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 Client made a formal Candidate Site Submission in August 2018, which was referenced
SR/080/013, seeking the allocation of their land for residential development within the
defined settlement limits of Llandeilo as part of the Replacement Local Development Plan.
The Candidate Site (edged red below) comprised of several parcels of land, with the eastern
half of the Site in the ownership of Carmarthenshire County Council and the western half in
the ownership of our Clients.
Plan A
As illustrated above, the Candidate Site comprised of three enclosures, each of lowmoderate
value in terms agriculture, and with all being well defined by a mix of hedgerows
and stock proof fencing. The westernmost enclosure (owned by the Council) is steeply
sloping, with the remaining two enclosures being more level in nature. The site as a whole is
then bounded by the existing urban form of Llandeilo to its south and west, with further
enclosures to its east and the Llandeilo Northern Bypass located a short distance to the
north. Due to the site’s location, it is within a short walk from a wide range of community
facilities and local services found within the Town.
It should be noted, that consultation has already begun on a comprehensive scheme for the
development of the majority of the Site by Pobl Housing Group, based on the site layout
drawing reproduced below, delivering 88 new units.
Plan B
The proposed development includes provision for addressing the phosphate regulations
published by Natural Resources Wales with regards to the disposal of foul water, ensuring
that the scheme is fully deliverable.
Notwithstanding the above, following its due consideration of submissions made at the
Candidate Site Stage, the Council then allocated part of the Candidate Site for residential
development in its 1st Deposit LDP, published in January 2020 (Plan C).
Plan C
In explaining its decision to exclude the western half of the Site and not allocate it all for
residential purposes, the Council advised in its ‘Site Assessment Table’ (January 2020) as
follows:
“There are concerns over the deliverability of the site. The site has been allocated for
housing for a number of years and has not been developed. Allocation to be reduced in size
to the area covered by candidate site SR/080/005 with reference SeC16/h1; the remainder
to be excluded from development limits.”
At the time of publication of the 1st Deposit LDP therefore, the Council’s concerns related to
concerns over the deliverability of the much larger allocation the Candidate Site formed part
of, and so reduced it to the area of land owned by the Council.
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:
“There are concerns over the deliverability of the site. The site has been allocated for
housing for a number of years and has not been developed. Allocation to be reduced in size
to the area covered by candidate site SR/080/005 with reference SeC16/h1; the remainder
to be excluded from development limits.”
As can be seen, the rationale of the Council for the exclusion of our Clients land from the
allocation in the LDP has remained the same. However, it is somewhat illogical and puzzling
for the Council to be citing ‘deliverability’ as the justification for its decision. In fact, and in
contrast, the Council have failed to sell or develop its own element of the Candidate Site for
a considerable time now, due to unreasonable land value aspirations and construction-cost
challenges due to its topography. However – as can be seen from the current scheme in
preparation for the wider site – when the land is looked at in combination, a scheme for the
larger area then becomes deliverable. As a result, without our Clients land, the proposed
allocation will be undeliverable and fail to provide the number of new housing units it is
expected to do so, resulting in turn in the Plan being ‘unsound’.
The Council’s decision is therefore 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 Cluster and
wider Plan area.
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 Integrated Sustainability Appraisal form
- Copy of Candidate Site Submission Report (August 2018)
- Copy of Transport Statement
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.
