Testun llawn:
Site SuV61/h1 – Land at Nieuport Farm, Pendine
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
Nieuport Farm, Pendine (LDP Ref. No. SuV61/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 10 residential units.
Plan A
(Extract of Proposals Map for Pendine and Land at Nieuport Farm 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 SuV61/h1 was considered as part of this process and as
a result the Council concluded as follows:
“Site to be allocated in the revised LDP with reference SuV61/h1. The allocation includes a
parcel of land under candidate site SR/126/002.”
The “Site Assessment Table” 2023 also concluded Candidate Site SR/126/002 (making up
part of Allocation SuV61/h1) as follows:
“Part of the site to be allocated (site ref. SuV61/h1) to allow a more comprehensive
development associated with the current allocation SC13/h1. Otherwise, there is sufficient
and more suitable land available within the settlement to accommodate new growth;”
It is clear from the above that the Council considers that the site is deliverable for the
purposes of 10 houses. However, it is unclear as to why and what evidence the Council has
received to believe beyond doubt that the allocation of part of Candidate Site SR/126/002 to
an already undeveloped Allocation SuV61/h1 provides absolute confidence that the site is
deliverable.
The allocation is brownfield in nature with its topography being relatively level. The eastern
boundary of the allocation is bordered by the B4314 while the western boundary is
dominated by a large, metal shed and what seems to be a storage yard, as can be seen
from the aerial photograph below (outlined in red below).
Photograph 1
(Extract from Google Earth – June 2021)
Access to the allocation is currently gained via the B4314, that being the main road running
north into the Village of Pendine (see below).
Photograph 2
(Streetscene of B4314)
Outline Planning Permission was granted for residential development on the site in May
2004, under application reference W/07003. Since this date, reserved matters have been
granted in January 2010 (W/21251) while more recently a non-material amendment was
made to application W/21251 which was in turn granted in November 2011 (PL/02770).
The site was allocated in the Carmarthenshire Local Development Plan (2014) under
Allocation SC13/h1 (as can be seen below).
Plan B
(Extract of current LDP Proposal Map for Land at Nieuport Farm (Adopted 2014))
Despite having almost 10 years of support for the principle of residential development at the
historic allocation from the Council, not a single housing unit has been delivered to date.
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.
