Allocate the whole site for housing in 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 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/159/006, seeking the allocation of their land for residential development within the
defined settlement limits of Tycroes as part of the Replacement Local Development Plan.
The Candidate Site (edged red below) comprised in effect of two elements – a now complete
residential development for 37 units in its western half and an undeveloped parcel of poor
agricultural land in its eastern half.

Plan A

It should be noted that the adjoining development retained provision to provide access to the
eastern half of the site, whilst access was also possible via the demolition of two properties
to its north, as illustrated below.
Plan B
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 allocated the Candidate Site for residential
development in its 1st Deposit LDP, published in January 2020 (Plan C).

Plan B

Allocated under reference PrC3/h32, the allocation in its totality was expected to deliver a
total of 62 units within the first 10 years of the Plan’s lifetime.

Notwithstanding the above decision, and for reasons well known, the Council then revisited
its 1st Deposit LDP in preparation of a second version. As part of the preparation process for
the 2nd Deposit LDP, the Council have published a “Site Assessment Table” (2023), which
provides details of the Council’s analysis of each received Candidate Site submission,
including that subject of this objection. We note that our Clients land was considered as part
of this process and as a result the Council concluded as follows:

“The site is to be partly allocated for residential development. Site reference is PrC3/h32.”

According then to the 2nd Deposit LDP Proposals Maps, now only the western half of the
original Candidate Site is allocated for residential development (37 units) as illustrated in
Plan D, despite construction on this element of the Site having been completed in 2022.

Plan D

Other than the text quoted above, the Council have provided no explanation for the removal
of the eastern half of the Site from the allocation, or its reduction from 62 units to 37 units.
They have raised no highway, ecological, utility or viability reason for its exclusion. This is
not only illogical, but also appears to be a dangerous and erroneous decision to make,
particularly in light of the level of under provision of deliverable housing sites within the Plan.

As a result of this decision we therefore consider that the LDP as it stands is “unsound” and
fails to meet the required Tests of Soundness. As detailed, 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 all 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
As detailed above, we are deeply concerned with the Council’s decision to reduce the
proposed housing allocation in question, and understand that this may be because the
Council holds the view that alternative allocations within Tycroes and the wider Principal
Centre it forms part of will deliver sufficient housing for the area during the Plan period. This
is in our view wholly incorrect.

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 the whole of the Candidate Site. It has
successfully addressed the reasons put forward by the Authority for its exclusion and has
highlighted that the reason 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 in its entirety as
part of the Carmarthenshire Local Development Plan to ensure that the document passes all
the relevant tests of soundness.