Testun llawn:
Further to the publication of the above document, we have been asked by our Client to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the
proposed provisions of Policy SD1 are of particular interest to our Client. As a result, we
offer the following for the Authority’s consideration, and Inspector’s in due course.
Our client made a formal Candidate Site Submission in August 2018, which was referenced
SR/064/004, seeking the inclusion of the land within the defined development limits of
Glanaman as part of the Replacement Local Development Plan. The Candidate Site (edged
red below) included two small parcels of land, set either side an existing residential property
with its associated hardstandings and outbuildings, being the core of an associated
smallholding.
Plan A
All boundaries of the Candidate Site were and continue to be well defined, with the public
highway (Mountain Road) then running along its north eastern boundary. The site then
continues to be within walking distance to the range of community facilities and local
services the adjoining settlement has to offer, as well as well serviced bus stops that provide
access to those services and facilities in the wider growth area.
Following its due consideration, the Council then included within the development limits the
south eastern two thirds of the land in question in its 1st Deposit LDP, published in January
2020 (Plan B).
Plan B
In explaining its decision to exclude part of the site, the Council advised in its ‘Site
Assessment Table’ (January 2020) as follows:
“Part of the site is considered appropriate for small scale rounding off, and the development
limits will be drawn to incorporate this element. In terms of the remainder of the site, it is
considered that there is sufficient and more suitable land available for development within
the settlement to accommodate the housing need.”
What was apparent therefore from the above was that the Council had assessed the
Candidate Site on the basis of its potential as a residential allocation – i.e. a site capable of
accommodating 5 units. Those sites put forward for less than this number by means of
seeking an amendment to the defined development limits therefore largely failed a number
of the stages of the assessment by default.
As part of the current consultation process into the 2nd Deposit LDP, the Council have again
published a “Site Assessment Table” (2023), which provides details of the Council’s analysis
of each received Candidate Site submission. We note that our Client’s land was considered
as part of this process and as a result the Council concluded as follows:
“Part of the site is considered appropriate for small scale rounding off, and the development
limits will be drawn to incorporate this element. In terms of the remainder of the site, it is
considered that there is sufficient and more suitable land available for development within
the settlement to accommodate the housing need.”
As can be seen, the process of assessment of our Client’s land by the Council has remained
unchanged, and whilst we support the inclusion of part of the land within the development
limits defined by Policy SD1, we consider the exclusion of the remainder of the site to be an
erroneous decision by the Council, as well as being an inconsistent approach taken by it in
the assessment of such sites. We therefore consider that the LDP is “unsound” and should
be changed, as it fails to meet the tests for “soundness”.
Specifically, we consider the approach of assessment taken by the Authority has been
inconsistent in terms of (a) other policy approaches taken by the Deposit LDP and (b) in
relation to other examples that were successfully included within defined development limits
of the 2nd Deposit LDP. We consider therefore that the whole of the land edged red in Plan
A, should be included within the defined development limits for Glanaman under the
provision of Policy SD1 of the Carmarthenshire Local Development Plan.
This formal representation letter supplements the following documents which comprise a
complete submission to the 2nd Deposit LDP Consultation stage:
- Completed 2nd Deposit LDP Representation Form
- Copy of Candidate Site Supporting Letter (August 2018)
- Copy of Candidate Site Location and Layout Plan (August 2018)
Response to Council’s Reasons for Non-Allocationof Site
Consistency with Other Policies of the Deposit LDP
The Council has provided no specific indication or guidance on how it has determined and
defined development limits within the 2nd Deposit LDP. It has therefore been difficult to
ascertain why some sites have been successfully included and others haven’t, which is
discussed further below. However, Policy HOM3 deals with small extensions to existing rural
villages and so provides a useful series of criteria in determining where such extensions
would be acceptable, namely the following:
Minor infill or a small gap between the existing built form; or
Logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
Conversion or the sub-division of large dwellings.
It is logical therefore that the same assessment criteria should be utilised in assessing
whether or not a candidate site would make an acceptable addition to existing development
limits (A separate representation with regards to Policy SD1 has been made on this basis).
Taking all our Client’s land into consideration, together with the actual ‘on-the-ground’
physical attributes of adjoining and nearby land and its use, it is clear that it would adhere to
the second criteria listed above and so should in turn have been included within the defined
development limits of Glanaman. Its exclusion would be inconsistent with the provisions of
Policy HOM3 and indeed decisions taken by the Council with regard to other sites within the
Plan area. As a result and on this basis alone, the Plan as it currently stands is unsound.
Consistency with Other Settlement Limits
Consistency in approach and application is critical in order for the planning system to be
both effective and credible to all its users. Without it, the system itself becomes unsound and
in the case of the determination of the development limits for Glanaman, the Council has
been found to be inconsistent.
The plans below are an extract of the 2nd Deposit LDP Proposals Maps for two areas
(indicated by the red star) at the eastern and western edges of Garnant.
Plan C
Plan D
As can be seen, although both areas are defined by strong boundary features, neither have
a developed form. In addition, the area shown on Plan C, the land on the opposite side of
the adjoining public highway from the site is predominantly undeveloped and the area of
‘white land’ in question also does not have any planning history, but its inclusion within the
limits will extend the existing form of the settlement in a western ‘ribbon-like’ manner.
It should be noted that we do not object to the form of alteration to the development limits as
referred to above, as it secures a varied form of available housing development opportunities
for a community. However, their inclusion are in direct contrast and inconsistency to the
Council’s decision to exclude our Client’s land as a whole from the development limits.
Combined with our Client’s land representing a logical rounding-off of the respective area of
the settlement, the exclusion of it would represent a clear inconsistency in approach taken
by the Council, resulting in the Plan as it stands being unsound.
In conclusion, this Representation to the 2nd Deposit Draft of the Revised LDP has sought to
examine the Council’s reasons for non-inclusion of a Candidate Site within the defined
development limits. It has successfully addressed the reason put forward by the Council for
its exclusion and highlighted that its continued exclusion would represent a dangerous
inconsistency.
We therefore respectfully request that this Representation be given careful examination, and
consequently the land in question be included within the defined development limits as part
of the Carmarthenshire Local Development Plan to ensure that the document passes all the
relevant tests of soundness.
