Remove allocation SuV63/h1 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 at
Woodend, Llanmiloe (LDP Ref. No. SuV63/h1) 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 28 residential units.


Plan A
(Extract of Proposals Map for Llanmiloe and Land at Woodend 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 SuV63/h1 was considered as part of this process and as
a result the Council concluded as follows:
“The site is under construction with a road and plot layout developed for self build
development. Site to be allocated with reference SuV63/h1.”

It is clear from the above that the Council considers that the site is deliverable for the
purposes of 28 houses. However, it is unclear as to the sustainability of the development of
self build plots for the purposes of the proposed Local Development Plan, or the reliability
that all plots will be completed during the plan period.
The allocation is brownfield in nature with its topography being relatively level in the southern
half of the allocation while the northern half slopes drastically from north to south. The
southern boundary of the allocation is bordered by the A4066, as can be seen from the
aerial photograph below (outlined in red below).

Access to the allocation is currently gained via the A4066, that being the main road running
between the villages of Pendine and Llanmiloe (see below).

Outline Planning Permission was granted for “Residential Development, together with associated vehicular and pedestrian accesses, car parking, landscaping and ancillary
development: site preparation, clearance, treatment, re-profiling and the installation of new services and infrastructure” on the site in Feburary 2016, under application reference W/32544. Since this date, individual plots have sought planning permission for their construction.

The site was allocated in the Carmarthenshire Local Development Plan (2014) under
Allocation SC13/h3 as well as the Carmarthenshire Unitary Development Plan (Allocation PDB41) as can be seen below.

Despite having almost 20 years of support for the principle of residential development at the historic allocation from the Council, only 3 housing units have been delivered to date on a site allocated for 28.

Given that the first plot was developed in 2019, and that to date there, are a total of 3 houses
that have been developed on the site, it seems that there has been a single plot developed
for each following year. At that build rate, it would take an estimated 25 years to complete the site therefore going beyond the proposed plan period. It is for this reason that the site should not be deemed as deliverable and that the allocation should be removed.

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 (housing supply). 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 allocation fails to test the soundness as the site is clearly unable to deliver any new
housing. The Welsh Governments Development Plans Manual (Edition 3) is quite clear
with regard to rolling forward allocations and states that allocations “… rolled forward from a
previous plan will require careful justification for inclusion in a revised plan, aligning with
PPW. There will need to be substantial change in circumstances to demonstrate sites can be
delivered and justify being included again. Clear evidence will be required that such sites
can be delivered”. No evidence has been presented to demonstrate a change in circumstances to indicate the allocation will now be deliverable and so its continued allocation 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.