Include site within development limits

Land off Black Lion Road, Gorslas.

Further to the publication of the above document, we have been asked by our Clients to review its contents, policies and proposals and advise them of any aspects we believe would unreasonably affect their aspirations and interests. In doing so, we consider that the proposed provisions of Policy SD1 are of particular interest to our Clients. As a result, we
offer the following for the Authority’s consideration, and Inspector’s in due course.
Our Clients made a formal Candidate Site Submission in August 2018, which was
referenced SR/067/006, seeking the inclusion of the land within the defined development
limits of Gorslas as part of the Replacement Local Development Plan. The Candidate Site
centred mainly on a small paddock of poor agricultural land that fronted onto Black Lion
Road (edged red on Plan A), together with existing residential properties on the opposite
side of the highway.

Further agricultural enclosures are positioned to the east, but residential development is
located directly to the land’s north and on the opposite side of Black Lion Road to the west.
The site is also within walking distance to the range of community facilities and local services
the settlement and larger settlement of Cross Hands has to offer, as well as well serviced
bus stops that provide access to those services and facilities in the wider growth area.
As part of the preparation of the 1st Deposit LDP, the Council then considered the
submissions made and provided a summary of its assessment in its ‘Site Assessment Table’
(January 2020), which read as follows:
“Development of the site would result in a ribbon pattern of development contrary to general planning principles.”
As a result, the proposed 1st Deposit LDP made no changes to the development limits in the
environs of the Candidate Site to those forming part of the current adopted LDP, as illustrated by the Proposals Map extract below.

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

As can be seen, the process of assessment of our Client’s land by the Council has remained
unchanged, as has its and the properties opposite’s exclusion from the development limits.
We however 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 Council 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
and the existing 4 properties opposite, should be included within the defined development limits for Gorslas 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 2
nd 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 our Clients 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 Gorslas. 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 Development 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 Gorslas and other settlements,
the Council has been found to be inconsistent.

The plans below are an extract of the 2
nd Deposit LDP Proposals Maps for two areas
(indicated by the red star) in the settlement of Llandybie and Llanwrda.

In the case of the Llandybie example, two separate parcels of undeveloped land have been included within the defined development limits, that extend the existing form of the
settlement in a southern ‘ribbon-like’ manner. The Llanwrda example is then an element of an existing larger agricultural enclosure, with two of its boundaries therefore currently
undefined and so extending the existing settlement’s limits beyond existing boundaries.

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 is in direct contrast and inconsistency to the
Council’s decision to exclude our Clients land and the aforementioned existing properties