Include Candidate Site reference SR/004/022 in the Plan

Further to the publication of the above document, we have been asked by our Client to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the
proposed provisions of Policy HOM1 are of particular interest to our Client. As a result, we
offer the following for the Authority’s consideration, and Inspector’s in due course.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/004/022, seeking the allocation of their land for future residential development within the
defined settlement limits of Ammanford/Betws as part of the Replacement Local
Development Plan. The Candidate Site (edged red below) comprised of a single existing
enclosure and an associated residential property with all boundaries clearly and well defined.

Plan A

As a result of this, existing residential development and their associated curtilages are
positioned directly to the north east, north west and south east. The site is also within close
proximity to the range of community facilities and local services the settlement and greater
urban area of Ammanford has to offer.
Following its due consideration, the Council then excluded the Site from the proposed
development limits for Ammanford/Betws in its 1st Deposit LDP, published in January 2020
(Plan B).

Plan B

In explaining its decision to exclude the site and not allocate it for residential purposes, the
Council advised in its ‘Site Assessment Table’ (January 2020) as follows:
“There is sufficient and more suitable land available for residential development within the
town to accommodate its housing need.”.

At the time of publication of the 1st Deposit LDP therefore, the only reason presented by the
Council for the exclusion of the site from the development limits and its non-allocation for
residential development, was on the basis that the Council considered there to be sufficient
alternative sites within the town to accommodate the housing need.

As part of the current consultation process into the 2nd Deposit LDP, the Council have again
published a “Site Assessment Table” (2023), which provides details of the Council’s analysis
of each received Candidate Site submission. We note that our Client’s land was considered
as part of this process and as a result the Council concluded as follows:

“There is sufficient and more suitable land available for residential development within the
town to accommodate its housing need. Access to the site would likely necessitate the
demolition of property likely to cause some disturbance to neighbouring properties. It is
unclear whether suitable visibility splays can be achieved.”

As can be seen, the initial rationale presented by the Council mirrors that at the 1st Deposit
LDP stage (housing land supply), but now the Council have questioned the means of access
to the site. Both reasons presented are puzzling, particularly the latter as the Candidate Site
submissions include a full Transport Statement that included new access provisions to serve
the site, in-line with the highway authority’s requirements. The proposed arrangement is
reproduced in Plan C below.

Plan C

It should of course be further noted that as a result of changes being brought in by the Welsh
Government later this year, the required level of visibility for new access will be reduced
even further. Unfortunately, it appears that in their assessment of the Candidate Site, the
Council have failed to take this and the submitted information into consideration. As a result
of this and the reasons above, we consider the sites exclusion to be an illogical and
erroneous decision by the Council and consider therefore that the LDP as it stands is
“unsound” and fails to meet the required Tests of Soundness.

Specifically, we consider that alternative allocations within the settlement and wider Principal
Centre are neither appropriate nor deliverable. We consider therefore that the land edged
red in Plan A, should be allocated for residential development under the provision of Policy
HOM1 of the Carmarthenshire Local Development Plan.
This formal representation letter supplements the following documents which comprise a
complete submission to the 2nd Deposit LDP Consultation stage:

- Completed Deposit LDP Representation Form
- Completed Integrated Sustainability Appraisal form
- Copy of Candidate Site Submission Report (August 2018)
- Ecological Appraisal
- Transport Statement

Response to Council’s Reasons for Non-Allocation of Site
Sufficient Residential Land Allocated Within Settlement
Part of the Council’s rationale for the non-allocation of the site for residential development is
on the basis that it considers that alternative allocations within Ammanford/Betws and the
wider Principal Centre it forms part of will deliver sufficient housing for the town during the
Plan period.

Under the current provision of the Deposit LDP, the Principal Centre has a range of
proposed residential allocations. Having undertaken a comprehensive review of the
proposed allocations put forward by the 2nd Deposit LDP for the Principal Centre in question,
it has been identified that a number have significant questions over their ability to be
delivered within the Plan period, including the following:

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

Table 1

As a result of the above – all of which have been allocated in previous development plans -
separate objections to their inclusion with the LDP have been made. This is due to the fact
that to continue to allocate such sites for residential development results in the Plan being
unsound. Alternative sites, such as that put forward by our Client, must therefore be
considered and brought forward in order to address this deficiency and ensure that the Plan
is sound in all respects.

In conclusion, this Representation to the 2nd Deposit Draft of the Revised LDP has sought to
examine the Council’s reasons for non-allocation of a Candidate Site. It has successfully
addressed the reasons put forward by the Authority for its exclusion and has highlighted that
currently proposed allocations are undeliverable.

We therefore respectfully request that this Representation be given careful examination, and
consequently the land in question be allocated for residential development as part of the
Carmarthenshire Local Development Plan to ensure that the document passes all the
relevant tests of soundness.