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 SD1 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/082/006, seeking the inclusion of the land within the defined development limits of
Llandybie as part of the Replacement Local Development Plan. The Candidate Site centred
mainly on a small agricultural paddock that fronted onto Kings Road, edged red on Plan A.
Plan A
Further agricultural enclosures are positioned to the east, but residential development is
located directly to the land’s south and on the opposite side of Kings Road to the west. The
Site is also within walking distance to the range of community facilities and local services the
settlement has to offer, as well as well serviced bus stops that provide access to those
services and facilities in the wider growth area.
As part of the preparation of the 1st Deposit LDP, the Council then considered the
submissions made and provided a summary of its assessment in its ‘Site Assessment Table’
(January 2020), which read as follows:
““Inclusion of the site would result in extending a ribbon pattern of development contrary to
general planning principles.”
As a result, the proposed 1st Deposit LDP made no changes to the development limits in the
environs of the Candidate Site to those forming part of the current adopted LDP, as
illustrated by the Proposals Map extract below.
Plan B
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:
“The site cannot accommodate 5 or more dwellings. Inclusion of the site would result
extending a ribbon pattern of development contrary to general planning principles.
As can be seen, the process of assessment of our Client’s land by the Council has remained
unchanged, as has its exclusion from the development limits. We however consider the
exclusion of the site to be an erroneous decision by the Council, as well as being an
inconsistent approach taken by it in the assessment of such sites. We therefore consider
that the LDP is “unsound” and should be changed, as it fails to meet the tests for
“soundness”.
Specifically, we consider the approach of assessment taken by the Council has been
inconsistent in terms of (a) other policy approaches taken by the Deposit LDP and (b) in
relation to other examples that were successfully included within defined development limits
of the 2nd Deposit LDP. We consider therefore that the whole of the land edged red in Plan
A, should be included within the defined development limits for Llandybie under the provision
of Policy SD1 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 2nd Deposit LDP Representation Form
- Copy of Candidate Site Supporting Letter (August 2018)
- Copy of Candidate Site Location and Layout Plan (August 2018)
Response to Council’s Reasons for Non-Allocation of Site
Consistency with Other Policies of the Deposit LDP
The Council has provided no specific indication or guidance on how it has determined and
defined development limits within the 2nd Deposit LDP. It has therefore been difficult to
ascertain why some sites have been successfully included and others haven’t, which is
discussed further below. However, Policy HOM3 deals with small extensions to existing rural
villages and so provides a useful series of criteria in determining where such extensions
would be acceptable, namely the following:
Minor infill or a small gap between the existing built form; or
Logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
Conversion or the sub-division of large dwellings.
It is logical therefore that the same assessment criteria should be utilised in assessing
whether or not a candidate site would make an acceptable addition to existing development
limits (A separate representation with regards to Policy SD1 has been made on this basis).
Taking our Client’s land into consideration, together with the actual ‘on-the-ground’ physical
attributes of adjoining and nearby land and its use, it is clear that it would adhere to the
second criteria listed above and so should in turn have been included within the defined
development limits of Llandybie. Its exclusion would be inconsistent with the provisions of
Policy HOM3 and indeed decisions taken by the Council with regard to other sites within the
Plan area. As a result and on this basis alone, the Plan as it currently stands is unsound.
Consistency with Other Development Limits
Consistency in approach and application is critical in order for the planning system to be
both effective and credible to all its users. Without it, the system itself becomes unsound and
in the case of the determination of the development limits for Llandybie and other
settlements, the Council has been found to be inconsistent.
The plans below are an extract of the 2nd Deposit LDP Proposals Maps for two areas
(indicated by the red star) in the settlement of Llandybie, Glanamman and Llanwrda.
Plan C
(Llandybie)
Plan D
(Llanwrda)
Plan E
(Glanamman)
In the case of the Llandybie example, two separate parcels of undeveloped land have been
included within the defined development limits, that extend the existing form of the
settlement in a southern ‘ribbon-like’ manner, and the Garnant example follows a similar
pattern. The Llanwrda example is then an element of an existing larger agricultural
enclosure, with two of its boundaries therefore currently undefined and so extending the
existing settlement’s limits beyond existing boundaries.
It should be noted that we do not object to the form of alteration to the development limits as
referred to above, as it secures a varied form of available housing development opportunities
for a community. However, their inclusion is in direct contrast and inconsistency to the
Council’s decision to exclude our Client’s land and the aforementioned existing properties
from the development limits. Combined with our Client’s land representing a logical
rounding-off of the respective area of the settlement (particularly when the on-the-ground
position is given full consideration), the exclusion of it would represent a clear inconsistency
in approach taken by the Council, resulting in the Plan as it stands being unsound.
In conclusion, this Representation to the 2nd Deposit Draft of the Revised LDP has sought to
examine the Council’s reasons for non-inclusion of a Candidate Site within the defined
development limits. It has successfully addressed the reason put forward by the Council for
its exclusion and highlighted that its continued exclusion would represent a dangerous
inconsistency.
We therefore respectfully request that this Representation be given careful examination, and
consequently the land in question be included within the defined development limits as part
of the Carmarthenshire Local Development Plan to ensure that the document passes all the
relevant tests of soundness.
