract below (Figure x).
Figure x (Source Sustrans)
7.22 In addition, the site is readily accessible to a local bus services (Route No. T1A) with the nearest bus stop less than a 2 minute walk away. The bus journey to Carmarthen takes approximately 20 minutes.
7.23 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).
7.24 Given its location within a field enclosure, the site lies immediately adjacent to an accessible green space. As such, it is considered the
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site satisfies ISA Objective 12 (Health & Well-being) and ISA Objective 15 (Social Fabric) .
7.25 The site is within a reasonable walking distance of Rhydargaeau which does have a range of employment/retail provisions, services and facilities. Other provisions, services and facilities can be found in the nearby village of Peniel, which is a reasonable distance away, Whilst the site clearly occupies a rural location, it represents a very sustainable location given its close proximity to the aforementioned settlements.
7.26 It is considered the site is within a reasonable distance of a number of employment and retail provisions as well as other services and facilities, given its proximity to the town of Carmarthen. As such, the site satisfies the following ISA Objectives; ISA 6 (Material Assets), ISA 10 (Population), ISA 14 (Economy), ISA 15 (Social Fabric).
7.27 The site represents a sustainable location in terms of its proximity to nearby nursery schools. The site is also within a reasonable distance of Bro Myrddin and Queen Elizabeth Secondary Schools (5km) and Peniel Primary School (0.5km). As such, ISA Objective 13 (Education & Skills) is satisfied in this instance.
7.28 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 (Sand & Gravel Safeguarding Area Category 1), 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.
7.29 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.
7.30 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.
7.31 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.
7.32 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).
7.33 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.
7.34 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.
7.35 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.
7.36 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.
7.37 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.
7.38 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.
7.39 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.
7.40 Overall, the proposed development would satisfy PPW’s objective of achieving sustainable development both by ensuring that the 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 Elfyn & Menna Thomas and provides planning support for the inclusion of additional land in the revised Local Development Plan to accommodate potential residential development adjacent to Rhydargaeau.
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 the site as a housing allocation within the Plan.

This representation objects to the exclusion of this site from the development limits for Ffarmers. Its inclusion would not lead to additional environmental pressure, but instead will foster sustainable growth and allow for a wider choice of housing type within this Tier 3 Sustainable Village. Its development would be in keeping and in character with the settlement, providing a natural ‘rounding off’ opportunity at this central village location, and will ensure a deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints and its short term delivery is assured.
A full description of the proposed site's development potential and merits has previously been provided in the candidate site submission, to which reference should be made.
It is considered that this site is both sustainable and deliverable and offers a valuable development opportunity within this Tier 3 Sustainable Village, and indeed where no other allocation is proposed.
The inclusion of this land within revised development limits would be fully supported.

Include the site as a housing allocation.

This representation objects to the exclusion of this site from the development limits for Ammanford. Its inclusion would not lead to additional environmental pressure, but instead will provide the opportunity for an attractive, appropriate development, thereby fostering sustainable growth and allowing a wider choice of housing type within this Tier 1 Principal Centre. Its development would be in keeping and in character with the settlement and will ensure a deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints and its delivery is assured.
A full description of the site's development potential and merits has previously been provided in the candidate site submission, to which reference should be made.
It is considered that this site is both sustainable and deliverable and offers a valuable development option within this Tier 1 Principal Centre.
The inclusion of this land within revised development limits would be fully supported.

Include the site as a Resdential allocation within the Plan.

This representation objects to the exclusion of this site from the development limits for Cross Hands. Its inclusion would not lead to additional environmental pressure, but instead will foster sustainable growth and allow for a wider choice of housing type within this Tier 1 Principal Centre. Its development would be in keeping and in character with the settlement and will ensure a readily deliverable source of future housing for this sustainable community.
The proposed site offers a valuable development option in this part of Cross Hands, where no other allocations have been proposed. The site also bears close resemblance to allocation PrC3/h8 in its form and context and which is deemed an acceptable residential development opportunity.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints and its delivery is assured.
A full description of the site's development potential and merits has previously been provided in the candidate site submission, to which reference should be made.
It is considered that this site is both more sustainable and readily deliverable than other sites that have been allocated within Cross Hands.
The inclusion of this land within revised development limits would be fully supported.
Ticiwch

Amend Plan to include the site

Please see Supporting Statement. The vast majority of the site is allocated for residential development (Ref: SC16/h1) in the current LDP, with a non committal allocation for 10 dwellings. Efforts have been made to deliver this allocation, with this portion of the site having gained outline planning permission for the erection of 13 dwellings and associated infrastructure work (Ref: PL/00629), and a planning application was submitted in March 2023 concerning full planning permission for the construction of an access road in order to serve those dwellings (Ref: PL/05573). This proves that an attempt has been made to deliver the only housing allocation in the current LDP for Llanybri, therefore there is no logical reason for it`s removal within the deposit plan. It is the applicant’s intention to bring the site forward via the submission of reserved matters for the housing itself in the near future. The candidate site to the immediate south of the housing allocation is a natural extension of this. At present, this portion of the land contains old agricultural structures that are now in a state of disrepair.

Supporting statement (not including appendices):

1 Introduction
1.1 This supporting statement document for the Second Deposit Revised Local Development Plan for Carmarthenshire has been prepared in relation to an existing LDP allocation (SC16/h1 land adjacent to Parc Y Delyn) and adjacent candidate site (SR/108/001 land at Maes Y Meillion) in Llanybri, Carmarthenshire (E: 233989, N: 212783). It is submitted on behalf of Mr David Rhodri Davies.
1.2 The existing LDP allocation (SC16/h1) reproduced in Appendix 1 is proposed to be de-allocated. The reason specified in the Site Assessment Table is “the site has been allocated since the UDP without any indication of delivery”. It will be shown in this statement that an Outline Planning application for 13 dwellings was registered on the 20th October, 2020 and subsequently approved by the LPA on the 5th August, 2022 under planning reference PL/00629. The applicant has also subsequently submitted a full planning application for the access in order to bring forward such facilitating works and this has been registered by the LPA and pending determination under planning reference PL/05573. The above show a clear intent by the landowner to bring forward this existing housing allocation, and thus it should not be de-allocated.
1.3 The southern part of the site was previously submitted as a candidate site in 2018 in Appendix 2 (Ref: SR/108/001), but this has not been included within the Deposit Plan. The reason specified in the Site Assessment table is “site access taken through existing housing allocation which is to be taken out. Therefore this is not taken forward”. The reason is specific to the access aspect through the existing housing allocation, which should be retained as a housing allocation for the reasons mentioned above. The housing layout and access design is such that it facilitates the delivery of candidate site SR/108/001. The candidate site at present contains old agricultural buildings that are now in a state of disrepair.
1.4 In summary, this submission concerns the entire Maes y Meillion site including both the existing LDP allocation (SC16/h1) and adjacent candidate site (SR/108/001), and the applicant wishes for them to be brought within the settlement limits of Llanybri in order to comply with LDP Policy SD1 (Development Limits), along with being included as a housing allocation in order to accord with Policy HOM1 (Housing Allocation).
1.5 The site is situated in the village of Llanybri, lying to the north west of Llansteffan and situated south of Llangynnog. The site lies roughly 8.5 miles away from Carmarthen town centre where there are a host of amenities and services including supermarkets, a university and leisure centre.
1.6 This submission will demonstrate that the overall site in question, both the existing housing allocation (SC16/h1) and candidate site (SR/108/001) ought to be included within the settlement boundary of Llanybri in the Deposit LDP. Efforts have been made to deliver the existing allocation, with this portion of the site having gained outline planning permission for the erection of 13 dwellings and associated infrastructure work (Ref: PL/00629), and a planning application was submitted in March 2023 concerning full planning permission for the construction of an access road in order to serve those dwellings (Ref: PL/05573). This proves that an attempt has been made to deliver the only housing allocation in the current LDP for Llanybri, therefore there is no logical reason for its removal within the deposit plan. It is the applicant’s intention to bring the site forward via the submission of reserved matters for the housing itself in the near future. The candidate site SR/108/001 is a logical extension of this existing housing allocation and will be accessed through it. Appendix 3 and 4 provide copies of the outline layout plan
and approval respectively, whilst Appendix 5 and 6 provide copies of the proposed access plan and registration document.
1.7 In terms of the content of the submission Section 2 of this report provides a brief description of the site; Section 3 discusses the overall planning policy context; Section 4 assesses the site in the context of criteria identified in Planning Policy Wales. Section 5 provides a summary and conclusions.
2 Site Description
2.1 This section discusses the site’s general location and provides a brief description of the application site and its immediate surroundings.
2.2 Llanybri is categorised as a Tier 3 sustainable village situated in the unitary authority of Carmarthenshire. It is located approximately 8.5 miles to the south west of the county town of Carmarthen and approximately 6.5 miles to the south east of St Clears. The highway that runs to the northwest of the site has a 30mph speed limit on entry to the village.
2.3 The majority of the entire site comprises agricultural grazing land, along with the farm holding of Maes Y Meillion. Access to the farm itself can be gained from the county road to the north via the concreted farm road on the eastern side, leading onto a hard-standing area in the south-eastern corner. There is a small agricultural building, which is now redundant and partially collapsed, in this corner of the field. Agricultural grassland and hedgerow forms the north eastern and north western boundaries. The north east of the site is bound by an access track associated with Maes Y Meillion and to the south east by Maes Y Meillion grounds within the ownership of the applicant. The south western boundary is formed by the curtilage of properties within Parc Y Delyn whereas the north western boundary is formed by the main highway running through Llanybri. Lying to the south of the site is an off-road track and children`s play area.
2.4 The village of Llanybri contains few services and facilities. Those located within the village includes places of worship and a public house. Llansteffan located nearby the site contains a few more facilities including Llansteffan primary school, a convenience shop and amenities associated with the coastal location, place of worship and community hall. The nearest service centre to the site is St. Clears which features a wider range of services and facilities including:
• Surgery;
• Ysgol Griffith Jones (Primary);
• St. Clears Leisure Centre;
• Supermarket;
• Convenience Shops; and
• Takeaways
2.5 The site can be reached via the B4312 from Carmarthen, that passes through Llangain, whereas those travelling from a westerly/northerly direction will cross the busy A40 dual carriageway near Bancyfelin and head along a country lane that leads to the centre of Llanybri. The road situated to the northwest of the site currently has a 30mph speed limit as users enter the village of Llanybri. The nearest national cycle route is route no.4 which is a long distance course between London and Fishguard. The nearest point of access for potential users is by Gul Wales: Littlemoor, approximately three miles from the site. Ger y Marbell bus stop is a short walk from the site and is serviced by the 227 bus. This service commences at Ger y Marbell and terminates at Carmarthen, with 6 services heading in that direction, and another six terminating at Ger y Marbell from Carmarthen on the return journey. In terms of trains, the nearest station is in Carmarthen town centre, nine miles away. The station is situated on the West Wales Line and is predominantly served by Transport for Wales who run services to destinations further west, along with journeys to Swansea, Cardiff Central and Manchester Piccadilly. In addition to this, Great Western Railway operate one service daily to London in both directions, and additional services are provided by the operator on Sundays.
2.6 In terms of ecology, a Preliminary Ecological Appraisal was conducted in July 2020 at the site to accompany outline application PL/00629. As it was conducted over two years ago, an updated appraisal of the site was required to accompany the full application for the access. Consequently, Habitat Matters conducted an Ecological Appraisal of the site during December 2022. The Preliminary Ecological summarised that “The site conditions remain unchanged from the July 2020 proposal apart from the derelict building which has now lost all sections of the roof. The recommendations for ecological mitigation and enhancement remain as before”. A section of hedge requires removal to facilitate the proposed access and will be translocated as shown in Appendix 7. In terms of ecological enhancements, the report suggests that these will be delivered as part of the wider residential development, comprising of suitable landscape planting and bird/bat boxes.
2.7 Intrado were instructed to produce a drainage strategy for the access proposal that is provided in Appendix 8. The engineering layout highlights how drainage aspects have been incorporated into the construction of the access road. These include:
1. 2.75m minimum width (half of highway) to be constructed from permeable asphalt to be lined with permeable geotextile membrane to facilitate infiltration to groundwater network below;
2. Kerb drainage to be installed at low point in highway to drain surface water runoff to infiltration basin during storm events in excess of 1:100yr to avoid highway flooding; and
3. ACO swale inlet (or similar approved product) to be installed in infiltration basin.
In addition to this, the Kerbing Layout notes that the kerb drainage will be implemented at a low point of the highway in order to convey runoff to bioretention section during an extreme storm occurrence greater than 1:100 years. The access and subsequent housing will be subject of separate SAB approval also.
3 Comments on Planning Policy
3.1 Paragraph 9.3 of the Revised Draft LDP correctly recognises the role that smaller settlements within Carmarthenshire have in delivering local and sustainable growth. This is further expanded upon in Paragraph 9.16 which again correctly recognises that by supporting growth of a proportionate scale in such areas, a positive contribution can be made towards the long term sustainability and cohesiveness of rural communities and the rural economy.
3.2 It is clear that there is a reliance on larger sites within rural areas which can be difficult to deliver. Due to issues around deliverability, this has impacted the resilience of housing land supply, with these larger sites not delivering the dwellings promised. A different approach is warranted in certain areas of Carmarthenshire, with a large proportion of the County being rural in nature. Within Tier 3 settlements (Sustainable Villages), sites that are small in scale but are easily deliverable ought to be favoured as they will be able to meet the housing need in an easy manner whilst not hampering the character of the area.
3.3 The Moving Rural Carmarthenshire Forward Report conducted in 2019 stated that in order to make rural areas attractive for younger people adequate housing needed to be provided to ensure that they could remain within their local communities. The report stated that a shift was required from depending on large housing developments to focusing more on smaller scale residential developments that would address housing requirements in rural settlements. A survey produced during the report revealed only 15% of respondents were happy with the housing provided within their rural area.
3.4 It is imperative that a sustainable and proportionate amount of housing growth is allowed in rural areas of Carmarthenshire during the plan period. The lack of such housing at present has unfortunately resulted in younger individuals departing rural areas, looking for housing and work in urban areas which is having a detrimental impact upon the resilience of rural areas
3.5 In terms of policy within the deposit LDP, the two key policies are SD1 (Development Limits) and HOM1 (Housing Allocations). In terms of Policy SD1, the site discussed in this statement ought to be included within the settlement boundary of Llanybri as it would represent a natural extension of the settlement. There is no logical reason for moving the site outside settlement limits within the deposit plan, as the site currently lies within limits and efforts have been made to develop the site, with two planning applications having recently been submitted, with the outline approved confirming acceptance of housing on the site
in principle. The candidate site to the south of the existing housing allocation is a logical extension of this and can be delivered via the facilitating infrastructure being developed for the existing housing allocation. The candidate site element includes old agricultural buildings, many of which are now in a state of disrepair.
3.6 In respect of Policy HOM1, there is proof that the site will be delivered as the site has gained outline planning permission for 13 dwellings and associated works, and a full application has recently been submitted for the access works. Welsh Government advice is to remove sites which have proved to be undeliverable, however this is not the case in respect of this land. The land owner is keen to progress development of the site with the submission of reserved matters for the housing itself in the near future. Furthermore, as a result of pulling the site out as a housing allocation within the deposit plan, Llanybri does not have any sites allocated for residential development. Retaining the existing housing allocation and including the logical extension to it will address this deficiency.
3.7 Having considered the last two paragraphs, there is no logical reason for altering the settlement limit of Llanybri, as this reduces opportunity for residential development and sustainable growth within a sustainable village. Furthermore, there is no reason for it to be removed as a housing allocation as there is intent to develop the site as illustrated by the submission of recent applications. Within the current plan, the site accords with LDP policy, and nothing suggests that the site could not do this when it comes to the deposit plan, were it to lie within settlement limits and be allocated for residential development. The candidate site to the south of the existing housing allocation is a logical extension to it and can be facilitated via the access being proposed.
4 Appraisal
4.1 This section examines the characteristics and features of the site in question.
Availability of Previously Developed Land
4.2 The site is not brownfield land but is well-connected to the current settlement pattern of Llanybri and its development for residential purposes represents a logical area for development and inclusion within the settlement boundary, at this location. Lying west is the Parc Y Delyn residential development which has a similar number of residential dwellings to what has gained outline planning permission at the Maes Y Meillion site, along with a comparable layout. Several services and facilities are available in the nearby towns of St Clears and Carmarthen that are a short drive away from the site.
4.3 In order to achieve a sufficient range and choice of housing land opportunities, there will be a need to consider sites which help achieve resilience in rural settings, with this site capable of being delivered in the short to medium term. The existing housing allocation element of the site can offer up to 13 residential units as illustrated in Appendix 3, whilst a few more can be delivered on the candidate site to the south. This will make a positive contribution to housing land supply,
Accessibility
4.4 Although the land consists of undeveloped agricultural grazing land which does not benefit from formal access, the site can be entered via the wider Maes Y Meillion grounds. The proposed access application submitted in March 2023 to the LPA will lie thirty yards south west of the current access. This development will offer access to a highway that runs centrally to the site with the 13 properties situated on either side as shown in Appendix 5. It will provide access to the parking areas, along with a turning head to enable vehicles to enter and leave the site in a forward gear. A section of hedge requires removal to facilitate the proposed access and will be translocated, whereas ecological enhancements as part of the proposed access will comprise suitable landscape planting and bird/bat boxes.
4.5 In terms of facilities, these are limited to a public house, chapel and playground within Llanybri. A range of services and facilities are provided in nearby Carmarthen, that can be reached via a bus service that calls at the nearby Ger Y Marbell bus stop. In terms of trains, the nearest station lies in Carmarthen, where services run to several destinations across south Wales, along with Manchester Piccadilly and London Paddington. The nearest cycle route is no 4 which is a long-distance route between London and Fishguard running via Reading, Bristol, Swansea, Tenby and St. Davids.
4.6 It is evident that drivers travel along the main road running through the village in a sensible manner as residents have to walk along the side of the road due to no footway being constructed. Such an arrangement is not uncommon in rural settlements of Carmarthenshire and underlines that the development is occurring within a pedestrian safe environment.
Land Ownership
4.7 The land to which this submission refers is within the joint-ownership of the Site Promoter – Mr David Rhodri Davies. The landowner is fully committed to bringing forward the development of the site.
Capacity of Infrastructure
Utilities
4.8 All utilities are readily available within the proximity of the site. 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
4.9 The site is not affected by a flood risk area (which would prevent vulnerable forms of development such as housing), and it is considered that foul water will connect with the existing mains sewer. Drainage aspects have been clearly incorporated into the proposed access, with further detail provided in Appendix 8.
Access
4.10 Achieving sufficient widths and visibility at the site’s proposed access point will be achieved, with some of the hedge at the northern end of the site translocated. The development will provide the necessary pedestrian and cyclist infrastructure within the site to encourage residents to walk and cycle, with 2m wide footways included on both sides of the carriageway, and a potential path may be built in future in order to connect the site with the playground that lies south of the site. A S.106 completed in relation to the outline permission also secured a £25,000 contribution towards improving pedestrian facilities in the village of Llanybri.
Impact on the Community/Welsh Language
4.11 It is not considered that the development of the site for housing will have any significant adverse impact upon the Welsh language or any local communities. The nearest primary school is situated in Llansteffan, which is a Welsh medium school therefore enabling development of the site could increase the number of Welsh speakers in the village. A S.106 was completed in relation to the outline which secured 30% affordable housing and a financial contribution towards local education facilities.
Physical and Environmental Constraints
Ecology
4.12 The Preliminary Ecological Appraisal in Appendix 7 summarised that appropriate ecological enhancements will be provided a part of the access application, and the hedge removed to facilitate the access will be translocated.
Visual Impact
4.13 Overall it is considered that the proposal would not have any significant adverse impact upon the visual amenities of the area. Separation distances, to prevent any adverse or overbearing impacts, between proposed dwellings and existing dwellings can easily be provided.
Coalescence of settlements
4.14 Development on the site would not result in the coalescence of settlements. Development of the site would result in the retention of the existing housing allocation in Llanybri and a marginal extension of Llanybri`s development limits within the deposit plan, which makes sense considering a similar scale residential development lies west of the site. Furthermore, part of the site currently lies within settlement limits, and is allocated for residential development within the adopted plan. It has been proven in this submission that the existing allocation is deliverable with progress already made at significant expense to
the applicant by successfully obtaining outline planning permission and submitting a full application to bring forward access facilitating works.
Flood Risk
4.15 The site is not identified in the TAN 15 Development Advice Maps as being at risk from flooding.
Site Contamination
4.16 In terms of ground conditions there are no known constraints that prevent the development of the site for residential uses.
Compatibility with Neighbouring Uses
4.17 It is anticipated that all of the proposed dwellings would respond well to the established character of the surrounding area. It is anticipated that a range of dwelling types and sizes, including 30% affordable dwellings would be incorporated ranging from 2 beds up to 4 beds which forms the basis for interesting street scenes and helps establish a balanced community. Overall it is considered that the proposal would not have any significant adverse impact upon the residential amenities of existing or future occupiers.
The Potential to reduce carbon emissions through co-location with other uses
4.18 The site is proposed for residential uses. However, increasing Llanybri`s population will allow help sustain local facilities and potentially increase demand for additional services to benefit the village.
Relationship with Historic Environment
4.19 The site is not located within or adjacent to the boundary of a Conservation Area. The closest feature of historic importance is Scheduled Ancient Monument Yr Hen Gapel which sits together with Grade II
listed Tower of Yr Hen Gapel. These are situated within the village of Llanybri, roughly 0.4 kilometres to the south west of the development site.
Delivery of Key Placemaking Objectives
4.20 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 site can provide homes in the right place and create a sustainable, well-designed, and high-quality housing scheme, where people will want to live, in accordance with national placemaking objectives.
Conclusion
5.1 This site representation is made by Asbri Planning Limited on behalf of Mr David Rhodri Davies. It in respect of the land at Maes Y Meillion, Llanybri which should be reinstated within the development limits of the village, as well as being included as a housing allocation as part of the Carmarthenshire County Council Second Deposit Revised Local Development Plan 2018 - 2033.
5.2 The extension of the settlement limit of Llanybri, and reintroduction of Maes y Meillion as a housing allocation for the Tier 3 settlement can ensure that a proportional amount of housing growth will be delivered across the plan period. Across the plan period it is highly unlikely that any other sites will come forward in the settlement, therefore it is essential that this site is reconsidered as part of the deposit plan, and as previously mentioned, the site is within limits and allocated for residential development in the current plan. The candidate site to the south is a logical extension of the existing housing allocation, with it currently including agricultural structures that are in a dilapidated state.
5.3 Whilst the soundness of the Plan is not challenged objections are made to the following policies within the deposit plan:
a) Object to SD1 (Development Limits) – the site shown in Appendix A ought to be reinstated within the settlement limits of Llanybri. Within the adopted plan, the site is within limits however it has been placed outside limits in the deposit plan. There is no justification for it`s removal, and allowing development at the land in Maes y Meillion enables a natural extension of the settlement. Lying west of the site is the Parc Y Delyn residential development which has a similar amount of residential dwellings to what has gained outline planning permission at the Maes Y Meillion site, along with a similar layout. The previous candidate site shown in Appendix B should also be included within the settlement limit as it is a natural extension of the existing housing allocation and can be facilitated by infrastructure developed as part of the current site that benefits from outline planning permission.
b) Object to HOM1 (Housing Allocation) – the Maes y Meillion housing allocation is not included within the deposit plan, although the site has been allocated for 10 dwellings within the adopted plan. The site layout in Appendix 3 shows 13 dwellings will be delivered in total. There is no reason for removing the site as an allocation, and it has gained outline planning permission for the erection of 13 dwellings and associated infrastructure work (Ref: PL/00629), and a subsequent planning application was submitted in March 2023 concerning full planning permission for the construction of an access road in order to serve those dwellings. The applicant is keen to progress with the reserved matters for the site shortly, therefore this would be considered a deliverable allocation were it to be included in the deposit plan. It is critical that this housing allocation is reinstated into the deposit plan as at present, no housing allocations are proposed for Llanybri, and there are limited opportunities for residential development in other parts of the settlement. The candidate site aspect as shown in Appendix B is a natural extension of this and should also be included.
5.4 Extending the development limit to incorporate this site would promote sustainable growth in a way that takes into consideration the nature of the current settlement. There needs to be an opportunity for some proportional housing growth within this tier 3 settlement that can be facilitated over the plan period until 2033. The site could potentially deliver 13-20 dwellings 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 suitable contribution to the area’s housing land supply. In addition to this, it is located in a sustainable area where some amenities can be accessed on foot, and nearby Carmarthen can be accessed via a bus service that runs nearby. It is also considered acceptable in terms of drainage and ecological aspects.
5.5 In summary, it is considered that Carmarthenshire County Council should, in its review of the Local Development Plan, include the site within the settlement boundary of Llanybri, and include the Maes y Meillion site as a housing allocation within the deposit plan.

