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 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/088/003, seeking the allocation of their land for future residential development within the
defined settlement limits of Llanfihangel-ar-Arth 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 single enclosure, with its eastern boundary fronting onto
the adjoining public highway, from which access to it was gained. Its remaining boundaries
are equally as well defined through a combination of existing hedgerows and residential
properties.
Following its due consideration, the Council then excluded the Site from the proposed
development limits for Lanfihangel-ar-Arth 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, Llanfihangel-ar-Arth has only one small allocation
(SuV39/h1) being put forward. It should be noted that this site has been allocated since the
adoption of the Carmarthenshire Unitary Development Plan (2006) and with the withdrawal
of a recent longstanding outline planning application that failed to satisfy the new phosphate
regulations, it is difficult to understand the Council’s logic that there are either ‘sufficient’ or
‘more suitable’ sites in the settlement to deliver new housing. The truth of the matter is there
are none.
Following on from the above, the number of units proposed to be accommodated by
allocation SuV39/h1 (7) 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
further confirms that the decision of the Council to not allocate the land on housing supply
basis 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 Llanfihangel-ar-Arth is
a settlement who’s growth has extended along its principal routes of access. The Alternative
Allocation follows this pattern and its development would provide a defensible line with
respect to the northern portion of the village and the open countryside beyond. 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 Llanfihangelar-Arth 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 2
nd 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.
