Remove residential allocation SeC18/h3 from 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 it necessary to
make a formal representation to the “soundness” of the Carmarthenshire Deposit Local
Development Plan in relation to the allocation for residential development at Land Adjacent
to Cefn Maes, St Clears (LDP Ref. No. SeC18/h3) under the provisions of Policy HOM1.
The proposed allocation has been fully assessed and in considering its context and
background (summarised below) it is considered that its continued inclusion will lead to the
Plan failing the 3 Tests of Soundness for the reasons set out below.

Site Background and Context
The allocation relates to the land shaded brown on the Proposals Map extract below and is
proposed for allocation in the 2nd Deposit LDP for the purposes of 100 residential units.

(Extract of Proposals Map for St Clears and land Adjacent to Cefn Maes Allocation)
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 and existing allocations within the current
adopted LDP. Proposed allocation SeC18/h3 was considered as part of this process and as
a result the Council concluded as follows:
“Site to be allocated with reference SeC18/h3.

It is clear from the above therefore that the Council considers that the site is deliverable for
the purposes of 100 houses, although it is not clear on what basis this conclusion has been
made. It is also unclear how the allocation of a previously allocated ‘green wedge’, used in
order to protect local green spaces as well as to prohibit the coalescence of settlements,
would now be deemed to be appropriate for future housing development.

The allocation is greenfield in nature with its topography being relatively level. The site is
made up of two enclosures with much of the perimeter of the allocation being covered with
mature vegetation, trees and hedgerows, as can be seen from the aerial photograph below
(outlined in red below).

There have been no planning applications made relating to the allocation site in question to
date.
Although the site was not allocated for development in the Carmarthenshire Local
Development Plan (2014), the site was not included within the defined settlement limits of St.
Clears. As well as this, within the Carmarthenshire Unitary Development Plan (2006), the
allocation site was defined as a green wedge (as can be seen below).

The purpose of the ‘Green Wedge’ allocation from Plan C is clear – to prevent an instance
that could contribute towards the coalesance of settlements (Pwll and St. Clears).
Tests of Soundness
Based on the above information and the guidance documents provided by the Welsh
Government and Council itself, it is considered that the inclusion of the adoption of the LDP
in its current form with the inclusion of the allocation in question, would result in it failing to
meet the requirements of the Tests of Soundness, for the reasons summarised below.

Test 1 – Does the Plan Fit?
The allocation fails the test of soundness due to its inappropriateness with regards to the
principles of sustainable growth and so is in conflict with Paragraph 4.2.2 of Planning
Policy Wales (Edition 11) requirements of national planning policy.
Test 2 – Is the Plan appropriate?
The allocation fails the test of soundness as its inability to be delivered would fail to
address key issues set out by the Plan (protection of landscape quality). The Council’s
decision to allocate the land appears to not have been done so on credible or robust
evidence.
Test 3 – Will the Plan deliver?
The fact that the site wasn’t allocated within the defined settlement limits on the current Carmarthenshire LDP demonstrates that the site is encroaching towards the open
countryside and does not reflect the layout of the town. Also, given that the site was once
allocated as a green wedge, within the Carmarthenshire UDP, indicates that the area is of
natural importance and that development in this area was not deemed acceptable due to it
resulting in a situation that could lead to the coalescence of settlements. Therefore, the
allocation of this site for the purposes of residential development would lead to the plan
being deemed unsound on this basis.

In summary, we object to the inclusion of the allocation in question on the basis of the
above and that its inclusion within the Plan would result in the document being ‘unsound’.
We therefore respectfully request that this Representation be given careful examination, and
that the allocation be removed to ensure that the document passes all the relevant tests of
soundness.