Testun llawn:
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/080/002, seeking the allocation of their and adjoining land for future residential
development within the defined settlement limits of Llandeilo as part of the Replacement
Local Development Plan. The Candidate Site is edged red below in Plan A.
Plan A
The Candidate Site comprised of a single enclosure, with its south western boundary
fronting onto the adjoining public highway, from which access to it was gained. Its remaining
boundaries were as equally well defined through a combination of existing woodland belts
and residential properties.
Following its due consideration, the Council then excluded the Site from the proposed
development limits for Ffairfach 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:
““Development would lead to an illogical extension of the urban form. The Site will remain
outside of limits. There is sufficient residential land allocated in the settlement. The position
with DCWW WWTW at Ffairfach is a consideration.”
At the time of publication of the 1st Deposit LDP therefore, the Council presented three
separate reasons for justifying its exclusion, although no further detail or explanation than
the above statement was provided.
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:
“Development would lead to an illogical extension of the urban form. The Site will remain
outside of limits. There is sufficient residential land allocated in the settlement. The position
with DCWW WWTW at Ffairfach is a consideration.”
As can be seen, the rationale of the Council for the exclusion of the Site as an allocation in
the LDP has remained the same. This is somewhat puzzling and illogical and for the reasons
set out below, puts the soundness of the Plan into question.
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 therefore 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)
Response to Council’s Reasons for Non-Allocation of Site
Sufficient Residential Land Allocated Within Settlement
Under the provisions of the 2nd Deposit LDP, Llandeilo in conjunction with Ffairfach and
Rhosmaen is defined as a Service Centre, representing the largest and most sustainable
settlement in Cluster 5 of the Settlement Framework. Despite this, and the fact that the
Council’s objective through the Plan is to channel most development to these settlements,
the current 2nd Deposit LDP has only allocated land for the provision of 27 new homes during
the Plan period for the Service Centre. To therefore suggest that there is ‘sufficient
residential land’ within the settlement to meet its community’s needs and satisfy the strategic
policies of the Plan is incredulous and for the Council’s proposals to remain unchanged
would result in the Plan being ‘unsound’.
In turn, the Service Centre then forms part of a group of settlements defined as Cluster 5 in
the Settlement Framework, with the table below providing an indication of the proposed
allocations in the 2nd Deposit LDP for the cluster.
Ref. No. Site Name Units
SeC15/h1 Land to north of Dan y Crug, Llandovery 61
SeC15/h2 Land adjacent to Bryndeilog, Tywi Avenue, Llandovery 8
SeC16/h1 Llandeilo Northern Quarter, Llandeilo 27
SeC17/h1 Land opp. Llangadog C.P School, Llangadog 16
SeC17/h3 Ger yr Ysgol, Llangadog 21
SuV49/h1 Ael y Mynyd, Llanfynydd 13
SuV51/h1 Opp. Village Hall, Cwmifor
Table 1
The above provides a worrying picture with regard to housing supply in the Cluster in
question. Despite being the largest and most sustainable Service Centre of Cluster 5,
Llandeilo/Rhosmaen/Ffairfach has a far lower level than the smaller settlement of Llandovery
and less than half the number allocated for Llangadog, despite the settlement being half the
size of Llandeilo.
The above is even more worrying when the deliverability, or the ability to deliver the
assigned number of units of some of the above allocations are in serious question
(SeC17/h1 and SuV51/h1), as well as some sites despite being allocated for over 30 years,
still having not delivered as single unit (SeC15/h1)
As a result of the above, separate objections have been made in relation to a number of the
aforementioned allocations and it is therefore important that alternative more deliverable
sites should be identified, to ensure the Plan can be regarded as being ‘sound’ in targeting
new housing development at the most sustainable location.
Development would lead to an unacceptable extension of the Urban Form.
The second reason given by the Authority for not allocating the Candidate Site was on the
basis that in its view it would “… lead to an illogical extension fo the urban form.”.
As the accompanying Candidate Site Supporting Statement highlights, the Candidate Site is
in fact well related to the existing settlement of Llandeilo. This is best apprecaited from an
aerial photograph (see below), which illustrates the close proximity of the site (edged red) to
existing residential and commercial development.
Photograph 1
It is in fact almost surrounded by existing non-agricultural land uses and so forms a logical
extension and addition to the wider urban form. From an accessibility perspective, the site is
within short walking distance of a number of the Town’s community facilities and local
services, as well as well served bus stops. The allocation of the Candidate Site would not
only represent a logical addition to the existing urban form, but would also represent a
sustainable form of development.
The position with DCWWWWTW at Ffairfach is a consideration.”
The final reasoning given by the Council then relates to the waste treatment plant at
Ffairfach, although it has not included this statement in any of its other response to its
assessment of Candidate Sites in the Service Centre. No explanation to date has been given
as to why.
Notwithstanding the above, we understand that provided all foul water leaving a
development from Llandeilo meets the phosphate regulations of Natural Resource Wales,
the WWTW in question will be able to accommodate such additional flows. The Site subject
of this submission is capable of providing such on-site infrastructure and the proposed 5
units, due to its size. This ratio has been based on other worked up examples and so the
third reason cited by the Council for excluding the Site is both illogical and erroneous
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.
