Allocate site for housing within the Revised LDP.

Further to the publication of the above document, we have been asked by our Client to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so, we consider that the
proposed provisions of Policy HOM1 and Policy SG1 are of particular interest to our Client.
As a result, we offer the following for the Authority’s consideration, and Inspector’s in due
course.

Our clients made a formal Strategic Candidate Site Submission in August 2018, which was
referenced SR/082/012, seeking the allocation of their land (edged red on Plan A) for a mix
of residential development, areas of formal and informal amenity space, together with an
area preserved for ecological interests, as part of the Replacement Local Development Plan.

Plan A

The site would serve the settlement of Llandybie and the surrounding area of the associated
Principal Centre (Cluster 3). The Strategic Candidate Site comprised of a series of existing
enclosures, with vehicular access gained directly off Blaneau Road, which runs along its
northern boundary. From a locational perspective, the site is also within close proximity to
the range of community facilities and local services the adjoining settlement and surrounding
area has to offer, as well as being in close proximity to a number of well served bus stops
that provide access to those services and facilities found in the wider region.

Following its due consideration, the Council then excluded the Site from the proposed
development limits for Llandybie 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:

“The site has been identified as being at high risk of flooding in the Revised Carmarthenshire
LDP SFCA. There are other more suitable sites available which can meet the housing needs
of the village.”

The above decision was somewhat puzzling and in our view erroneous, as (a) the SFCA
was wrong to exclude the whole of the site from consideration (the area of the Site within the
flood zone was minimal) and that (b) alternative allocations within the settlement and wider
growth area were clearly neither appropriate nor deliverable.

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:

“The site has been identified as being at high risk of flooding in the Revised Carmarthenshire
LDP SFCA (2019). There are other more suitable sites available which can met the housing
needs of the village.”

As can be seen, the rationale presented by the Council replicates that at the 1st Deposit LDP
stage (flood risk and housing land supply), although when examined fully, they appear both
illogical and erroneous.
Plan C and Plan D below provide an indication under the provisions of Technical Note 15:
Development and Flood Risk of the considered current and emerging risk of flooding in
relation to the Site.

Plan C Plan D

(Development Advice Maps) Flood Maps for Planning)
As can be seen, less than 5% of the total area of the Site is considered to be at risk of
flooding. Furthermore, as illustrated on the submitted Indicative Layout Plan, none of this
area is required to deliver the mix of development put forward for the Site and so the Council
have undertaken an incomplete and clearly erroneous assessment of the Alternative
Strategic Site. As a result of this and the reasons below, 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 (see below). We consider therefore that the
land edged red in Plan A, should be allocated for residential development under the
provision of Policy HOM1 and Policy SG1 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
- Indicative Master Plan

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 Llandybie 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 and that the Council’s assessment of the
Alternative Strategic Site was flawed.

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