Amend Plan to include the site

Please see Supporting Statement. The vast majority of the site is allocated for residential development (Ref: SC16/h1) in the current LDP, with a non committal allocation for 10 dwellings. Efforts have been made to deliver this allocation, with this portion of the site having gained outline planning permission for the erection of 13 dwellings and associated infrastructure work (Ref: PL/00629), and a planning application was submitted in March 2023 concerning full planning permission for the construction of an access road in order to serve those dwellings (Ref: PL/05573). This proves that an attempt has been made to deliver the only housing allocation in the current LDP for Llanybri, therefore there is no logical reason for it`s removal within the deposit plan. It is the applicant’s intention to bring the site forward via the submission of reserved matters for the housing itself in the near future. The candidate site to the immediate south of the housing allocation is a natural extension of this. At present, this portion of the land contains old agricultural structures that are now in a state of disrepair.

Supporting statement (not including appendices):

1 Introduction
1.1 This supporting statement document for the Second Deposit Revised Local Development Plan for Carmarthenshire has been prepared in relation to an existing LDP allocation (SC16/h1 land adjacent to Parc Y Delyn) and adjacent candidate site (SR/108/001 land at Maes Y Meillion) in Llanybri, Carmarthenshire (E: 233989, N: 212783). It is submitted on behalf of Mr David Rhodri Davies.
1.2 The existing LDP allocation (SC16/h1) reproduced in Appendix 1 is proposed to be de-allocated. The reason specified in the Site Assessment Table is “the site has been allocated since the UDP without any indication of delivery”. It will be shown in this statement that an Outline Planning application for 13 dwellings was registered on the 20th October, 2020 and subsequently approved by the LPA on the 5th August, 2022 under planning reference PL/00629. The applicant has also subsequently submitted a full planning application for the access in order to bring forward such facilitating works and this has been registered by the LPA and pending determination under planning reference PL/05573. The above show a clear intent by the landowner to bring forward this existing housing allocation, and thus it should not be de-allocated.
1.3 The southern part of the site was previously submitted as a candidate site in 2018 in Appendix 2 (Ref: SR/108/001), but this has not been included within the Deposit Plan. The reason specified in the Site Assessment table is “site access taken through existing housing allocation which is to be taken out. Therefore this is not taken forward”. The reason is specific to the access aspect through the existing housing allocation, which should be retained as a housing allocation for the reasons mentioned above. The housing layout and access design is such that it facilitates the delivery of candidate site SR/108/001. The candidate site at present contains old agricultural buildings that are now in a state of disrepair.
1.4 In summary, this submission concerns the entire Maes y Meillion site including both the existing LDP allocation (SC16/h1) and adjacent candidate site (SR/108/001), and the applicant wishes for them to be brought within the settlement limits of Llanybri in order to comply with LDP Policy SD1 (Development Limits), along with being included as a housing allocation in order to accord with Policy HOM1 (Housing Allocation).
1.5 The site is situated in the village of Llanybri, lying to the north west of Llansteffan and situated south of Llangynnog. The site lies roughly 8.5 miles away from Carmarthen town centre where there are a host of amenities and services including supermarkets, a university and leisure centre.
1.6 This submission will demonstrate that the overall site in question, both the existing housing allocation (SC16/h1) and candidate site (SR/108/001) ought to be included within the settlement boundary of Llanybri in the Deposit LDP. Efforts have been made to deliver the existing allocation, with this portion of the site having gained outline planning permission for the erection of 13 dwellings and associated infrastructure work (Ref: PL/00629), and a planning application was submitted in March 2023 concerning full planning permission for the construction of an access road in order to serve those dwellings (Ref: PL/05573). This proves that an attempt has been made to deliver the only housing allocation in the current LDP for Llanybri, therefore there is no logical reason for its removal within the deposit plan. It is the applicant’s intention to bring the site forward via the submission of reserved matters for the housing itself in the near future. The candidate site SR/108/001 is a logical extension of this existing housing allocation and will be accessed through it. Appendix 3 and 4 provide copies of the outline layout plan
and approval respectively, whilst Appendix 5 and 6 provide copies of the proposed access plan and registration document.
1.7 In terms of the content of the submission Section 2 of this report provides a brief description of the site; Section 3 discusses the overall planning policy context; Section 4 assesses the site in the context of criteria identified in Planning Policy Wales. Section 5 provides a summary and conclusions.
2 Site Description
2.1 This section discusses the site’s general location and provides a brief description of the application site and its immediate surroundings.
2.2 Llanybri is categorised as a Tier 3 sustainable village situated in the unitary authority of Carmarthenshire. It is located approximately 8.5 miles to the south west of the county town of Carmarthen and approximately 6.5 miles to the south east of St Clears. The highway that runs to the northwest of the site has a 30mph speed limit on entry to the village.
2.3 The majority of the entire site comprises agricultural grazing land, along with the farm holding of Maes Y Meillion. Access to the farm itself can be gained from the county road to the north via the concreted farm road on the eastern side, leading onto a hard-standing area in the south-eastern corner. There is a small agricultural building, which is now redundant and partially collapsed, in this corner of the field. Agricultural grassland and hedgerow forms the north eastern and north western boundaries. The north east of the site is bound by an access track associated with Maes Y Meillion and to the south east by Maes Y Meillion grounds within the ownership of the applicant. The south western boundary is formed by the curtilage of properties within Parc Y Delyn whereas the north western boundary is formed by the main highway running through Llanybri. Lying to the south of the site is an off-road track and children`s play area.
2.4 The village of Llanybri contains few services and facilities. Those located within the village includes places of worship and a public house. Llansteffan located nearby the site contains a few more facilities including Llansteffan primary school, a convenience shop and amenities associated with the coastal location, place of worship and community hall. The nearest service centre to the site is St. Clears which features a wider range of services and facilities including:
• Surgery;
• Ysgol Griffith Jones (Primary);
• St. Clears Leisure Centre;
• Supermarket;
• Convenience Shops; and
• Takeaways
2.5 The site can be reached via the B4312 from Carmarthen, that passes through Llangain, whereas those travelling from a westerly/northerly direction will cross the busy A40 dual carriageway near Bancyfelin and head along a country lane that leads to the centre of Llanybri. The road situated to the northwest of the site currently has a 30mph speed limit as users enter the village of Llanybri. The nearest national cycle route is route no.4 which is a long distance course between London and Fishguard. The nearest point of access for potential users is by Gul Wales: Littlemoor, approximately three miles from the site. Ger y Marbell bus stop is a short walk from the site and is serviced by the 227 bus. This service commences at Ger y Marbell and terminates at Carmarthen, with 6 services heading in that direction, and another six terminating at Ger y Marbell from Carmarthen on the return journey. In terms of trains, the nearest station is in Carmarthen town centre, nine miles away. The station is situated on the West Wales Line and is predominantly served by Transport for Wales who run services to destinations further west, along with journeys to Swansea, Cardiff Central and Manchester Piccadilly. In addition to this, Great Western Railway operate one service daily to London in both directions, and additional services are provided by the operator on Sundays.
2.6 In terms of ecology, a Preliminary Ecological Appraisal was conducted in July 2020 at the site to accompany outline application PL/00629. As it was conducted over two years ago, an updated appraisal of the site was required to accompany the full application for the access. Consequently, Habitat Matters conducted an Ecological Appraisal of the site during December 2022. The Preliminary Ecological summarised that “The site conditions remain unchanged from the July 2020 proposal apart from the derelict building which has now lost all sections of the roof. The recommendations for ecological mitigation and enhancement remain as before”. A section of hedge requires removal to facilitate the proposed access and will be translocated as shown in Appendix 7. In terms of ecological enhancements, the report suggests that these will be delivered as part of the wider residential development, comprising of suitable landscape planting and bird/bat boxes.
2.7 Intrado were instructed to produce a drainage strategy for the access proposal that is provided in Appendix 8. The engineering layout highlights how drainage aspects have been incorporated into the construction of the access road. These include:
1. 2.75m minimum width (half of highway) to be constructed from permeable asphalt to be lined with permeable geotextile membrane to facilitate infiltration to groundwater network below;
2. Kerb drainage to be installed at low point in highway to drain surface water runoff to infiltration basin during storm events in excess of 1:100yr to avoid highway flooding; and
3. ACO swale inlet (or similar approved product) to be installed in infiltration basin.
In addition to this, the Kerbing Layout notes that the kerb drainage will be implemented at a low point of the highway in order to convey runoff to bioretention section during an extreme storm occurrence greater than 1:100 years. The access and subsequent housing will be subject of separate SAB approval also.
3 Comments on Planning Policy
3.1 Paragraph 9.3 of the Revised Draft LDP correctly recognises the role that smaller settlements within Carmarthenshire have in delivering local and sustainable growth. This is further expanded upon in Paragraph 9.16 which again correctly recognises that by supporting growth of a proportionate scale in such areas, a positive contribution can be made towards the long term sustainability and cohesiveness of rural communities and the rural economy.
3.2 It is clear that there is a reliance on larger sites within rural areas which can be difficult to deliver. Due to issues around deliverability, this has impacted the resilience of housing land supply, with these larger sites not delivering the dwellings promised. A different approach is warranted in certain areas of Carmarthenshire, with a large proportion of the County being rural in nature. Within Tier 3 settlements (Sustainable Villages), sites that are small in scale but are easily deliverable ought to be favoured as they will be able to meet the housing need in an easy manner whilst not hampering the character of the area.
3.3 The Moving Rural Carmarthenshire Forward Report conducted in 2019 stated that in order to make rural areas attractive for younger people adequate housing needed to be provided to ensure that they could remain within their local communities. The report stated that a shift was required from depending on large housing developments to focusing more on smaller scale residential developments that would address housing requirements in rural settlements. A survey produced during the report revealed only 15% of respondents were happy with the housing provided within their rural area.
3.4 It is imperative that a sustainable and proportionate amount of housing growth is allowed in rural areas of Carmarthenshire during the plan period. The lack of such housing at present has unfortunately resulted in younger individuals departing rural areas, looking for housing and work in urban areas which is having a detrimental impact upon the resilience of rural areas
3.5 In terms of policy within the deposit LDP, the two key policies are SD1 (Development Limits) and HOM1 (Housing Allocations). In terms of Policy SD1, the site discussed in this statement ought to be included within the settlement boundary of Llanybri as it would represent a natural extension of the settlement. There is no logical reason for moving the site outside settlement limits within the deposit plan, as the site currently lies within limits and efforts have been made to develop the site, with two planning applications having recently been submitted, with the outline approved confirming acceptance of housing on the site
in principle. The candidate site to the south of the existing housing allocation is a logical extension of this and can be delivered via the facilitating infrastructure being developed for the existing housing allocation. The candidate site element includes old agricultural buildings, many of which are now in a state of disrepair.
3.6 In respect of Policy HOM1, there is proof that the site will be delivered as the site has gained outline planning permission for 13 dwellings and associated works, and a full application has recently been submitted for the access works. Welsh Government advice is to remove sites which have proved to be undeliverable, however this is not the case in respect of this land. The land owner is keen to progress development of the site with the submission of reserved matters for the housing itself in the near future. Furthermore, as a result of pulling the site out as a housing allocation within the deposit plan, Llanybri does not have any sites allocated for residential development. Retaining the existing housing allocation and including the logical extension to it will address this deficiency.
3.7 Having considered the last two paragraphs, there is no logical reason for altering the settlement limit of Llanybri, as this reduces opportunity for residential development and sustainable growth within a sustainable village. Furthermore, there is no reason for it to be removed as a housing allocation as there is intent to develop the site as illustrated by the submission of recent applications. Within the current plan, the site accords with LDP policy, and nothing suggests that the site could not do this when it comes to the deposit plan, were it to lie within settlement limits and be allocated for residential development. The candidate site to the south of the existing housing allocation is a logical extension to it and can be facilitated via the access being proposed.
4 Appraisal
4.1 This section examines the characteristics and features of the site in question.
Availability of Previously Developed Land
4.2 The site is not brownfield land but is well-connected to the current settlement pattern of Llanybri and its development for residential purposes represents a logical area for development and inclusion within the settlement boundary, at this location. Lying west is the Parc Y Delyn residential development which has a similar number of residential dwellings to what has gained outline planning permission at the Maes Y Meillion site, along with a comparable layout. Several services and facilities are available in the nearby towns of St Clears and Carmarthen that are a short drive away from the site.
4.3 In order to achieve a sufficient range and choice of housing land opportunities, there will be a need to consider sites which help achieve resilience in rural settings, with this site capable of being delivered in the short to medium term. The existing housing allocation element of the site can offer up to 13 residential units as illustrated in Appendix 3, whilst a few more can be delivered on the candidate site to the south. This will make a positive contribution to housing land supply,
Accessibility
4.4 Although the land consists of undeveloped agricultural grazing land which does not benefit from formal access, the site can be entered via the wider Maes Y Meillion grounds. The proposed access application submitted in March 2023 to the LPA will lie thirty yards south west of the current access. This development will offer access to a highway that runs centrally to the site with the 13 properties situated on either side as shown in Appendix 5. It will provide access to the parking areas, along with a turning head to enable vehicles to enter and leave the site in a forward gear. A section of hedge requires removal to facilitate the proposed access and will be translocated, whereas ecological enhancements as part of the proposed access will comprise suitable landscape planting and bird/bat boxes.
4.5 In terms of facilities, these are limited to a public house, chapel and playground within Llanybri. A range of services and facilities are provided in nearby Carmarthen, that can be reached via a bus service that calls at the nearby Ger Y Marbell bus stop. In terms of trains, the nearest station lies in Carmarthen, where services run to several destinations across south Wales, along with Manchester Piccadilly and London Paddington. The nearest cycle route is no 4 which is a long-distance route between London and Fishguard running via Reading, Bristol, Swansea, Tenby and St. Davids.
4.6 It is evident that drivers travel along the main road running through the village in a sensible manner as residents have to walk along the side of the road due to no footway being constructed. Such an arrangement is not uncommon in rural settlements of Carmarthenshire and underlines that the development is occurring within a pedestrian safe environment.
Land Ownership
4.7 The land to which this submission refers is within the joint-ownership of the Site Promoter – Mr David Rhodri Davies. The landowner is fully committed to bringing forward the development of the site.
Capacity of Infrastructure
Utilities
4.8 All utilities are readily available within the proximity of the site. 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
4.9 The site is not affected by a flood risk area (which would prevent vulnerable forms of development such as housing), and it is considered that foul water will connect with the existing mains sewer. Drainage aspects have been clearly incorporated into the proposed access, with further detail provided in Appendix 8.
Access
4.10 Achieving sufficient widths and visibility at the site’s proposed access point will be achieved, with some of the hedge at the northern end of the site translocated. The development will provide the necessary pedestrian and cyclist infrastructure within the site to encourage residents to walk and cycle, with 2m wide footways included on both sides of the carriageway, and a potential path may be built in future in order to connect the site with the playground that lies south of the site. A S.106 completed in relation to the outline permission also secured a £25,000 contribution towards improving pedestrian facilities in the village of Llanybri.
Impact on the Community/Welsh Language
4.11 It is not considered that the development of the site for housing will have any significant adverse impact upon the Welsh language or any local communities. The nearest primary school is situated in Llansteffan, which is a Welsh medium school therefore enabling development of the site could increase the number of Welsh speakers in the village. A S.106 was completed in relation to the outline which secured 30% affordable housing and a financial contribution towards local education facilities.
Physical and Environmental Constraints
Ecology
4.12 The Preliminary Ecological Appraisal in Appendix 7 summarised that appropriate ecological enhancements will be provided a part of the access application, and the hedge removed to facilitate the access will be translocated.
Visual Impact
4.13 Overall it is considered that the proposal would not have any significant adverse impact upon the visual amenities of the area. Separation distances, to prevent any adverse or overbearing impacts, between proposed dwellings and existing dwellings can easily be provided.
Coalescence of settlements
4.14 Development on the site would not result in the coalescence of settlements. Development of the site would result in the retention of the existing housing allocation in Llanybri and a marginal extension of Llanybri`s development limits within the deposit plan, which makes sense considering a similar scale residential development lies west of the site. Furthermore, part of the site currently lies within settlement limits, and is allocated for residential development within the adopted plan. It has been proven in this submission that the existing allocation is deliverable with progress already made at significant expense to
the applicant by successfully obtaining outline planning permission and submitting a full application to bring forward access facilitating works.
Flood Risk
4.15 The site is not identified in the TAN 15 Development Advice Maps as being at risk from flooding.
Site Contamination
4.16 In terms of ground conditions there are no known constraints that prevent the development of the site for residential uses.
Compatibility with Neighbouring Uses
4.17 It is anticipated that all of the proposed dwellings would respond well to the established character of the surrounding area. It is anticipated that a range of dwelling types and sizes, including 30% affordable dwellings would be incorporated ranging from 2 beds up to 4 beds which forms the basis for interesting street scenes and helps establish a balanced community. Overall it is considered that the proposal would not have any significant adverse impact upon the residential amenities of existing or future occupiers.
The Potential to reduce carbon emissions through co-location with other uses
4.18 The site is proposed for residential uses. However, increasing Llanybri`s population will allow help sustain local facilities and potentially increase demand for additional services to benefit the village.
Relationship with Historic Environment
4.19 The site is not located within or adjacent to the boundary of a Conservation Area. The closest feature of historic importance is Scheduled Ancient Monument Yr Hen Gapel which sits together with Grade II
listed Tower of Yr Hen Gapel. These are situated within the village of Llanybri, roughly 0.4 kilometres to the south west of the development site.
Delivery of Key Placemaking Objectives
4.20 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 site can provide homes in the right place and create a sustainable, well-designed, and high-quality housing scheme, where people will want to live, in accordance with national placemaking objectives.
Conclusion
5.1 This site representation is made by Asbri Planning Limited on behalf of Mr David Rhodri Davies. It in respect of the land at Maes Y Meillion, Llanybri which should be reinstated within the development limits of the village, as well as being included as a housing allocation as part of the Carmarthenshire County Council Second Deposit Revised Local Development Plan 2018 - 2033.
5.2 The extension of the settlement limit of Llanybri, and reintroduction of Maes y Meillion as a housing allocation for the Tier 3 settlement can ensure that a proportional amount of housing growth will be delivered across the plan period. Across the plan period it is highly unlikely that any other sites will come forward in the settlement, therefore it is essential that this site is reconsidered as part of the deposit plan, and as previously mentioned, the site is within limits and allocated for residential development in the current plan. The candidate site to the south is a logical extension of the existing housing allocation, with it currently including agricultural structures that are in a dilapidated state.
5.3 Whilst the soundness of the Plan is not challenged objections are made to the following policies within the deposit plan:
a) Object to SD1 (Development Limits) – the site shown in Appendix A ought to be reinstated within the settlement limits of Llanybri. Within the adopted plan, the site is within limits however it has been placed outside limits in the deposit plan. There is no justification for it`s removal, and allowing development at the land in Maes y Meillion enables a natural extension of the settlement. Lying west of the site is the Parc Y Delyn residential development which has a similar amount of residential dwellings to what has gained outline planning permission at the Maes Y Meillion site, along with a similar layout. The previous candidate site shown in Appendix B should also be included within the settlement limit as it is a natural extension of the existing housing allocation and can be facilitated by infrastructure developed as part of the current site that benefits from outline planning permission.
b) Object to HOM1 (Housing Allocation) – the Maes y Meillion housing allocation is not included within the deposit plan, although the site has been allocated for 10 dwellings within the adopted plan. The site layout in Appendix 3 shows 13 dwellings will be delivered in total. There is no reason for removing the site as an allocation, and it has gained outline planning permission for the erection of 13 dwellings and associated infrastructure work (Ref: PL/00629), and a subsequent planning application was submitted in March 2023 concerning full planning permission for the construction of an access road in order to serve those dwellings. The applicant is keen to progress with the reserved matters for the site shortly, therefore this would be considered a deliverable allocation were it to be included in the deposit plan. It is critical that this housing allocation is reinstated into the deposit plan as at present, no housing allocations are proposed for Llanybri, and there are limited opportunities for residential development in other parts of the settlement. The candidate site aspect as shown in Appendix B is a natural extension of this and should also be included.
5.4 Extending the development limit to incorporate this site would promote sustainable growth in a way that takes into consideration the nature of the current settlement. There needs to be an opportunity for some proportional housing growth within this tier 3 settlement that can be facilitated over the plan period until 2033. The site could potentially deliver 13-20 dwellings 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 suitable contribution to the area’s housing land supply. In addition to this, it is located in a sustainable area where some amenities can be accessed on foot, and nearby Carmarthen can be accessed via a bus service that runs nearby. It is also considered acceptable in terms of drainage and ecological aspects.
5.5 In summary, it is considered that Carmarthenshire County Council should, in its review of the Local Development Plan, include the site within the settlement boundary of Llanybri, and include the Maes y Meillion site as a housing allocation within the deposit plan.

