Include site within the Plan

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 HOM1 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/132/008, seeking the allocation of their land for future residential
development within the defined settlement limits of Penygroes as part of the Replacement
Local Development Plan. The Candidate Site (edged red below) comprised in effect of two
existing enclosures, split by a stock proof fence and public footpath.

Plan A

It should be noted that the adjoining development was constructed by our Clients and so
they have a recent proven development track record of delivering residential development in
the area. The site is then within close proximity to the range of community facilities and local
services the settlement has to offer.
Following its due consideration, the Council then excluded the Site from the proposed
development limits for Penygroes 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:

““Inclusion of the site would contribute towards the coalescence of two villages contrary to
general planning principles.”

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 the development of
the site would lead to the coalescence of two villages. However, as can be seen from Plan A
and Plan B above, this is clearly not the case.

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:
“Inclusion of the site would contribute towards the coalescence of two villages contrary to
general planning principles. .”

As can be seen, the initial rationale presented by the Council replicates that at the 1st
Deposit LDP stage, but it is still considered that the reasoning given is illogical. Using the
relevant extract of the 2nd Deposit Proposals Map and highlighting in red the Alternative Site,
it can be seen that even with its development, a gap would remain between the southern
most limits of Penygroes and the northernmost limits of Capel Hendre.

Plan C

It is quite clear therefore, that the development of the Alternative Site would not lead to the
coalescence of two villages and as a result of this, 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. This is particularly
worrying, in view of the lack of deliverable allocations within the Principal Tier of which the
Alternative Site forms part of (please 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 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 Sustainability Appraisal form
- Copy of Candidate Site Submission Report (August 2018)
- Copy of Ecological Appraisal Report

Response to Council’s Reasons for Non-Allocation of Site
Sufficient Residential Land Allocated Within Settlement
We understand from discussions with Officers that part of the Council’s rationale for the nonallocation
of the site for residential development is on the basis that it considers that
alternative allocations within Penygroes and the wider Principal Centre it forms part of will
deliver sufficient housing for the area 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 Clients, 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
the reasons given are illogical and erroneous. In addition, it has been highlighted in
conjunction with our submissions made by this Practice, that the currently proposed
allocations put forward by the 2nd Deposit LDP 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.