Amend Plan to include the site

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/148/002, seeking the allocation of their land for future residential development within the
defined settlement limits of Saron 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 series of enclosures, with its south western boundary
fronting onto the adjoining public highway (A484), from which access to the site is gained. Its
remaining boundaries were as equally well defined through a combination of established
field boundaries and residential properties.
Following its due consideration, the Council then excluded the Site from the proposed
development limits for Saron 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 of the site would have a detrimental impact on the character and setting of the
settlement. Furthermore, there is sufficient and more suitable land available for development
within the settlement to accommodate its housing need.”

At the time of publication of the 1st Deposit LDP therefore, the principle reason presented by
the Council for the exclusion of the site from the development limits and its non-allocation for
residential development, was on the basis that the Council considered there to be sufficient
alternative sites within the settlement to accommodate the housing need.

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 of the site would have a detrimental impact on the character and setting of the
settlement. Furthermore, there is sufficient and more suitable land available for development
within the settlement to accommodate its housing need.”

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. In terms of
‘alternative sites’ in the 2nd Deposit LDP, Saron has only one small allocation being put
forward. In addition, the number of units proposed to be accommodated by the allocation
does not seem to have taken on board the requirement for on-site provision for phosphate
provision, which can amount to up to 25% of a development site’s area. (Please see
accompanying Site Layout plan for site at Heol Hathren, Cwmann). This and the low number
of allocations within the settlement seems an extremely erroneous decision, particularly in
terms of (a) the sustainable attributes of the settlement and (b) the number of undeliverable
allocations being put forward by the 2nd Deposit LDP and so further sites are required (see
below).

The second reason given for the exclusion of the site is completely illogical and inconsistent
with other decisions taken by the Council in the preparation of its 2nd Deposit LDP. As can be
seen form the accompanying Candidate Site Report, the settlement of Saron has a nuclear
pattern of growth that then extends along the main transport arteries that support it.

Overtime as the settlement has evolved and grown, such growth has occurred then in
between these strands of development. Contrary to the Council’s view, it is clear therefore
that the development of the Site in question would harmonise with the settlements existing
character and setting.

On the basis of the above, we consider the sites exclusion to be an illogical and erroneous
decision by the Council and consider therefore that the LDP as it stands is “unsound” and
fails to meet the required Tests of Soundness.
In addition, we consider that alternative allocations within the wider Cluster that Saron forms
part of (discussed below) are neither appropriate nor deliverable. 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
As detailed above, we are deeply concerned with the Council’s decision to not allocate the
land in question and understand that this may be because the Council holds the view that
alternative allocations within the wider Cluster it forms part of will deliver sufficient housing
for the area during the Plan period. This is in our view wholly incorrect.

Under the current provision of the Deposit LDP, the Cluster has a range of proposed
residential allocations. Having undertaken a comprehensive review of the proposed
allocations put forward by the 2nd Deposit LDP for the Cluster in question, it has been
identified that a number have significant questions over their ability to be delivered within the
Plan period, including the following:

Ref. No. Site Name Units
SeC12/h1 Trem y Ddol, Newcastle Emlyn 17
SeC12/h3 Land to r/o Dolcoed, Newcastle Emlyn 20
SeC13/h1 Adjoining y Neyadd, Llanybydder 10
SeC14/h1 Blossom Garage, Pencader 20
SeC14/h2 Land adj. Maescader, Pencader 24
SuV33/h1 Land opp. Brogeler, Llangeler
SuV28/h1 Maes y Bryn, Capel Iwan 6
SuV39/h1 Adj. Yr Hendre, Llanfihangel ar Arth 7
Su41/h2 Cilgwyn Bach, Pontyweli 14

Table 1

As a result of the above – all of which have been allocated in previous development plans -
separate objections to their inclusion with the LDP have been made. This is due to the fact
that to continue to allocate such sites for residential development results in the Plan being
unsound. Alternative sites, such as that put forward by our Client, must therefore be
considered and brought forward in order to address this deficiency and ensure that the Plan
is sound in all respects.

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.