Include the site as a residential allocation in the Plan.

This representation objects to the exclusion of this site from the development limits for Llansteffan – a Tier 3 Sustainable Village. Its inclusion would not lead to additional environmental pressure, but instead will foster sustainable growth and allow for a wider choice of housing type. Its development would be in keeping and in character with the settlement and will ensure a deliverable source of future housing for this sustainable community.
In addition, providing the opportunity for development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints and its short term delivery is assured.
It is considered that this site is both sustainable and readily deliverable and offers a valuable development option within this Tier 3 Sustainable Village.
The inclusion of this land as part of the Llansteffan settlement within revised development limits should be fully supported.

Include the site as a residential allocation in the Plan.

This representation objects to the exclusion of this site from the development limits for Gorslas/Cross Hands. The frontage portion of the site has recently been granted planning permission for residential development and it seems fitting that the rear portion now be allocated. The site offers a valuable development option in this part of Gorslas, where no other allocations are proposed and which is deemed an acceptable residential development opportunity.
Its inclusion would not lead to additional environmental pressure, but instead will foster sustainable growth and allow for a wider choice of housing type within this Tier 1 Principal Centre. Its development would be in keeping and in character with the settlement and will ensure a readily deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints and its short term delivery is assured.
It is considered that this site is both sustainable and readily deliverable and its inclusion within revised development limits should be fully supported.

Allocate site AS2/090/001 for housing within the Plan.

This representation comprises both an objection and a supporting submission. The proposer's land ownership at Llangadog comprises a number of fields immediately adjacent to the settlement’s centre. A frontage portion at Heol Pendref has been identified as being suitable for residential development and has been included within development limits, the remainder of the land holding has however been excluded. The part-inclusion of this frontage portion is clearly supported, but an objection is hereby made to the exclusion of the remainder. The justification for including only part of the proposer's land will apply to the whole area.
The following objection is made to the exclusion of the majority part of this site from the development limits for Llangadog, an identified Tier 2 Service Centre. It must be emphasised that the proposed scheme includes a number of community benefits and does not seek residential development on the entire landholding. The proposer is keen to offer land for uses that will provide both short and long term benefit to village residents, both in a practical sense and from a more holistic well-being perspective.
A key element of the scheme is to offer land for a much needed car park which is indicated on the accompanying layout drawing as being located immediately adjacent to the village centre. Parking provision is scarce in Llangadog and such a community facility in this village centre location would be welcomed and would help alleviate current on-road congestion. A convenient village centre access is proposed from the A4069 road.
Also, of benefit to the community is a proposed communal garden adjacent to the car park, which would provide an open green public area in the village centre.
Also proposed is an area to be set aside for community allotments which again will benefit the residents of Llangadog and aid in promoting both physical and mental well-being and also benefit the local environment through biodiversity enhancement.
The residential element of the scheme would comprise a high quality phased development and would draw on local Welsh vernacular architectural design elements, making every effort to be sustainable, both through the employment of local contractors, the use of local suppliers, and in the long term, through the provision of residential units within convenient walking distance of village services and facilities.
The proposer’s land is in a vastly more sustainable location than the residential allocations included in the plan for Llangadog, particularly SeC17/h2, which is on the perimeter of the settlement and thereby will contribute towards additional private car usage and exacerbated congestion within the village. The other two sites (SeC17/h1 and SeC17/h3) have been partly constructed and again, are more distant from the village centre.
The inclusion of the proposer’s land would not lead to additional environmental pressure, but instead will foster sustainable growth and allow for a wider choice of housing type within this Tier 2 Service Centre. Its development would be in keeping and in character with the settlement and will ensure a deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints and its delivery is assured.
A full description of the site's development potential and merits has previously been provided in the candidate site submission, to which reference should be made.
It is considered that this site is both more sustainable and deliverable than other sites that have been allocated within Llangadog.
The inclusion of this land within revised development limits would be fully supported.

Amend Plan to include the site

This representation comprises an objection to the exclusion of this site from
the development limits for Capel Hendre. The inclusion of the proposer’s land
would not lead to additional environmental pressure, but instead will foster
sustainable growth and allow for a wider choice of housing type within this Tier
1 Principal Centre. Its development would be in keeping and in character with
the settlement and will ensure a readily deliverable source of future housing
for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature
conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood
risk, hydrological, ecological, archaeological or land ownership related
constraints and its short term delivery is assured.
It is considered that this site is both sustainable and readily deliverable and its
inclusion within revised development limits should be fully supported.

Include current LDP site T3/9/h4 within the Revised LDP as a housing allocation.

Land South of Cwmgarw Road, Brynamman – ref. T3/9/h4 / ref. SR/015/004

Please find enclosed, on behalf of and under instruction from our clients, Mrs H Wight, Mrs C Dudlyke and G Searles, a detailed Site Representation, submitted to Carmarthenshire County Council for consideration for inclusion / allocation / retention within the 2nd Revised Local Development Plan (LDP).
As required, to enter the site for evaluation within the LDP process at this stage of plan preparation, the following documentation is enclosed with this submission:
• Completed Online Representations Form;
• Site Location Plan;
• Illustrative Masterplan;
• 01C – Proposed Access
• 02B - Proposed Improvements; and
• Detailed case provided in an addendum below.
In addition to the enclosed documentation, a detailed case for the retained inclusion of the Site within the emerging LDP as a housing allocation is provided - which is requested to be carefully and thoroughly taken into consideration in appraising the Site Representation and the site’s credentials for inclusion within the new Development Plan. As well as promoting the retention of the existing allocation within the LDP (Option 1), this representation also seeks to allocate the wider land beyond the existing allocation (Option 2) – in line with Candidate Site ref. SR/015/004, and the existing adopted LDP site allocation ref. T3/9/h4 (or part thereof). As such, this representation comprises an objection to the Deposit Plan on the basis that the site is to be delivered as a residential development during the Plan period.
In the absence of any methodology for the assessment of new allocations, we have reverted to the criteria and methodology outlined within the Site Assessment Methodology (September 2022).
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 2 of 20 We look forward to hearing from you in due course. In the meantime, we hope and trust that all is in order with this submission. Please do not hesitate to contact us in the event that further information is required or considered beneficial.
Yours sincerely
Geraint John
Director
Geraint John Planning Ltd

Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 3 of 20 Preface
Previous representations were made in support of this site, on behalf of the clients, to set out a detailed case for the retention of the site’s allocation within the current LDP, and inclusion of the wider site beyond the existing allocation, in response to the 1st Deposit Plan consultation in 2020.
Carmarthenshire County Council have advised that representations / comments submitted as part of the consultation on the 1st Deposit LDP will no longer be considered. Only those submitted as part of the 2nd Deposit will be considered and forwarded to the Inspector. Any previous representations / comments must be resubmitted and reflect the content of the second Deposit LDP. As such, this submission seeks to ‘build on’ and update the previously submissions made.
Carmarthenshire County Council’s ‘Site Assessment Table’ has set out that the candidate sites / options ref. T3/9/h4 / ref. SR/015/004 submitted through the candidate site process have failed Stage 2b of the Site Assessment Methodology of the candidate site process, and therefore, are not to be progressed as residential allocations.
Separate to the LDP process, the site itself has been previously subject to two previous outline applications for residential development, both of which have been refused. These are as follows:
• PL/01036 – refused 30th July 2021; and
• PL/04459 – refused 17th February 2023.
These applications have sought permission for proposed residential use on the basis that the site benefits from an existing residential allocation with the Adopted Local Development Plan. The proposal has been supported by a comprehensive level of assessment work, to evidence the site’s credentials in that it is not physically constrained by any means. It is therefore considered that the site is deliverable, and would represent an acceptable form of sustainable development in this location – not least that it is allocated for residential use. Moreover, the principle of development is considered acceptable, by way of its existing allocation, and all other planning considerations relating to the site / proposal are addressed by way of detailed supporting material that accompanied the planning submissions.
The second application (ref. PL/04459) is of particular importance, in terms of how it relates to this representation, in that it forms the basis of setting out the acceptability of the site as an allocation for residential development. It is considered that the reasons for refusal are not insurmountable in any event, and by association, would not pose a constraint to the deliverability of the site. Supporting assessment work has evidenced the acceptability of the proposal, in light of the concerns raised that underpin the reasons for refusal.
Accordingly, this submission responds to and addresses the reasons of refusal of the latest application ref. PL/04459, to evidence support the site’s credentials as a residential allocation within the RLDP.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 4 of 20 Detailed Site Representation
As set out on the previous page, these representations object to the Deposit LDP on the basis of the lack of inclusion of deliverable sites. Those being:
(1) The retention of the existing allocation (ref. T3/9/h4) in the LDP;
(2) The allocation of Candidate Site ref. SR/015/004 – which includes LDP allocation T3/9/h4.
The above sites are illustrated on the maps below:
Existing Allocation T3/9/h4 – Option 1
SR/015/004– Option 2
The two options presented above were submitted in response to the previous Deposit Plan consultation in 2020 as potential candidate site options (submission can be found in Appendix B).
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 5 of 20 Carmarthenshire County Council’s ‘Site Assessment Table’ sets out the assessments and conclusions of each candidate site submitted through the LDP Review process. In respect of the candidate site submissions previously made (ref. T3/9/h4 and SR/015/004), the site passed Stage 1 and 2a of the assessment, but was considered to fail Stage 2b for the following reason:
“There are concerns at the deliverability of the site. The site represents a longstanding residential allocation (T3/9/h4) and no firm progress has been made on delivery. Sufficient residential opportunities exist within the settlement.”
The representations below, therefore, set out the objection as a whole against the non-inclusion of the 2 options presented, specifically in response to the reasoning above.
Site Description /Characteristics
This representation relates to the Land South of Cwmgarw Road in Brynamman. As noted above, the representation proposes two options:
1) The retention of the existing allocation (ref. T3/9/h4) in the LDP;
2) The retention of the existing allocation in the LDP, as well as the allocation of the wider land within the site promoters ownership surrounding this site for residential development (as per Candidate Site ref. SR/015/004).
A summary of the characteristics of the site and options is set out below:
• The site is a irregularly shaped greenfield space, consisting of fields and bounded by trees;
• The site promoted in Option 1 is approximately 2ha in area and represents a portion of a wider allocation (approx. 3.5ha total) for residential development in the current LDP;
• The site promoted in Option 2 is approximately 4ha in area and comprises of the land allocated for residential development in Option 1, as well as additional land to the south within the site promoters ownership;
• The site is accessed via two access points in its north-eastern and north-western corners, which are both within the ownership of the site owner;
• The southern and western boundaries of the site comprise of further greenfield land;
• The northern and eastern boundaries of the site consist of the rear gardens of the properties along Cwmgarw Road.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 6 of 20 Site Location Plan with Option 1 Filled in Blue and Option 2 Outlined in Red
Current Planning Status – Designation in the Adopted Local Development Plan
LDP Proposal Map Extracts
Option 1 Outlined in Red and Option 2 in Blue
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 7 of 20 Symbol Designation Symbol Designation
Development Limits (GP2)
Residential Allocation (H1)
Cycle / Proposed Cycle Route (TR4)
Recreation / Open Space (REC1)
Higher Proportion of Welsh Speakers (SP18)
Category 2 Sand and Gravel (MPP3)
Coal Primary Resource Zone (MPP3)
To summarise, the site is:
• Located within settlement limits of Brynamman;
• Allocated for residential development (ref. T3/9/h4);
• Situated within an area with a Higher Proportion of Welsh Speakers;
• In close proximity to an existing / proposed Cycle Route; and
• In proximity to Recreation / Open Space – situated to the north of the site.
The LDP contains a significant number of policies of potential relevance to any development of the site. The key policies of relevance to the site and any proposal are appended to this overview (Appendix A).
Candidate Sites: Assessment Criteria & Methodology
We are aware that, in appraising the credentials of sites for inclusion as an allocation in the Plan, a series of criteria and a methodology have been defined and adopted.
We are also aware that the appraisal process consists of multiple stages, summarised as the following:
• Stage 1: An assessment of the site and its compatibility with the Preferred Strategy;
• Stage 2a: Identification of fundamental site constraints that cannot be overcome or mitigated for;
• Stage 2b: Detailed, site specific assessment including an analysis of its sustainability, viability and deliverability, as well as the assessment of the site against a SA/SEA;
• Stage 3: The sites will be further assessed with a HRA to be carried out to ensure that the Deposit plan has no significant detrimental impact on European Designated Sites.
The stage 1 assessment, as set out within the Site Assessment Methodology (September 2019) included criteria to filter sites out where they may be contrary to National Policy, or unsuitable due to overarching constraints (unless sufficient information is provided to prove otherwise).. As set out above, the site is NOT any of the following designations:
• Sites of Special Scientific Interest;
• Special Area of Conservation;
• Special Protection Areas;
• Local Nature Reserves;
• National Nature Reserves;
• Historic Parks and Gardens;
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 8 of 20 • Scheduled Ancient Monuments;
• C1 and C2 Flood Zones;
• Coal Safeguarding Areas;
• Land Stability and Coal Mining Issues (That are not remediable for economic or other reasons);
• Hazardous Installation Facilities;
• Landfill Sites; and
• Areas of Contamination (That are not remediable for economic or other reasons).
According to the LDP Site Assessment table, the site was found to be compatible with the location of future growth presented within the Preferred Strategy and as a result passed Stage 1. The Candidate Site also went on to pass Stage 2a of the Site Assessment, having been found to have no fundamental constraints which cannot be overcome or mitigated for.
The candidate sites’ performance in these respects have been previously dealt with at both the Candidate Site Stage for the current LDP, prior to its allocation within the Plan, and at the same stage for the Deposit Plan and as a result will not be rehearsed within these representations.
The Site Assessment table outlines that the site failed the Stage 2b Assessment, with the comments noting that this was due to concerns regarding the deliverability of the site. The comments go on to state that ‘There are concerns at the deliverability of the site. The site represents a longstanding residential allocation (T3/9/h4) and no firm progress has been made on delivery. Sufficient residential opportunities exist within the settlement.”
As such, the representations below will relate to the assessment of the site at Stage 2b, highlighting its deliverability during the Plan period.
Key Issues
It is considered that the key arguments in support of the inclusion of the Candidate Site within the LDP for residential development relate to areas identified within the Site Assessment Methodology ‘Stage 2b’, relating largely to site deliverability – this being the sole concern raised within the Sites Assessment at this stage.
However, as previously stated, two separate applications have been made for this site, which demonstrates the clients’ willingness to deliver the site for residential development within the site. Whilst both applications have been refused, it is considered that the concerns associated with the proposal are not insurmountable, and with the support of further assessment work, these issues can be overcome, by way of a further planning application.
Accordingly, in respect of the ‘deliverability’ of the site, it is pertinent to consider the key Reasons for Refusal relating to the previous application (ref. PL/04459), and how this relates to the overall acceptability of the site. The following section sets this out in detail, explaining the reasons for refusal, as well as the clients’ response to how the issues can be overcome – warranting an acceptable candidate site submission for its inclusion / allocation / retention in the RLDP.
Planning Application (PL/04459)
As set out above, the key issues relating to the site’s credentials as a residential allocation within the RLDP relate to its ‘deliverability’. Two separate applications have been made to-date for the proposed development of the site under its current allocation.
The concerns and objections to the proposed residential use, which formed the reasons of refusal for the most recent application (ref. PL/04459), are set out in the table overleaf:
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 9 of 20 ‘Reason for Refusal’
Issue
Basis for concern
1
Fails to demonstrate suitable visibility, which would impact upon highway safety
• Double Yellow Lines are subject to a Traffic Regulation Order – which cannot be conditioned.
• Lack of information to confirm that adequate access and visibility is proposed.
2
Would result in a net loss of biodiversity
• Would have an impact on priority species and habitats, resulting in a loss of Section 7 habitats.
• Mitigation proposed is unsuitable.
3
Fails to provide any community benefits
a) No legal agreement has been committed to.
In light of the above reasons for refusal, it is considered expedient to set out a detailed response to each. Before doing so, it is necessary to make the point that the clients contend the view and position taken that the scheme is unacceptable in both highways and ecology terms (Reason for Refusal 1 – highway safety, and Reason for Refusal 2 – Ecology).
Lengthy discussions took place with the Highways Authority, before and during the application process, particularly with the Applicant’s highway consultant, to discuss all matters pertaining to highway safety. Highways design proposals were submitted to obtain feedback, and necessary amendments were made to reflect the changes request by the HA, to ensure that the scheme would be acceptable. Throughout this process, it was acknowledged that the proposed Double Yellow Lines (DYL) to secure the appropriate visibility splays, would be subject to a Traffic Regular Order – a separate consultation process. However, it was not considered expedient, nor appropriate to in any event, to commence this process until planning permission had been secured for the proposal. As such, it was considered that the requirement for a TRO could be conditioned upon any granting of the planning permission.
In respect of ecology, it is acknowledged and accepted that an alternative means of mitigation is required, given that the previous proposal would have not been acceptable – in that it would not have achieved a ‘net benefit’. The mitigation proposed comprised the translocation of existing Section 7 habitat species to a supplementary area (within the Applicant’s ownership) where the species were already present. Accordingly, it was deemed that no translocation could take place, and therefore, no net gain could be achieved. As such, alternative areas of mitigation within the Applicant’s control were required to offset any ecological impacts.
Finally, in respect of Reason for Refusal 3, it is considered that this will “fall away”, in that the necessary legal agreements can be agreed and implemented, to secure community benefits. Given the aforementioned issues were ongoing, it was not considered expedient to commence the drafting of legal terms until the position had been resolved, and was progressing to a favourable conclusion.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 10 of 20 Having set out these matters, the following responses are made in respect to each of the reasons for refusal.
Highways
The Decision Notice for this application set out that there were two elements of which the proposal was not acceptable under highway grounds, relating to:
a) Double yellow lines (DYL) as proposed are subject to a Traffic Regulation Order and would displace parking for existing dwellings; and
b) There is a lack of information to confirm that adequate access and visibility is being proposed.
The above matters are discussed further below.
a) Double Yellow Lines & displacement of parking
Double Yellow Lines
In relation the need to carry out a TRO, it was conceived that measures subject to a TRO could not be conditioned upon any permission, as it is a separate process. Specifically, the following is outlined on the Decision Notice:
‘Measures subject to a Traffic Regulation Order cannot be conditioned as they are subject to consideration under other legislation and there is no reasonable certainty that they will be found acceptable. This process should be undertaken at the developer’s expense prior to resubmission of any application.’
However, it is considered that a ‘Grampian’ condition could have been imposed upon any permission, which would seek to control the development, subject to a TRO being carried out, prior to works commencing on site / occupation. Specifically, the following condition working could have been utilised:
“The development hereby approved shall not be occupied until a scheme to provide Traffic Regulation Orders along Cwmgarw Road has been submitted to and agreed in writing by the Local Planning Authority. The works shall be completed in accordance with the approved details prior to any works commencing on site.”
In addition, WG Circular 016/2014, (Oct 2014) : ‘The Use of Planning Conditions for Development Management’ sets out the following when advising on Access conditions:
5.34
“A ‘Grampian’ condition can be used to prevent the commencement of development until certain highway improvements are made, if they relate directly to the development. TAN 18 (Transport) provides further advice with regards to such conditions.”
Moreover, Annex F of Tan 18 : Transport, set outs in para. F1 that
“Planning authorities may grant planning permission subject to a condition that development should not be commenced or occupied until some obstacle to the development has been surmounted (a ‘Grampian Condition). This may include the carrying out of highway works. A ‘Grampian’ condition may be necessary where works must be caried out in an existing highway in order to safely and efficiently accommodate traffic created by a development.” (GJP Emphasis).
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 11 of 20 Clearly, the imposition of a Grampian condition is supported by legislation and national policy, to ensure that highway issues relating to a development are not insurmountable, and are addressed in an appropriate manner. The highlighted text clearly demonstrates that Grampian conditions relating to highway works are acceptable, which is of course pertinent to the refused application i.e. carrying out of a TRO to implement DYL.
It should be recalled that it is considered that the TRO is to be needed to make the development acceptable in planning terms. The TRO will be confined to highway land / extent – which is always pre-supposed to be available to development to make an otherwise unacceptable position acceptable. CCC Highways are in control of the TRO, and having required its entering into in the first place cannot then determine that it is not possible or appropriate to enter into. This means that any condition meets the test of being necessary, reasonable, related, precise and enforceable etc.
The other point to make is that without a scheme there’s no need for a/the TRO. The latter therefore follows the former. This is the same principle and approach to all other regulatory regimes – building control following planning / licensing following planning. Without an approval to the development in the first place, these other regulatory processes have no meaning or purpose.
In summary, it has not been / is not considered expedient to commence the TRO process simultaneously to the application, given in any case it can be undertaken thereafter following approval, which, as evidenced above, can be controlled by condition.
Accordingly, in terms of how this relates to the promotion of the site as an allocation within the new Plan, the above evidences that the site is deliverable, in that the requirement to undertake a TRO can be actioned in any event, and is not an insurmountable issue that would deem the site undeliverable.
Displacement of Parking
It was raised by the HA that the proposed implementation of DYL, to the east of the proposed access, to ensure that appropriate visibility splays are achieved, would result in the displacement of existing residents’ parking.
It is noted that the existing arrangement comprises residents parking off Cwmgarw Road, along the pavements, which do not constitute formal off-road parking. The result of this existing arrangement poses a risk to highway safety, in that the width of Cwmgarw Road is narrowed, thus increasing the likelihood of car collisions across this stretch of the road. In addition, the pavement is also narrowed, culminating in a tight space for wheelchair uses and child push chairs i.e. vulnerable users, to use the pedestrian path.
The proposed alterative arrangement, as illustrated below, would address the existing highway safety concerns set out above, whilst also providing a safe means of parking for the residents. The proposal takes the form of providing safe and accessible parking along the bow access road into the development, off Cwmgarw Road.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 12 of 20 Proposed Access Arrangements
In total, there is capacity for 3no. cars to park along the access road, without causing any detriment to highway safety, and this would serve the two existing dwellings east of The Tregib Arms (public house). It is proposed that this stretch of the internal high network of the development is to be adopted, and therefore, there is no constraint proposed that would prohibit car parking here. Moreover, tactile paving is proposed near the access to facilitate safe pedestrian crossing from this stretch of road to the forementioned dwellings – to ensure that there is a link between the car parking and dwellings.
As such, it is considered that the parking proposals represents a safer and more appropriate arrangement than that of the existing, therefore, resulting in a betterment for highway safety.
b) Adequate access and visibility
To support the planning application submission, an Access Design was submitted, setting out the proposed access arrangements. As shown in the extract below, visibility splays of 2.4m x 43m can be achieved in either direction, which is considered to be appropriate for a 30mph road. This is supported by Manual for Streets guidance which sets out that under the assumption that 85th percentile traffic speeds are no more than 10% above the posted 30mph speed limit, visibility splays of 2.4m x 43m in each direction are required. As such, the proposed visibility splays comply with the pertinent guidance.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 13 of 20 Proposed Access Design
Of course, the proposed access design is subject to the TRO process, as discussed above, to ensure that parked cars do not impinge upon visibility for cars egressing the site. Specifically, the yellow lines will extend into the development site to remove parked vehicles from within the junction bellmouth, and allow vehicles on exit from the site to approach Cwmgarw Road correctly i.e. perpendicular to it.
As previously set out, it is considered that the TRO can be undertaken in any event, for the proposed DYL, and therefore, the proposed arrangement does not give rise to any highway concerns, in that it represents a safety improvement to the existing position.
In summary, the proposed site access junction provides sufficient visibility to ensure highway safety is not adversely affected by the development. The increase in traffic generated by the proposal is negligible, and therefore, will not cause any detriment to Cwmgarw Road.
Ecology
The Decision Notice (PL/04459) outlined that the proposal would have a negative impact upon biodiversity within the site, in regard to existing priority species and habitats. Specifically, the following is set out:
“The proposed development will have an adverse impact on priority species and habitats and result in a loss of Section 7 habitat, marshy grassland and broad-leaved woodland as well as loss of otter habitat (bramble) and dormouse habitat (dense scrub). Marshy grassland and broadleaved-woodland are habitats that appear on the Environment (Wales) Act 2016 Section 7 list of habitats of key significance to sustain and improve biodiversity in relation to Wales.”
To offset the loss of Section 7 habitats, it was proposed through the application that these would be translocated to the south-western area of the site, which would act as a ‘mitigation area’. Essentially, this comprised the proposed translocation of Marshy Grassland and the planting of Semi-Natural broad-leaved woodland.
However, it was advised by the Council’s ecologist that the proposed mitigation area already contained the Section 7 habitats, and therefore, translocation / planting could not be achieved as these habitats were already in-situ.
The clients have been in discussions with the scheme’s Ecologist in regard to exploring alternative areas of land, which have potential and capacity to accommodate the necessary translocation of the Section 7 habitats. The clients own a number of parcels of land that are within their control, which are located within the vicinity of the promotion site. It is considered that these parcels are sufficient in size in that they can meet the requisite ratios of planting and translocation, to mitigate the loss of the protected species within the site.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 14 of 20 Ecology surveys are to be undertaken of these parcels, to unequivocally confirm their suitability to act as a mitigation area for the development, however, a desk-based review has confirmed that there are no existing Section 7 habitats present within these sites – contrary to that of the previously proposed mitigation area.
Accordingly, it is considered that there are possible solutions to overcome this ecology issue, with neighbouring land having the potential to accommodate the required translocation of the Section 7 habitats. As outlined above, these lands are within the clients’ control, and therefore, it is considered that there are no legal issues associated with this possible approach. As such, the possible ecological impacts of the development can be mitigated for, to ensure that a biodiversity ‘net gain’ is achieved with the development of the site.
In light of this, it is conceived that the ecological position does not present a constraint to the deliverability of the site, as a proposed residential allocation within the RLDP, and therefore, is wholly acceptable in respect of this Reason for Refusal.
Legal Agreement
Finally, in respect of Reason for Refusal 3, the Decision Notice sets out that the proposal “does not contribute to the creation of sustainable places and spaces since the proposal has not been accompanied by a commitment to enter into a legal agreement to secure any community benefits.”
Given that discussions were ongoing between the Applicant and the LPA, in relation to the outstanding issues discussed above (i.e. highways and ecology), it was not considered expedient to undertake the necessary arrangements to prepare a legal agreement i.e. S106 agreement. It was acknowledged throughout the application process that contributions would be required, as part of the approval, following consultation responses received from statutory consultees.
Both the principle and the detail relating to the requested contributions were not disputed by the Applicants, nor would be in any event for a future application, as it is expected that a proposal of this nature and scale would warrant a S106 application – given the effects on the wider community.
Given the aforementioned issues were ongoing, it was not considered expedient to commence the drafting of legal terms until the position had been resolved, and was progressing to a favourable conclusion.
It is therefore considered that the securement of a legal agreement is not an insurmountable issue that would deem the development undeliverable, and therefore, would not impede upon the site’s allocation within the RLDP.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 15 of 20 Other Planning Considerations
Land Ownership
The site could make a realistic (and sustainable) contribution towards the provision of housing land within Carmarthenshire over the LDP period.
The land – representing a large portion of the site as allocated within the existing LDP – is wholly within the ownership of the site promoters, Mrs H Wight, Mrs G Searles and Mrs C Dudlyke, and no restrictions / constraints to the development of the site coming forward over the plan period are identified. The land is readily available to come forward for development, as evidenced by the proceeding sections.
Sustainability
Sustainability and Linkages with Nearby Settlements
As referred to above, the site is located within the settlement limits for Brynamman, which is identified as a Local Service Centre within the current local development plan. As a result, the site has close association and linkages with the facilities and services available within the settlement. A key destination for local residents is The Black Mountain Centre, which comprises a community centre including a café, post office, library and doctors surgery. Other services located within the settlement and within close proximity to the site include a number of public houses, places of worship, food / retail outlets and amenity / recreational facilities.
Pedestrian footways are provided on both sides of Cwmgarw Road with a general width of at least 1.5m, albeit with some instances of localised narrowing due to physical constraints or footway parking. There are also opportunities for cycling in the area, mainly consisting of on-carriageway routes although National Cycle Route 437 is accessible within 500m of the site, linking the site to Ammanford in the west and Cwmllwynfell in the east.
Evidently, the site is located in a highly accessible location, within easy and convenient walking distance of the services provided within Brynamman, with a range of facilities on offer. The site therefore benefits from being positioned within a highly sustainable location – which in light of the availability existing services and facilities, is considered extremely well-suited to residential development. It is considered that the services and facilities in close proximity to the site would facilitate and encourage the growth of the settlement in both a natural and sustainable manner.
Public Transport
The proposed development site is well served by public transport with a number of regular scheduled bus services running along Cwmgarw Road. Bus stops are available well within the recommended maximum walking distance of 400m from the application site, with travel via bus available in both directions near the site frontage.
The bus stops along Cwmgarw Road are served by service numbers X26, 64, 124, 167 and 905, providing services to Swansea, Upper Brynamman, Tycroes, Neath Abbey, Ammanford, Ystradgynlais, Crynant and Cwmtwrch Isaf.
In terms of rail transport, Ammanford railway station is located approximately 9.4km to the west of the site. Whilst not convenient for all, it could be used as part of a multi-modal journey along with a car, taxi, bicycle or bus.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 16 of 20 Flood Risk
The relevant extract from Natural Resources Wales’ Development Advice Map (DAM) (NRW) Flood Map is provided overleaf. This confirms that the representation site is not at risk of flooding.
Extract from NRW Flood Map
Key:
Heritage and Conservation
The Historic Wales website indicates that there are no Listed buildings or Scheduled Ancient Monuments on or within close proximity of the site. Moriah Chapel, situated in the north-eastern corner of the site, is contained as a National Monument Record for Wales and within the Welsh Archaeological Trusts’ Historic Environment Records as a post-medieval church. Given the residential setting of the chapel, the impact of the residential development of the site is expected to be negligible.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 17 of 20 Extract from NMR (Historic Wales)
Tree Preservation Order (TPO)
Carmarthenshire County Council’s online map indicates that there are no protected trees on site as illustrated below:
TPO Map Extract
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 18 of 20 A tree survey of the site has been carried out by ArbTS which will guide the form of development proposed at the site. It is considered that appropriate access, infrastructure and built form can be incorporated within the site without detrimentally impacting the existing trees on the site.
Summary and Conclusions
As outlined above, it is considered that the site is a highly suitable location for housing, and for inclusion as such within the emerging LDP at the Candidate Site stage. To summarise:
• The land lies within the settlement boundary for Brynamman, and within a defined ‘Local Service Centre’.
• The site (Option 1) is currently afforded a residential allocated status within the currently adopted LDP, and this should be considered as the baseline for the site.
• The Reasons for Refusal of planning application ref. PL/04459 are not considered to be insurmountable, in that they would culminate in the proposal being either undeliverable or unacceptable, therefore, representing an appropriate form of development.
• The development of the site would not unduly damage the character of the surrounding area, due to the site’s location within an existing residential area and its strong association with the settlement of Brynamman.
• The site benefits from a close association and connection with the services and facilities provided within Brynamman, which are situated within convenient walking distance (which would facilitate sustainable growth of the settlement).
• The sustainability and accessibility credentials of the site lend themselves to supporting residential development at this location – several bus stops are located immediately north of the site on Cwmgarw Road.
• The land is not identified as being of any special landscape / nature conservation / ecology interest – it is not afforded any such protection status within the current LDP; and
• It is considered that the inclusion of this land for residential development will assist the Local Authority in meeting their housing needs provision.
• The site is wholly deliverable and can realistically come forward within the early years of the Plan period.
• Object to the Deposit LDP on the grounds that the site isn’t included and is set to be delivered, as set out above.
We consider that the site ‘performs’ well against the defined assessment criteria and methodology, with no evident constraints, obstacles, or failings.
Our clients would be happy to discuss any aspect of the submission made and credentials of the site when your Authority (and the appointed Inspector in turn) comes to evaluate matters.
We respectfully urge you, for the reasons given herein and in the associated submitted information, to include the site put forward within the emerging LDP for housing development.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 19 of 20 APPENDIX A – CARMARTHENSHIRE PLANNING POLICY
Ref. Title Summary
SP1
Sustainable Places and Spaces
Proposals for development will be supported where they reflect sustainable development and design principles subject to a number of criteria.
SP2
Climate Change
Development proposals which respond to, are resilient to, adapt to and minimise for the causes and impacts of climate change will be supported subject to a number of criteria.
SP3
Sustainable Distribution – Settlement Framework
Provision for growth and development will be at sustainable locations in accordance with the settlement framework. Llanelli is identified as a Growth Area.
SP9
Transportation
Proposals should contribute to the delivery of an efficient, effective, safe and sustainable integrated transport system.
SP13
Protection and Enhancement of the Built and Historic Environment
Development proposals should preserve or enhance the built and historic environment of the County, its cultural, townscape and landscape assets and where appropriate, their setting.
SP14
Protection and Enhancement of the Natural Environment
Development should reflect the need to protect, and wherever possible enhance the County’s natural environment. All development proposals should be considered in accordance with national guidance/legislation and the policies and proposals of this Plan, with due consideration given to areas of nature conservation value, the countryside, landscapes and coastal areas.
GP1
Sustainability and High Quality Design
Development proposals will be permitted where they accord with a range of criteria.
GP2
Development Limits
Proposals within defined Development Limits will be permitted, subject to policies and proposals of this Plan, national policies and other material planning considerations.
GP3
Planning Obligations
The Council will, where necessary seek developers to enter into Planning Obligations (Section 106 Agreements), or to contribute via the Community Infrastructure Levy to secure contributions to fund improvements to infrastructure, community facilities and other services to meet requirements arising from new developments.
GP4
Infrastructure and New Development
Proposals for development will be permitted where the infrastructure is adequate to meet the needs of the development.
H1
Housing Allocations
Land has been allocated for residential development for the plan period 2006 – 2021 at those locations as set out in the LDP, and as depicted on the Proposals Map.
H2
Housing within Development Limits
Proposals for housing developments on unallocated sites within the development limits of a defined settlement will be permitted, provided they are in accordance with the principles of the Plan’s strategy and its policies and proposals.
AH1
Affordable Housing
A contribution to affordable housing will be required on all housing allocations and windfall sites. The Council will seek a level of affordable housing contribution of 30% in the higher viable areas, 20% in the middle viable areas, and 10% within the Ammanford / Cross Hands sub-market areas.
Where viability at the target levels cannot be achieved, variation may be agreed on a case-by-case basis.
TR2
Location of Development – Transport Considerations
States that proposals which have a potential for significant trip generation will be permitted where:
a) it is located in a manner consistent with the plans strategic objectives, its settlement framework and its policies and proposals;
b) it is accessible to non-car modes of transport including public transport, cycling and walking;
c) provision is made for the non-car modes of transport and for those with mobility difficulties in the design of the proposal and the provision of onsite facilities;
d) travel plans have been considered and where appropriate incorporated.
TR3
Highways in Developments – Design Considerations
The design and layout of all development proposals will, where appropriate, be required to include a range of criteria. Proposals which do not generate unacceptable levels of traffic on the surrounding road network and would not be detrimental to highway safety or cause significant harm to the amenity of residents will be permitted. Proposals which will not result in offsite congestion in terms of parking or service provision or where the capacity of the network is sufficient to serve the development will be permitted.
TR4
Cycling and Walking
Developments should, where appropriate seek to incorporate, or where acceptable, facilitate links to the cycle, rights of way and bridleway network to ensure an integrated sustainable approach in respect of any site.
REC2
Open Space Provision and New Developments
All new residential developments of five or more units will be required to provide on site open space in accordance with the Council’s adopted standards of 2.4ha per 1000 population.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 20 of 20 Ref. Title Summary
EQ4
Biodiversity
Proposals for development which have an adverse impact on priority species, habitats and features of recognised principal importance to the conservation of biodiversity and nature conservation, will not be permitted, except where it can be demonstrated that unless specific criteria can be met.
EP1
Water Quality and Resources
Proposals for development will be permitted where they do not lead to a deterioration of either the water environment and/or the quality of controlled waters. Proposals will, where appropriate, be expected to contribute towards improvements to water quality.
EP2
Pollution
Proposals for development should wherever possible seek to minimise the impacts of pollution. New developments will be required to demonstrate that they:
• Do not conflict with National Air Quality Strategy objectives, or adversely affect to a significant extent, designated Air Quality Management Areas;
• Do not cause a deterioration in water quality;
• Ensure that light and noise pollution are where appropriate minimised;
• Ensure that risks arising from contaminated land are addressed through an appropriate land investigation and assessment of risk and land remediation to ensure its suitability for the proposed use.
EP3
Sustainable Drainage
Proposals for development will be required to demonstrate that the impact of surface water drainage, including the effectiveness of incorporating Sustainable Drainage Systems (SUDS), has been fully investigated

Include Candidate Site reference SR/015/004 within the Plan as a housing allocation.

Land South of Cwmgarw Road, Brynamman – ref. T3/9/h4 / ref. SR/015/004

Please find enclosed, on behalf of and under instruction from our clients, Mrs H Wight, Mrs C Dudlyke and G Searles, a detailed Site Representation, submitted to Carmarthenshire County Council for consideration for inclusion / allocation / retention within the 2nd Revised Local Development Plan (LDP).
As required, to enter the site for evaluation within the LDP process at this stage of plan preparation, the following documentation is enclosed with this submission:
• Completed Online Representations Form;
• Site Location Plan;
• Illustrative Masterplan;
• 01C – Proposed Access
• 02B - Proposed Improvements; and
• Detailed case provided in an addendum below.
In addition to the enclosed documentation, a detailed case for the retained inclusion of the Site within the emerging LDP as a housing allocation is provided - which is requested to be carefully and thoroughly taken into consideration in appraising the Site Representation and the site’s credentials for inclusion within the new Development Plan. As well as promoting the retention of the existing allocation within the LDP (Option 1), this representation also seeks to allocate the wider land beyond the existing allocation (Option 2) – in line with Candidate Site ref. SR/015/004, and the existing adopted LDP site allocation ref. T3/9/h4 (or part thereof). As such, this representation comprises an objection to the Deposit Plan on the basis that the site is to be delivered as a residential development during the Plan period.
In the absence of any methodology for the assessment of new allocations, we have reverted to the criteria and methodology outlined within the Site Assessment Methodology (September 2022).
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 2 of 20 We look forward to hearing from you in due course. In the meantime, we hope and trust that all is in order with this submission. Please do not hesitate to contact us in the event that further information is required or considered beneficial.
Yours sincerely
Geraint John
Director
Geraint John Planning Ltd

Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 3 of 20 Preface
Previous representations were made in support of this site, on behalf of the clients, to set out a detailed case for the retention of the site’s allocation within the current LDP, and inclusion of the wider site beyond the existing allocation, in response to the 1st Deposit Plan consultation in 2020.
Carmarthenshire County Council have advised that representations / comments submitted as part of the consultation on the 1st Deposit LDP will no longer be considered. Only those submitted as part of the 2nd Deposit will be considered and forwarded to the Inspector. Any previous representations / comments must be resubmitted and reflect the content of the second Deposit LDP. As such, this submission seeks to ‘build on’ and update the previously submissions made.
Carmarthenshire County Council’s ‘Site Assessment Table’ has set out that the candidate sites / options ref. T3/9/h4 / ref. SR/015/004 submitted through the candidate site process have failed Stage 2b of the Site Assessment Methodology of the candidate site process, and therefore, are not to be progressed as residential allocations.
Separate to the LDP process, the site itself has been previously subject to two previous outline applications for residential development, both of which have been refused. These are as follows:
• PL/01036 – refused 30th July 2021; and
• PL/04459 – refused 17th February 2023.
These applications have sought permission for proposed residential use on the basis that the site benefits from an existing residential allocation with the Adopted Local Development Plan. The proposal has been supported by a comprehensive level of assessment work, to evidence the site’s credentials in that it is not physically constrained by any means. It is therefore considered that the site is deliverable, and would represent an acceptable form of sustainable development in this location – not least that it is allocated for residential use. Moreover, the principle of development is considered acceptable, by way of its existing allocation, and all other planning considerations relating to the site / proposal are addressed by way of detailed supporting material that accompanied the planning submissions.
The second application (ref. PL/04459) is of particular importance, in terms of how it relates to this representation, in that it forms the basis of setting out the acceptability of the site as an allocation for residential development. It is considered that the reasons for refusal are not insurmountable in any event, and by association, would not pose a constraint to the deliverability of the site. Supporting assessment work has evidenced the acceptability of the proposal, in light of the concerns raised that underpin the reasons for refusal.
Accordingly, this submission responds to and addresses the reasons of refusal of the latest application ref. PL/04459, to evidence support the site’s credentials as a residential allocation within the RLDP.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 4 of 20 Detailed Site Representation
As set out on the previous page, these representations object to the Deposit LDP on the basis of the lack of inclusion of deliverable sites. Those being:
(1) The retention of the existing allocation (ref. T3/9/h4) in the LDP;
(2) The allocation of Candidate Site ref. SR/015/004 – which includes LDP allocation T3/9/h4.
The above sites are illustrated on the maps below:
Existing Allocation T3/9/h4 – Option 1
SR/015/004– Option 2
The two options presented above were submitted in response to the previous Deposit Plan consultation in 2020 as potential candidate site options (submission can be found in Appendix B).
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 5 of 20 Carmarthenshire County Council’s ‘Site Assessment Table’ sets out the assessments and conclusions of each candidate site submitted through the LDP Review process. In respect of the candidate site submissions previously made (ref. T3/9/h4 and SR/015/004), the site passed Stage 1 and 2a of the assessment, but was considered to fail Stage 2b for the following reason:
“There are concerns at the deliverability of the site. The site represents a longstanding residential allocation (T3/9/h4) and no firm progress has been made on delivery. Sufficient residential opportunities exist within the settlement.”
The representations below, therefore, set out the objection as a whole against the non-inclusion of the 2 options presented, specifically in response to the reasoning above.
Site Description /Characteristics
This representation relates to the Land South of Cwmgarw Road in Brynamman. As noted above, the representation proposes two options:
1) The retention of the existing allocation (ref. T3/9/h4) in the LDP;
2) The retention of the existing allocation in the LDP, as well as the allocation of the wider land within the site promoters ownership surrounding this site for residential development (as per Candidate Site ref. SR/015/004).
A summary of the characteristics of the site and options is set out below:
• The site is a irregularly shaped greenfield space, consisting of fields and bounded by trees;
• The site promoted in Option 1 is approximately 2ha in area and represents a portion of a wider allocation (approx. 3.5ha total) for residential development in the current LDP;
• The site promoted in Option 2 is approximately 4ha in area and comprises of the land allocated for residential development in Option 1, as well as additional land to the south within the site promoters ownership;
• The site is accessed via two access points in its north-eastern and north-western corners, which are both within the ownership of the site owner;
• The southern and western boundaries of the site comprise of further greenfield land;
• The northern and eastern boundaries of the site consist of the rear gardens of the properties along Cwmgarw Road.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 6 of 20 Site Location Plan with Option 1 Filled in Blue and Option 2 Outlined in Red
Current Planning Status – Designation in the Adopted Local Development Plan
LDP Proposal Map Extracts
Option 1 Outlined in Red and Option 2 in Blue
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 7 of 20 Symbol Designation Symbol Designation
Development Limits (GP2)
Residential Allocation (H1)
Cycle / Proposed Cycle Route (TR4)
Recreation / Open Space (REC1)
Higher Proportion of Welsh Speakers (SP18)
Category 2 Sand and Gravel (MPP3)
Coal Primary Resource Zone (MPP3)
To summarise, the site is:
• Located within settlement limits of Brynamman;
• Allocated for residential development (ref. T3/9/h4);
• Situated within an area with a Higher Proportion of Welsh Speakers;
• In close proximity to an existing / proposed Cycle Route; and
• In proximity to Recreation / Open Space – situated to the north of the site.
The LDP contains a significant number of policies of potential relevance to any development of the site. The key policies of relevance to the site and any proposal are appended to this overview (Appendix A).
Candidate Sites: Assessment Criteria & Methodology
We are aware that, in appraising the credentials of sites for inclusion as an allocation in the Plan, a series of criteria and a methodology have been defined and adopted.
We are also aware that the appraisal process consists of multiple stages, summarised as the following:
• Stage 1: An assessment of the site and its compatibility with the Preferred Strategy;
• Stage 2a: Identification of fundamental site constraints that cannot be overcome or mitigated for;
• Stage 2b: Detailed, site specific assessment including an analysis of its sustainability, viability and deliverability, as well as the assessment of the site against a SA/SEA;
• Stage 3: The sites will be further assessed with a HRA to be carried out to ensure that the Deposit plan has no significant detrimental impact on European Designated Sites.
The stage 1 assessment, as set out within the Site Assessment Methodology (September 2019) included criteria to filter sites out where they may be contrary to National Policy, or unsuitable due to overarching constraints (unless sufficient information is provided to prove otherwise).. As set out above, the site is NOT any of the following designations:
• Sites of Special Scientific Interest;
• Special Area of Conservation;
• Special Protection Areas;
• Local Nature Reserves;
• National Nature Reserves;
• Historic Parks and Gardens;
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 8 of 20 • Scheduled Ancient Monuments;
• C1 and C2 Flood Zones;
• Coal Safeguarding Areas;
• Land Stability and Coal Mining Issues (That are not remediable for economic or other reasons);
• Hazardous Installation Facilities;
• Landfill Sites; and
• Areas of Contamination (That are not remediable for economic or other reasons).
According to the LDP Site Assessment table, the site was found to be compatible with the location of future growth presented within the Preferred Strategy and as a result passed Stage 1. The Candidate Site also went on to pass Stage 2a of the Site Assessment, having been found to have no fundamental constraints which cannot be overcome or mitigated for.
The candidate sites’ performance in these respects have been previously dealt with at both the Candidate Site Stage for the current LDP, prior to its allocation within the Plan, and at the same stage for the Deposit Plan and as a result will not be rehearsed within these representations.
The Site Assessment table outlines that the site failed the Stage 2b Assessment, with the comments noting that this was due to concerns regarding the deliverability of the site. The comments go on to state that ‘There are concerns at the deliverability of the site. The site represents a longstanding residential allocation (T3/9/h4) and no firm progress has been made on delivery. Sufficient residential opportunities exist within the settlement.”
As such, the representations below will relate to the assessment of the site at Stage 2b, highlighting its deliverability during the Plan period.
Key Issues
It is considered that the key arguments in support of the inclusion of the Candidate Site within the LDP for residential development relate to areas identified within the Site Assessment Methodology ‘Stage 2b’, relating largely to site deliverability – this being the sole concern raised within the Sites Assessment at this stage.
However, as previously stated, two separate applications have been made for this site, which demonstrates the clients’ willingness to deliver the site for residential development within the site. Whilst both applications have been refused, it is considered that the concerns associated with the proposal are not insurmountable, and with the support of further assessment work, these issues can be overcome, by way of a further planning application.
Accordingly, in respect of the ‘deliverability’ of the site, it is pertinent to consider the key Reasons for Refusal relating to the previous application (ref. PL/04459), and how this relates to the overall acceptability of the site. The following section sets this out in detail, explaining the reasons for refusal, as well as the clients’ response to how the issues can be overcome – warranting an acceptable candidate site submission for its inclusion / allocation / retention in the RLDP.
Planning Application (PL/04459)
As set out above, the key issues relating to the site’s credentials as a residential allocation within the RLDP relate to its ‘deliverability’. Two separate applications have been made to-date for the proposed development of the site under its current allocation.
The concerns and objections to the proposed residential use, which formed the reasons of refusal for the most recent application (ref. PL/04459), are set out in the table overleaf:
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 9 of 20 ‘Reason for Refusal’
Issue
Basis for concern
1
Fails to demonstrate suitable visibility, which would impact upon highway safety
• Double Yellow Lines are subject to a Traffic Regulation Order – which cannot be conditioned.
• Lack of information to confirm that adequate access and visibility is proposed.
2
Would result in a net loss of biodiversity
• Would have an impact on priority species and habitats, resulting in a loss of Section 7 habitats.
• Mitigation proposed is unsuitable.
3
Fails to provide any community benefits
a) No legal agreement has been committed to.
In light of the above reasons for refusal, it is considered expedient to set out a detailed response to each. Before doing so, it is necessary to make the point that the clients contend the view and position taken that the scheme is unacceptable in both highways and ecology terms (Reason for Refusal 1 – highway safety, and Reason for Refusal 2 – Ecology).
Lengthy discussions took place with the Highways Authority, before and during the application process, particularly with the Applicant’s highway consultant, to discuss all matters pertaining to highway safety. Highways design proposals were submitted to obtain feedback, and necessary amendments were made to reflect the changes request by the HA, to ensure that the scheme would be acceptable. Throughout this process, it was acknowledged that the proposed Double Yellow Lines (DYL) to secure the appropriate visibility splays, would be subject to a Traffic Regular Order – a separate consultation process. However, it was not considered expedient, nor appropriate to in any event, to commence this process until planning permission had been secured for the proposal. As such, it was considered that the requirement for a TRO could be conditioned upon any granting of the planning permission.
In respect of ecology, it is acknowledged and accepted that an alternative means of mitigation is required, given that the previous proposal would have not been acceptable – in that it would not have achieved a ‘net benefit’. The mitigation proposed comprised the translocation of existing Section 7 habitat species to a supplementary area (within the Applicant’s ownership) where the species were already present. Accordingly, it was deemed that no translocation could take place, and therefore, no net gain could be achieved. As such, alternative areas of mitigation within the Applicant’s control were required to offset any ecological impacts.
Finally, in respect of Reason for Refusal 3, it is considered that this will “fall away”, in that the necessary legal agreements can be agreed and implemented, to secure community benefits. Given the aforementioned issues were ongoing, it was not considered expedient to commence the drafting of legal terms until the position had been resolved, and was progressing to a favourable conclusion.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 10 of 20 Having set out these matters, the following responses are made in respect to each of the reasons for refusal.
Highways
The Decision Notice for this application set out that there were two elements of which the proposal was not acceptable under highway grounds, relating to:
a) Double yellow lines (DYL) as proposed are subject to a Traffic Regulation Order and would displace parking for existing dwellings; and
b) There is a lack of information to confirm that adequate access and visibility is being proposed.
The above matters are discussed further below.
a) Double Yellow Lines & displacement of parking
Double Yellow Lines
In relation the need to carry out a TRO, it was conceived that measures subject to a TRO could not be conditioned upon any permission, as it is a separate process. Specifically, the following is outlined on the Decision Notice:
‘Measures subject to a Traffic Regulation Order cannot be conditioned as they are subject to consideration under other legislation and there is no reasonable certainty that they will be found acceptable. This process should be undertaken at the developer’s expense prior to resubmission of any application.’
However, it is considered that a ‘Grampian’ condition could have been imposed upon any permission, which would seek to control the development, subject to a TRO being carried out, prior to works commencing on site / occupation. Specifically, the following condition working could have been utilised:
“The development hereby approved shall not be occupied until a scheme to provide Traffic Regulation Orders along Cwmgarw Road has been submitted to and agreed in writing by the Local Planning Authority. The works shall be completed in accordance with the approved details prior to any works commencing on site.”
In addition, WG Circular 016/2014, (Oct 2014) : ‘The Use of Planning Conditions for Development Management’ sets out the following when advising on Access conditions:
5.34
“A ‘Grampian’ condition can be used to prevent the commencement of development until certain highway improvements are made, if they relate directly to the development. TAN 18 (Transport) provides further advice with regards to such conditions.”
Moreover, Annex F of Tan 18 : Transport, set outs in para. F1 that
“Planning authorities may grant planning permission subject to a condition that development should not be commenced or occupied until some obstacle to the development has been surmounted (a ‘Grampian Condition). This may include the carrying out of highway works. A ‘Grampian’ condition may be necessary where works must be caried out in an existing highway in order to safely and efficiently accommodate traffic created by a development.” (GJP Emphasis).
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 11 of 20 Clearly, the imposition of a Grampian condition is supported by legislation and national policy, to ensure that highway issues relating to a development are not insurmountable, and are addressed in an appropriate manner. The highlighted text clearly demonstrates that Grampian conditions relating to highway works are acceptable, which is of course pertinent to the refused application i.e. carrying out of a TRO to implement DYL.
It should be recalled that it is considered that the TRO is to be needed to make the development acceptable in planning terms. The TRO will be confined to highway land / extent – which is always pre-supposed to be available to development to make an otherwise unacceptable position acceptable. CCC Highways are in control of the TRO, and having required its entering into in the first place cannot then determine that it is not possible or appropriate to enter into. This means that any condition meets the test of being necessary, reasonable, related, precise and enforceable etc.
The other point to make is that without a scheme there’s no need for a/the TRO. The latter therefore follows the former. This is the same principle and approach to all other regulatory regimes – building control following planning / licensing following planning. Without an approval to the development in the first place, these other regulatory processes have no meaning or purpose.
In summary, it has not been / is not considered expedient to commence the TRO process simultaneously to the application, given in any case it can be undertaken thereafter following approval, which, as evidenced above, can be controlled by condition.
Accordingly, in terms of how this relates to the promotion of the site as an allocation within the new Plan, the above evidences that the site is deliverable, in that the requirement to undertake a TRO can be actioned in any event, and is not an insurmountable issue that would deem the site undeliverable.
Displacement of Parking
It was raised by the HA that the proposed implementation of DYL, to the east of the proposed access, to ensure that appropriate visibility splays are achieved, would result in the displacement of existing residents’ parking.
It is noted that the existing arrangement comprises residents parking off Cwmgarw Road, along the pavements, which do not constitute formal off-road parking. The result of this existing arrangement poses a risk to highway safety, in that the width of Cwmgarw Road is narrowed, thus increasing the likelihood of car collisions across this stretch of the road. In addition, the pavement is also narrowed, culminating in a tight space for wheelchair uses and child push chairs i.e. vulnerable users, to use the pedestrian path.
The proposed alterative arrangement, as illustrated below, would address the existing highway safety concerns set out above, whilst also providing a safe means of parking for the residents. The proposal takes the form of providing safe and accessible parking along the bow access road into the development, off Cwmgarw Road.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 12 of 20 Proposed Access Arrangements
In total, there is capacity for 3no. cars to park along the access road, without causing any detriment to highway safety, and this would serve the two existing dwellings east of The Tregib Arms (public house). It is proposed that this stretch of the internal high network of the development is to be adopted, and therefore, there is no constraint proposed that would prohibit car parking here. Moreover, tactile paving is proposed near the access to facilitate safe pedestrian crossing from this stretch of road to the forementioned dwellings – to ensure that there is a link between the car parking and dwellings.
As such, it is considered that the parking proposals represents a safer and more appropriate arrangement than that of the existing, therefore, resulting in a betterment for highway safety.
b) Adequate access and visibility
To support the planning application submission, an Access Design was submitted, setting out the proposed access arrangements. As shown in the extract below, visibility splays of 2.4m x 43m can be achieved in either direction, which is considered to be appropriate for a 30mph road. This is supported by Manual for Streets guidance which sets out that under the assumption that 85th percentile traffic speeds are no more than 10% above the posted 30mph speed limit, visibility splays of 2.4m x 43m in each direction are required. As such, the proposed visibility splays comply with the pertinent guidance.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 13 of 20 Proposed Access Design
Of course, the proposed access design is subject to the TRO process, as discussed above, to ensure that parked cars do not impinge upon visibility for cars egressing the site. Specifically, the yellow lines will extend into the development site to remove parked vehicles from within the junction bellmouth, and allow vehicles on exit from the site to approach Cwmgarw Road correctly i.e. perpendicular to it.
As previously set out, it is considered that the TRO can be undertaken in any event, for the proposed DYL, and therefore, the proposed arrangement does not give rise to any highway concerns, in that it represents a safety improvement to the existing position.
In summary, the proposed site access junction provides sufficient visibility to ensure highway safety is not adversely affected by the development. The increase in traffic generated by the proposal is negligible, and therefore, will not cause any detriment to Cwmgarw Road.
Ecology
The Decision Notice (PL/04459) outlined that the proposal would have a negative impact upon biodiversity within the site, in regard to existing priority species and habitats. Specifically, the following is set out:
“The proposed development will have an adverse impact on priority species and habitats and result in a loss of Section 7 habitat, marshy grassland and broad-leaved woodland as well as loss of otter habitat (bramble) and dormouse habitat (dense scrub). Marshy grassland and broadleaved-woodland are habitats that appear on the Environment (Wales) Act 2016 Section 7 list of habitats of key significance to sustain and improve biodiversity in relation to Wales.”
To offset the loss of Section 7 habitats, it was proposed through the application that these would be translocated to the south-western area of the site, which would act as a ‘mitigation area’. Essentially, this comprised the proposed translocation of Marshy Grassland and the planting of Semi-Natural broad-leaved woodland.
However, it was advised by the Council’s ecologist that the proposed mitigation area already contained the Section 7 habitats, and therefore, translocation / planting could not be achieved as these habitats were already in-situ.
The clients have been in discussions with the scheme’s Ecologist in regard to exploring alternative areas of land, which have potential and capacity to accommodate the necessary translocation of the Section 7 habitats. The clients own a number of parcels of land that are within their control, which are located within the vicinity of the promotion site. It is considered that these parcels are sufficient in size in that they can meet the requisite ratios of planting and translocation, to mitigate the loss of the protected species within the site.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 14 of 20 Ecology surveys are to be undertaken of these parcels, to unequivocally confirm their suitability to act as a mitigation area for the development, however, a desk-based review has confirmed that there are no existing Section 7 habitats present within these sites – contrary to that of the previously proposed mitigation area.
Accordingly, it is considered that there are possible solutions to overcome this ecology issue, with neighbouring land having the potential to accommodate the required translocation of the Section 7 habitats. As outlined above, these lands are within the clients’ control, and therefore, it is considered that there are no legal issues associated with this possible approach. As such, the possible ecological impacts of the development can be mitigated for, to ensure that a biodiversity ‘net gain’ is achieved with the development of the site.
In light of this, it is conceived that the ecological position does not present a constraint to the deliverability of the site, as a proposed residential allocation within the RLDP, and therefore, is wholly acceptable in respect of this Reason for Refusal.
Legal Agreement
Finally, in respect of Reason for Refusal 3, the Decision Notice sets out that the proposal “does not contribute to the creation of sustainable places and spaces since the proposal has not been accompanied by a commitment to enter into a legal agreement to secure any community benefits.”
Given that discussions were ongoing between the Applicant and the LPA, in relation to the outstanding issues discussed above (i.e. highways and ecology), it was not considered expedient to undertake the necessary arrangements to prepare a legal agreement i.e. S106 agreement. It was acknowledged throughout the application process that contributions would be required, as part of the approval, following consultation responses received from statutory consultees.
Both the principle and the detail relating to the requested contributions were not disputed by the Applicants, nor would be in any event for a future application, as it is expected that a proposal of this nature and scale would warrant a S106 application – given the effects on the wider community.
Given the aforementioned issues were ongoing, it was not considered expedient to commence the drafting of legal terms until the position had been resolved, and was progressing to a favourable conclusion.
It is therefore considered that the securement of a legal agreement is not an insurmountable issue that would deem the development undeliverable, and therefore, would not impede upon the site’s allocation within the RLDP.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 15 of 20 Other Planning Considerations
Land Ownership
The site could make a realistic (and sustainable) contribution towards the provision of housing land within Carmarthenshire over the LDP period.
The land – representing a large portion of the site as allocated within the existing LDP – is wholly within the ownership of the site promoters, Mrs H Wight, Mrs G Searles and Mrs C Dudlyke, and no restrictions / constraints to the development of the site coming forward over the plan period are identified. The land is readily available to come forward for development, as evidenced by the proceeding sections.
Sustainability
Sustainability and Linkages with Nearby Settlements
As referred to above, the site is located within the settlement limits for Brynamman, which is identified as a Local Service Centre within the current local development plan. As a result, the site has close association and linkages with the facilities and services available within the settlement. A key destination for local residents is The Black Mountain Centre, which comprises a community centre including a café, post office, library and doctors surgery. Other services located within the settlement and within close proximity to the site include a number of public houses, places of worship, food / retail outlets and amenity / recreational facilities.
Pedestrian footways are provided on both sides of Cwmgarw Road with a general width of at least 1.5m, albeit with some instances of localised narrowing due to physical constraints or footway parking. There are also opportunities for cycling in the area, mainly consisting of on-carriageway routes although National Cycle Route 437 is accessible within 500m of the site, linking the site to Ammanford in the west and Cwmllwynfell in the east.
Evidently, the site is located in a highly accessible location, within easy and convenient walking distance of the services provided within Brynamman, with a range of facilities on offer. The site therefore benefits from being positioned within a highly sustainable location – which in light of the availability existing services and facilities, is considered extremely well-suited to residential development. It is considered that the services and facilities in close proximity to the site would facilitate and encourage the growth of the settlement in both a natural and sustainable manner.
Public Transport
The proposed development site is well served by public transport with a number of regular scheduled bus services running along Cwmgarw Road. Bus stops are available well within the recommended maximum walking distance of 400m from the application site, with travel via bus available in both directions near the site frontage.
The bus stops along Cwmgarw Road are served by service numbers X26, 64, 124, 167 and 905, providing services to Swansea, Upper Brynamman, Tycroes, Neath Abbey, Ammanford, Ystradgynlais, Crynant and Cwmtwrch Isaf.
In terms of rail transport, Ammanford railway station is located approximately 9.4km to the west of the site. Whilst not convenient for all, it could be used as part of a multi-modal journey along with a car, taxi, bicycle or bus.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 16 of 20 Flood Risk
The relevant extract from Natural Resources Wales’ Development Advice Map (DAM) (NRW) Flood Map is provided overleaf. This confirms that the representation site is not at risk of flooding.
Extract from NRW Flood Map
Key:
Heritage and Conservation
The Historic Wales website indicates that there are no Listed buildings or Scheduled Ancient Monuments on or within close proximity of the site. Moriah Chapel, situated in the north-eastern corner of the site, is contained as a National Monument Record for Wales and within the Welsh Archaeological Trusts’ Historic Environment Records as a post-medieval church. Given the residential setting of the chapel, the impact of the residential development of the site is expected to be negligible.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 17 of 20 Extract from NMR (Historic Wales)
Tree Preservation Order (TPO)
Carmarthenshire County Council’s online map indicates that there are no protected trees on site as illustrated below:
TPO Map Extract
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 18 of 20 A tree survey of the site has been carried out by ArbTS which will guide the form of development proposed at the site. It is considered that appropriate access, infrastructure and built form can be incorporated within the site without detrimentally impacting the existing trees on the site.
Summary and Conclusions
As outlined above, it is considered that the site is a highly suitable location for housing, and for inclusion as such within the emerging LDP at the Candidate Site stage. To summarise:
• The land lies within the settlement boundary for Brynamman, and within a defined ‘Local Service Centre’.
• The site (Option 1) is currently afforded a residential allocated status within the currently adopted LDP, and this should be considered as the baseline for the site.
• The Reasons for Refusal of planning application ref. PL/04459 are not considered to be insurmountable, in that they would culminate in the proposal being either undeliverable or unacceptable, therefore, representing an appropriate form of development.
• The development of the site would not unduly damage the character of the surrounding area, due to the site’s location within an existing residential area and its strong association with the settlement of Brynamman.
• The site benefits from a close association and connection with the services and facilities provided within Brynamman, which are situated within convenient walking distance (which would facilitate sustainable growth of the settlement).
• The sustainability and accessibility credentials of the site lend themselves to supporting residential development at this location – several bus stops are located immediately north of the site on Cwmgarw Road.
• The land is not identified as being of any special landscape / nature conservation / ecology interest – it is not afforded any such protection status within the current LDP; and
• It is considered that the inclusion of this land for residential development will assist the Local Authority in meeting their housing needs provision.
• The site is wholly deliverable and can realistically come forward within the early years of the Plan period.
• Object to the Deposit LDP on the grounds that the site isn’t included and is set to be delivered, as set out above.
We consider that the site ‘performs’ well against the defined assessment criteria and methodology, with no evident constraints, obstacles, or failings.
Our clients would be happy to discuss any aspect of the submission made and credentials of the site when your Authority (and the appointed Inspector in turn) comes to evaluate matters.
We respectfully urge you, for the reasons given herein and in the associated submitted information, to include the site put forward within the emerging LDP for housing development.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 19 of 20 APPENDIX A – CARMARTHENSHIRE PLANNING POLICY
Ref. Title Summary
SP1
Sustainable Places and Spaces
Proposals for development will be supported where they reflect sustainable development and design principles subject to a number of criteria.
SP2
Climate Change
Development proposals which respond to, are resilient to, adapt to and minimise for the causes and impacts of climate change will be supported subject to a number of criteria.
SP3
Sustainable Distribution – Settlement Framework
Provision for growth and development will be at sustainable locations in accordance with the settlement framework. Llanelli is identified as a Growth Area.
SP9
Transportation
Proposals should contribute to the delivery of an efficient, effective, safe and sustainable integrated transport system.
SP13
Protection and Enhancement of the Built and Historic Environment
Development proposals should preserve or enhance the built and historic environment of the County, its cultural, townscape and landscape assets and where appropriate, their setting.
SP14
Protection and Enhancement of the Natural Environment
Development should reflect the need to protect, and wherever possible enhance the County’s natural environment. All development proposals should be considered in accordance with national guidance/legislation and the policies and proposals of this Plan, with due consideration given to areas of nature conservation value, the countryside, landscapes and coastal areas.
GP1
Sustainability and High Quality Design
Development proposals will be permitted where they accord with a range of criteria.
GP2
Development Limits
Proposals within defined Development Limits will be permitted, subject to policies and proposals of this Plan, national policies and other material planning considerations.
GP3
Planning Obligations
The Council will, where necessary seek developers to enter into Planning Obligations (Section 106 Agreements), or to contribute via the Community Infrastructure Levy to secure contributions to fund improvements to infrastructure, community facilities and other services to meet requirements arising from new developments.
GP4
Infrastructure and New Development
Proposals for development will be permitted where the infrastructure is adequate to meet the needs of the development.
H1
Housing Allocations
Land has been allocated for residential development for the plan period 2006 – 2021 at those locations as set out in the LDP, and as depicted on the Proposals Map.
H2
Housing within Development Limits
Proposals for housing developments on unallocated sites within the development limits of a defined settlement will be permitted, provided they are in accordance with the principles of the Plan’s strategy and its policies and proposals.
AH1
Affordable Housing
A contribution to affordable housing will be required on all housing allocations and windfall sites. The Council will seek a level of affordable housing contribution of 30% in the higher viable areas, 20% in the middle viable areas, and 10% within the Ammanford / Cross Hands sub-market areas.
Where viability at the target levels cannot be achieved, variation may be agreed on a case-by-case basis.
TR2
Location of Development – Transport Considerations
States that proposals which have a potential for significant trip generation will be permitted where:
a) it is located in a manner consistent with the plans strategic objectives, its settlement framework and its policies and proposals;
b) it is accessible to non-car modes of transport including public transport, cycling and walking;
c) provision is made for the non-car modes of transport and for those with mobility difficulties in the design of the proposal and the provision of onsite facilities;
d) travel plans have been considered and where appropriate incorporated.
TR3
Highways in Developments – Design Considerations
The design and layout of all development proposals will, where appropriate, be required to include a range of criteria. Proposals which do not generate unacceptable levels of traffic on the surrounding road network and would not be detrimental to highway safety or cause significant harm to the amenity of residents will be permitted. Proposals which will not result in offsite congestion in terms of parking or service provision or where the capacity of the network is sufficient to serve the development will be permitted.
TR4
Cycling and Walking
Developments should, where appropriate seek to incorporate, or where acceptable, facilitate links to the cycle, rights of way and bridleway network to ensure an integrated sustainable approach in respect of any site.
REC2
Open Space Provision and New Developments
All new residential developments of five or more units will be required to provide on site open space in accordance with the Council’s adopted standards of 2.4ha per 1000 population.
Revised 2nd Carmarthenshire Local Development Plan April 2023
Candidate Site Representations:
Land South of Cwmgarw Road, Brynamman Page 20 of 20 Ref. Title Summary
EQ4
Biodiversity
Proposals for development which have an adverse impact on priority species, habitats and features of recognised principal importance to the conservation of biodiversity and nature conservation, will not be permitted, except where it can be demonstrated that unless specific criteria can be met.
EP1
Water Quality and Resources
Proposals for development will be permitted where they do not lead to a deterioration of either the water environment and/or the quality of controlled waters. Proposals will, where appropriate, be expected to contribute towards improvements to water quality.
EP2
Pollution
Proposals for development should wherever possible seek to minimise the impacts of pollution. New developments will be required to demonstrate that they:
• Do not conflict with National Air Quality Strategy objectives, or adversely affect to a significant extent, designated Air Quality Management Areas;
• Do not cause a deterioration in water quality;
• Ensure that light and noise pollution are where appropriate minimised;
• Ensure that risks arising from contaminated land are addressed through an appropriate land investigation and assessment of risk and land remediation to ensure its suitability for the proposed use.
EP3
Sustainable Drainage
Proposals for development will be required to demonstrate that the impact of surface water drainage, including the effectiveness of incorporating Sustainable Drainage Systems (SUDS), has been fully investigated

Amend Plan to include the site

This representation objects to the exclusion of this site and the existing development opposite from the development limits for the Black Lion Road part of Cross Hands. Its inclusion would form a natural ‘rounding off’ to this part of the settlement and would not lead to additional environmental pressure, instead fostering sustainable growth and allowing a wider choice of housing type within this Tier 1 Principal Centre. Its development would be in keeping and in character with the settlement and will ensure a readily deliverable source of future housing for this sustainable community. The proposed site offers a valuable development option in this part of Cross Hands.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints and its short term delivery is assured.
It is considered that this site is both sustainable and deliverable and can accommodate an appropriate form of development. The site is readily available and there is sufficient interest in the locality for development to take place within the early years of the plan period.
The inclusion of this land within revised development limits would be fully supported.

Amend the Plan to include the whole site

This representation comprises both an objection and a supporting submission. The proposer's land ownership at Cwmifor (a designated Tier 3 Sustainable Village) comprises an area of land ideally situated at the entrance to the village and opposite Cwmifor Village Hall.
A frontage portion (SuV51/h1) has already been identified as being suitable for residential development and has been included within development limits, the remainder of the land holding has however been excluded. The part-inclusion of this frontage portion is clearly supported, but an objection is hereby made to the exclusion of the remainder. The justification for including only part of the proposer's land will apply to the whole area.
The following objection is to the exclusion of the majority part of this site from the development limits for Cwmifor. A detailed planning application was submitted in respect of the objection site and which was to be reported to Planning Committee with a recommendation for approval. However, the day prior to that meeting, the application was held in abeyance, due to the decision of Natural Resources Wales (NRW) to impose phosphate discharge restrictions within the entire Tywi Valley SAC area.
It must be emphasised that the proposed scheme includes a key community benefit. The development of the full site will facilitate the provision of a community car park that will provide benefit to village residents and will ease on-road parking. The proposed parking area will be located immediately adjacent to the communal hub of Cwmifor – the village hall and Church. Existing parking provision in this locality is limited and therefore this community facility would be of considerable benefit.
The residential element of the scheme would comprise a high quality phased development and would draw on local Welsh vernacular architectural design elements, making every effort to be sustainable, both through the employment of local contractors, the use of local suppliers, and in the long term, through the provision of residential units within convenient walking distance of village services and facilities.
A frontage portion of the proposer’s land (SuV51/h1) comprises the only residential allocation within Cwmifor. It must be emphasised that the entire objection site is readily deliverable and would be entirely appropriate for a phased form of development.
The inclusion of the proposer’s land would not lead to additional environmental pressure, but instead will foster sustainable growth and allow for a wider choice of housing type within this Tier 3 Sustainable Village. Its development would be in keeping and in character with the settlement and will ensure a readily deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints and its short term delivery is assured.
The inclusion of this land within revised development limits would be fully supported.

Include candidate site SR/049/007 within the Plan as a housing allocation.

This representation objects to the exclusion of this site from the development limits for Drefach and seeks to secure the inclusion of an area of land off Heol Blaenhirwaun within the residential development limits for Drefach. Its development is supported by national planning policy.
Drefach is categorised as part of a Tier 1 Principal Centre but is only scheduled to receive a minor level of development. Given its strategic location, Drefach justifies appropriate level of suitable residential development. It offers a range of facilities and services that have a community focus, including primary and secondary education, healthcare provision, together with localised shopping facilities and other services. Drefach offers locational advantages similar to those of many other areas currently recommended to receive significant residential land allocations.
The objection site adjoins an existing bus route and is situated within walking and cycling distance of key facilities. A planning permission for residential development has been granted in respect of the field adjacent to the objection site and which is allocated within the current LDP.
The residential element of the scheme would comprise a high quality phased development and would draw on local Welsh vernacular architectural design elements, making every effort to be sustainable, both through the employment of local contractors, the use of local suppliers, and in the long term, through the provision of residential units within convenient walking distance of services and facilities.
The proposer’s land is in a more sustainable location than other residential allocations in Drefach and has the advantage of being readily deliverable to provide quality housing in the short term in this Tier 1 Principal Centre.
The inclusion of the proposer’s land would not lead to additional environmental pressure, but instead will foster sustainable growth and allow for a wider choice of housing type within Drefach. Its development would be in keeping and in character with the settlement and will ensure a deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints and its short term delivery is assured.
It is considered that this site is both sustainable and readily deliverable and its inclusion within revised development limits would be fully supported.

Include site within the Plan

Barratt David Wilson Homes South Wales Ltd (“BDW Homes”) does not consider that the Deposit Revised Carmarthenshire LDP is sound as the Plan will not deliver the required number and mix of housing over the Plan period, for the reasons we have stated on the online consultation form, in relation to the deliverability of the proposed site allocations.
BDW has prepared a site-specific representation in support of the proposed allocation of Land off Heol-y-Mynydd, Bryn for residential use within the Second Deposit Revised Carmarthenshire Local Development Plan. This was previously submitted at the Candidate Sites stage of the LDP's preparation together with a Candidate Site Assessment Questionnaire. It is supported by the following documentation, which confirm the site’s suitability for residential development:
- Site Boundary Plan by Roberts Limbrick Ltd (ref: 9047 PL01);
- Concept Masterplan by Roberts Limbrick Ltd (ref: 9047 SK01A);
- Issues & Opportunities Plan by Roberts Limbrick Ltd (ref: 9047 SK02);
- Drainage Technical Note by BDW Homes (August 2018);
- Extended Phase I Habitat Survey by TerrAqua Ecological Services Ltd (July 2018);
- Initial Landscape and Visual Appraisal by Anthony Jellard Associates (28th July 2018); and
- Technical Note by Lime Transport (ref: 18130, 11th June 2018).
The above documentation is enclosed with this representation.
It is respectfully requested that Land off Heol-y-Mynydd, Bryn is included within the Deposit Revised LDP as a residential allocation for up to 160 homes.

Covering letter:

Dear Sir /Madam,
Carmarthenshire Second Deposit Revised Local Development Plan
Representation on behalf of Barratt David Wilson Homes South Wales Ltd regarding Land off
Heol-y-Mynydd, Bryn (SR/086/053)
We are pleased to submit this representation on behalf of Barratt David Wilson Homes South Wales
Ltd (‘BDW Homes’) in response to the current consultation on the Carmarthenshire Second Deposit
Revised Local Development Plan Consultation for the site Land off Heol-y-Mynydd, Bryn. The site is
recorded in the 2023 Site Assessment Table under reference SR/086/053 (Land off Heol-y-Mynydd,
Bryn).
Barratt Homes has an option agreement for the site, which has been promoted in part for residential
development through the previous LDP process. This submission is also made alongside the recent
representations in response to the Carmarthenshire Revised Local Development Plan 2018-2033.
Candidate Site and Preferred Strategy consultations.
Executive Summary
• We do not support the Council’s Strategic Policy SP4 housing requirement of 8,822 homes for
the plan period (2018-2033). We consider the Plan Period should be rolled forward by a further
two years, to 2021-2036, to take into account the time lost owing to the NRW intervention and
COVID-19 pandemic.
• We do not support Policy HOM1 which includes a number of housing allocations located within
Phosphate Sensitive Catchment Areas. The Council should reconsider their spatial distribution
of housing allocations to include additional allocations outside of phosphate areas.
• Accordingly, Bryn can accommodate future growth requirements, and the land off Heol-y-
Mynydd, Bryn should be included as an allocation.
Page 2 of 7
We have set out our full response to the 2nd Deposit Revised Plan below as well as our response
which was submitted as part of the previous Deposit Plan.
Paragraph 5.6 – A Carmarthenshire of Cohesive Communities
BDW Homes welcomes the recognition of the impact of the lack of delivery of new housing upon the
creation of Cohesive Communities. The delivery of new homes and the maintenance of a five year
supply of housing is essential to ensure that Cohesive Communities are created in line with the Well
Being of Future Generations Act. It is therefore crucial that proposed site allocations within the Plan
are deliverable. This is essential to ensure that the Plan accords with Test of Soundness 3. As
identified in later sections BDW Homes raise a number of concerns regarding proposed Allocations
and their impact upon the Council’s proposed Trajectory and lack of deliverability which has effects
Cohesive Communities.
Paragraph 6.4
BDW Homes is supportive of the proposed Vision for ‘One Carmarthenshire’ as it seeks to achieve an
appropriate balance between environmental, economic, social and cultural objectives. The proposed
Vision therefore complies with the holistic ‘Placemaking’ approach advocated by Planning Policy
Wales (Edition 10, p.16). The Vision also accurately reflects the Well-being Goals set out within the
WBFGA. BDW Homes particularly welcomes direct references within the Vision to securing
prosperous, cohesive and sustainable communities and the economic aspirations associated with the
Swansea Bay City Region.
Paragraph 7.6: Strong Connections - Strongly connected people, places and organisations that
are able to adapt to change.
BDW Homes is supportive of the wording of Strategic Objective SO6, which seeks to ensure that ‘The
principles of spatial sustainability are upheld by directing development to sustainable locations with
access to services and facilities..’. This Strategic Objective is therefore consistent with the ‘Key
Planning Principles’ set out within Planning Policy Wales (Edition 10, p.18) which seeks to ensure that
the planning system contributes to the long-term economic well-being of Wales, by making use of
existing infrastructure and facilities.
Paragraph 7.6: Prosperous People and Places - To maximise opportunities for people and
places in both urban and rural parts of our county.
BDW Homes supports Strategic Objective SO10, which refers to the delivery of an appropriate number
and mix of new housing meet society’s needs. The need to ensure that “there is sufficient housing
land available to meet the need for new private market and affordable housing” is one of the key issues
within the ‘Active & Social Places’ theme within Planning Policy Wales.
Paragraph 8.2
BDW Homes agrees that the use of the WG 2018-based subnational projections (4,359 homes) would
impact upon the historic growth of the County and would not deliver the quantity of homes required.
To this end, BDW broadly Homes supports the Council’s Preferred Strategic Growth Option, the tenyear
trend-based projection which would allow for 8,822 homes, on the basis that it seeks an ambitious
Page 3 of 7
but achievable level of growth to support the aspirations of the Strategic Regeneration Plan for
Carmarthenshire. However, BDW feels that a higher level of growth should be sought on the basis of
the National Development Framework’s aspirations for the South West National Growth Area, with its
focus on the Llanelli Area and secondary town of Carmarthen.
Preferred Option – Balanced Community and Sustainable Growth Strategy
BDW Homes is broadly supportive of the ‘Balanced Community and Sustainable Growth Strategy’ and
note that the strategy considers the role and function of settlements in seeking to assign growth. This
should ensure that new housing is directed to those areas that are likely to attract higher levels of
employment generation. In this regard, it is considered that more growth could be accommodated
within the Llanelli and South Gwendraeth Area.
Paragraph 9.11
BDW Homes supports the strategy of building in flexibility to ensure the delivery of sustainable growth
and to overcome any potential unforeseen deliverability issues, in line with national guidance.
However, the Council should ensure that sites are viable and deliverable before they are taken forward
as firm allocations in the LDP. There are concerns about several sites and their ability to contribute to
delivering the housing growth projected over the Plan period. Paragraph 4.2.10 of PPW (Edition 10)
states that, “The supply of land to meet the housing requirement proposed in a development plan must
be deliverable.”
Paragraph 11.79
It is acknowledged that windfalls can make an important contribution to the overall housing
requirement for the County. However, in order to ensure the deliverability of the housing requirement
then sufficient sites should be identified and allocated to meet this requirement. Windfall sites are
unidentified by definition and therefore should form part of the flexibility allowance only.
Strategic Policy SP4: A Sustainable Approach to Providing New Homes
Draft Strategic Policy SP4 sets out the Council’s overall housing requirement of 8,822 homes for the
plan period (2018-2033) and so provision has been made for 9,704 new homes. Owing to the delays
caused by COVID-19, which has resulted in a second Deposit Plan consultation, we consider it
necessary for the plan period, currently set at 2018-2033 to be rolled forward to 2021-2036.
Consequently, the Authority should consider the need for a higher provision of housing to
accommodate the additional two years for the plan period. Carmarthenshire County Council (CCC)
have noted that they consider that the Deposit Plan meets the ‘Tests of Soundness’ and so is in
general conformity with Future Wales 2040. According to the Planning and Compulsory Purchase Act
2004 and set out within National Planning Policy, there is a fundamental requirement for any Local
Development Plan to be found sound. To ensure that this policy meets the tests of soundness and is
justified, and effective, those allocations located within phosphate sensitive areas should be removed
and replaced with sites located outside of these areas.
To this end, BDW consider the inclusion of housing allocations within phosphate sensitive areas in the
2nd Deposit Revised Plan to be unsound as it fails the Council’s own Test of Soundness in respect of:
Page 4 of 7
• Test 2 the housing allocations located within phosphate areas are not sufficiently robust or
flexible to ensure compliance with national policy as set out in Planning Policy Wales (PPW),
and;
• Test 3 in allowing the inclusion of phosphate sensitive housing allocations the plan will not be
implemented owing to the lack of an agreed mitigation measure for phosphorous sites. To this
end, the projected housing figure will not be met.
To ensure the consistent delivery of dwellings, it is considered that additional sites should be allocated
within the Draft LDP to provide a contingency, should some allocated sites fail to be delivered at the
rate set out within the housing trajectory. This would ensure the consistent delivery of homes
throughout the Plan period.
Policy HOM1: Housing Allocations
BDW objects to a number of proposed allocations owing to concerns in relation to their suitability and
deliverability. The previous Deposit Plan response in relation to HOM1 has been set out below:
PrC2/h4
No progress of effort has been made to bring the site forward for a prolonged period. The site is not
considered to be deliverable within the Plan period.
PrC2/h10
BDW objects to the proposed allocation of this site. We have serious concerns regarding its
deliverability. The site is a former quarry and is covered by dense vegetation with complicated access
arrangements which are affected by Flood Risk Zone C2 constraints. It has not been demonstrated
that this site can be accessed without unacceptable flood risk consequences. The site is also
brownfield in nature, and it should be demonstrated that appropriate ground investigation work has
been undertaken to demonstrate that the site is viable and deliverable. The site should be removed
as a draft allocation from the Deposit Revised LDP.
PrC2/h22
BDW objects to the allocation of this site. It comprises an existing allocation within the adopted LDP
which is proposed to be ‘rolled’ forward by CCC. There is no evidenced justification for the continued
allocation of this site, given that no progress has been made since its first allocation in 2014. The
delivery of this site has been pushed back a year in every JHLAS since at least 201, which confirms
the lack of progress and deliverability of this site. This site should be removed as a draft allocation
from the Deposit Revised LDP.
PrC2/h23
The site is not deliverable during the plan period. It has a number of constraints, is not sustainable in
terms of its location and it is not supported by a robust masterplan.
Sec5/h2
The site is constrained, is not viable and is not deliverable within the plan period.
Page 5 of 7
PrC3/h4
This is an historic allocation and there has been little progress in bringing the site forward for
development despite extensive marketing. The site is not deliverable within the Plan period.
PrC1/MU2
BDW is concerned that whilst this is a major urban extension to the south of Carmarthen, there is no
confirmation that an end user is in place in the form of a residential developer to deliver the quantum
of development proposed within the Plan period. The deliverability of this site is therefore questionable.
Phosphate Sensitive Catchment Areas
In addition to the above, BDW Homes wholly object to a number of additional housing allocations
which fall within Phosphate Sensitive Catchment Areas. A detailed list of these housing allocations
have been provided in Table 1: List of Housing Allocations in Phosphates areas, as well as our detailed
response to each of the proposed housing allocation. A number of the sites have been included as
housing allocations as they have gained planning permission. We do not agree with the inclusion of
these sites as they should be listed as commitments. Similarly, those allocations included as they have
a planning application submitted and pending should not be automatically included as an allocation.
This is contrary to the tests of soundness, as those allocations being rolled forward within phosphate
sensitive areas are currently not suitable nor deliverable owing to NRW phosphorous guidance.
With regards to CCC’s efforts to solve the phosphate issue within the County, investigative work has
been undertaken which forms part of the LDP evidence base. From reviewing this work, it is evident
that CCC have no agreed mitigation measure to tackle the phosphate issue. A nutrient budget
calculator has been constructed which calculates the phosphate levels that a proposed residential
development in Carmarthenshire could produce. This is not a mitigation measure and so
Carmarthenshire are yet to find a suitable phosphate solution.
In addition, a Nutrient Mitigation Options Technical Review (2022) has been prepared by Ricardo
Energy & Environmental, outlining guidance on phosphorous mitigation options for use in
Carmarthenshire. Although the report provides a short list and review of possible mitigation options no
set option has been agreed upon. The report concludes ‘it is likely that all schemes will require
engagement with/by CCC, Natural Resources Wales, the Nutrient Management Board and
developers. Other stakeholders like landowners/land managers, Dwr Cymru Welsh Water and
environmental NGOs are likely to also have a role in delivery of specific solutions.’
To this end, BDW Homes wholly object to the allocation of sites within Phosphate Catchment areas
owing to the County having no established mitigation solution for development in phosphate areas. As
such, all housing allocations which fall within phosphate sensitive areas should be discounted from
the LDP, as these suits are not suitable nor deliverable. Additional more suitable sites should be
sought which are located outside of the phosphate sensitive areas. Land off Heol-y-Mynydd, Bryn is
a suitable location for development, being located adjacent to the settlement of Bryn/Llanelli and
located outside a phosphate sensitive area.
Page 6 of 7
Candidate Site Assessment - Land off Heol-y-Mynydd, Bryn (SR/086/053)
From reviewing the Candidate Site Assessment Table 2023 it appears Candidate Site (SR/086/053),
Land off Heol-y-Mynydd, has been filtered out during the stage 2 assessment process, owing to
concerns at the over intensification of residential development within the immediate area and that the
site will remain outside of the development limits. We wholly object to this decision and perceive the
assessment of the site as contrasting information in relation to the site’s constraints. Owing to the
allocation of two other sites within the settlement of Bryn, Maes Y Bryn (PrC2/h21) and Harddfan
(PrC2/h20), CCC have confirmed Bryn is a suitable location for development. Both housing allocations
will total 40 dwellings combined. Given Maes y Bryn benefits from planning permission for 34 dwellings
and planning conditions are currently being discharged, this site should not count towards the housing
provision of Bryn. On this basis, the proposed allocation of Land off Heol-y-Mynydd would not cause
an over intensification of the settlement of Bryn.
The candidate site presents an opportunity for a logical continuation of existing residential
development in Bryn. The Candidate Site is located within a sustainable location close to a number of
facilities and good transport links. This is evidenced in the accompanying Technical Note prepared by
Lime Transport confirms that desirable walking distances for commuting and school journeys is 500m,
while the acceptable walking distance is 1km and 2km comprises the preferred maximum. The majority
of roads in the vicinity of the Site (including Heol-y-Mynydd) accommodate pedestrian facilities,
thereby linking the Site to all local services and facilities.
In terms of local services and facilities, the Site is situated approximately 400m from Bryn Community
Primary School and 3km from Bryngwyn School. The Site is also situated 1.6km from Llwynhendy
Health Centre, 600m from Bryn Post Office and 600m from Bryn Village Hall. The Site is also situated
approximately 1.5km from Llwynhendy, which provides a wide range of services including a library,
convenience store, public house and various takeaway restaurants, beauty salons and other retail
stores. Llanelli Town Centre is situated 4km from the Site and Parc Trostre Retail Park is situated 3km
from the Site, both of which provide a variety of services and employment opportunities.
With regards to public transport, Table 2.1 of the Technical Note by Lime Transport confirms that the
Site is situated in close proximity (ranging from 450m to 1km) to a number of bus stops which provide
regular services to Llanelli, Pontarddulais and Swansea among other destinations. Llanelli train station
is also situated approximately 4km to the south-west of the Site, which is served by bus routes 110
and 111 which operate within the acceptable walking distance of the Site.
The submitted LVA states that due to recent and ongoing housing developments in the area, the
development of Land off Heol-y-Mynydd would now represent a logical rounding off of the settlement
boundary. Accordingly, we consider that Llanelli / Bryn is capable of accommodating a significant
proportion of the County’s growth over the next Plan period, and this Site is capable of making a
significant contribution to this growth.
A concept masterplan has been prepared by Roberts Limbrick Ltd illustrating the site can
accommodate up to 160 dwellings, open space, landscaping and associated infrastructure. This
proposed scale of development would accord with the Deposit Plan in terms of the scale of strategic
Page 7 of 7
site required to deliver the housing requirement. Additionally, it is considered to be an appropriate
extension to the settlement in this location.
The site falls within Cluster 2: Llanelli and Southern Gwendraeth Area which has been identified as a
‘national growth area’ within Future Wales. To this end, with the potential for up to 160 dwellings to be
delivered, this site is genuinely deliverable and can contribute to the identified housing need within the
locality.
Final Remarks
Overall, BDW Homes raise a number of concerns regarding the current Preferred Strategy, including:
• We do not support the Council’s Strategic Policy SP4 housing requirement of 8,822 homes for
the plan period (2018-2033). We consider the Plan Period should be rolled forward by a further
two years, to 2021-2036, to take into account the time lost owing to the NRW intervention and
COVID-19 pandemic, and is contrary to Tests of Soundness 2 & 3.
• Significant objections are raised in relation to Policy HOM1 which includes a number of
housing allocations located within Phosphate Sensitive Catchment Areas. The Council should
reconsider their spatial distribution of housing allocations to include additional allocations
outside of phosphate areas.
Consequently, support is provided for Land off Heol-y-Mynydd, Bryn, which is deliverable and
developer lead, it has a developer on board and ready to take the site forward. Accordingly,
Bryn/Llanelli can accommodate future growth requirements, and the land off Heol-y-Mynydd, Bryn
should be included as an allocation.
We would be grateful if we could be kept informed on the further progress of the plan and further
opportunities for engagement.
Yours sincerely,
Katherine Dowdall
Principal Planner

Include site within the Plan under policy HOM1.

This representation objects to the exclusion of this site from the development
limits for Betws/Ammanford. Its inclusion would not lead to additional
environmental pressure, but instead will foster sustainable growth and allow
for a wider choice of housing type within this Tier 1 Principal Centre. Its
development would be in keeping and in character with the settlement and will
ensure a deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature
conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood
risk, hydrological, ecological, archaeological or land ownership related
constraints and its short term delivery is assured.
A full description of the site's development potential and merits has previously
been provided in the candidate site submission, to which reference should be
made.
It is considered that this site is both more sustainable and readily deliverable
than those other larger sites that have been allocated within the locality
(PrC3/h6 and PrC3/h36). A separate objection in respect of these two sites has been submitted.

The inclusion of this land within revised development limits would be fully supported.

Amend the Plan to include the site

This representation objects to the exclusion of this site from the development limits for Betws/Ammanford. Its inclusion would not lead to additional environmental pressure, but instead will foster sustainable growth and allow for a wider choice of housing type within this Tier 1 Principal Centre. Its development would be in keeping and in character with the settlement and will ensure a deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
· would not be detrimental to the amenity of adjacent properties;
· would satisfy recognised housing and sustainability objectives;
· would not have a detrimental impact on the landscape or nature conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints and its short term delivery is assured with necessary infrastructure available.
A full description of the site's development potential and merits has previously been provided in the candidate site submission, to which reference should be made.
It is considered that this site is both more sustainable and readily deliverable than those other larger sites that have been allocated within the locality (PrC3/h6 and PrC3/h36). A separate objection in respect of these two sites has been submitted.
The inclusion of this land within revised development limits would be fully supported.

Allocate site for housing in the Plan.

This representation objects to the exclusion of this site from the development limits for Pontargothi. Its inclusion would not lead to additional environmental pressure, but instead will foster sustainable growth and allow for a wider choice of housing type within this Tier 3 Sustainable Village. Its development would be in keeping and in character with the settlement and will ensure a deliverable source of future housing for this sustainable community.
In addition, residential development at this location:-
• would facilitate the provision of an extended car parking area for the village hall, as well as an alternative and safer access to the A40;
• would not be detrimental to the amenity of adjacent properties;
• would satisfy recognised housing and sustainability objectives;
• would not have a detrimental impact on the landscape or nature conservation interests.
Furthermore, the site is not impeded by any access, ground condition, flood risk, hydrological, ecological, archaeological or land ownership related constraints and its delivery is assured.
A full description of the site's development potential and merits has previously been provided in the candidate site submission, to which reference should be made.
It is considered that this site is both sustainable and deliverable and offers a valuable development option within this Tier 3 Sustainable Village.
The inclusion of this land within revised development limits would be fully supported.

Amend the Plan to include the site

The site consists of gently sloping agricultural pasture land situated adjacent
to the existing LDP boundary.

The site has good access from the main B4299 and good visibility splays for a
development of this size.

All utilities and services are close at hand and have capacity for a development
of this size.
The site does not have any adverse ground conditions that may obstruct
development.

The site currently has a natural hedge bank boundary and it is not envisaged
that any works will be required to the boundaries.
We are not aware of any protected trees or wildlife within the site.

Allocate candidate site SR/086/007 for housing in the Revised LDP.

Please see attached documents

Amend the Plan to include the site

The site consists of gently sloping agricultural pasture land situated adjacent
to the existing LDP boundary.

The site has good access from the main B4299 and good visibility splays for a
development of this size.

All utilities and services are close at hand and have capacity for a development
of this size.
The site does not have any adverse ground conditions that may obstruct
development.

The site currently has a natural hedge bank boundary and it is not envisaged
that any works will be required to the boundaries.
We are not aware of any protected trees or wildlife within the site.

Amend the Plan to include the site

The site consists of gently sloping agricultural pasture land situated adjacent
to the existing LDP boundary.

The site has good access from the main B4299 and good visibility splays for a
development of this size.

All utilities and services are close at hand and have capacity for a development
of this size.
The site does not have any adverse ground conditions that may obstruct
development.

The site currently has a natural hedge bank boundary and it is not envisaged
that any works will be required to the boundaries.
We are not aware of any protected trees or wildlife within the site.

Include site for housing within the development limits for Brynamman.

Change of Development Limits at field at Caenewydd Farm, off Arfryn Estate, Mountain Road, Upper Brynamman, Ammanford. Please see attached document.

Include Candidate Site reference SR/067/007 as an allocation within the Plan.

The LDP is unsound on the basis that insufficient deliverable housing land has
been allocated in the Ammanford/Cross Hands Principal Centre for the Plan period
up to 2033. The housing land allocated in the Plan for this area include sites that
have historically been allocated for residential development in the County's current
LDP and previous UDP, but have still not been developed. For example, the Emlyn
Brickworks site in Penygroes has been the subject of limited residential
development despite being allocated for housing in the County’s previous
development plans. Similarly, land at Tirychen Farm in Ammanford has been
allocated for 150 dwellings in the Plan despite having historically been allocated
for residential development in the LDP and UDP, and not having been developed
to date. There are clearly barriers that are preventing the delivery of these historic
housing allocations and their continued allocation with the County’s Development
Plan is at odds with the objectives of Planning Policy Wales which states that the
supply of land to meet the housing requirements of the County must be
deliverable. The allocation of sites that are not deliverable within the Plan period
will result in a shortfall of housing land in the County.

The inclusion of Land adjacent to Crud-Yr—Awel, Black Lion Road within the
development limits of Black Lion Road in Gorslas will provide land for up to 4-5
dwellings that will assist in meeting this shortfall in housing land. its inclusion.
within the development limits of Black Lion Road, together with the neighbouring cluster of five existing properties either side, will serve to round-off this part of the
settlement while providing an infill development opportunity, between existing
residential developments? The land consists of part of an existing field enclosure
that is not currently in agricultural use nor or any ecological or biodiversity value. It
would provide a small number of self-build plots and an opportunity for local
people to build their own home in the settlement in contrast to the larger housing
sites allocated in the Plan that are invariably acquired and delivered by
developers, rather than on a self—build basis. The land is level and devoid any
constraints, having easy access to the existing utility services along the roadway,
including the public sewer and electricity and gas supplies. it has easy access to
public transport facilities being on a bus route and within a short walking distance
of existing bus stops that can be easily accessed by the pedestrian facilities along
Black Lion Road. It is located within the 30mph speed limit in the settlement and
benefits from easy access onto the roadway with good visibility in both directions
given the alignment of the road. The site is also well related to the existing retail
and employment facilities in Cross Hands Business Park and Cape! Hendre
Industrial estate having active travel links to both- It is also within walking distance
of the local primary and secondary schools in Gorslas, Cefneithin and Penygroes,
as well as the doctor’s surgery and pharmacists in both Penygroes and Cross
Hands.