Allocate candidate site reference SR/019/008.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/019/008, seeking the inclusion of their land within the development limits of Capel Iwan
as part of the Replacement Local Development Plan.
The Candidate Site comprises part of a field enclosure, being irregular in shape but shares a
common boundary on two sides with detached dwellinghouses which fronts the main road
running north to south through the village centre. The land benefits from an undeveloped
gap set between existing bungalows and the farm buildings of Cruglwyd set just to the north
of the field. Its extents are illustrated by the site edged in red at Figure 1 below.
The Council have published a “Site Assessment Table” (January 2023) which provides
details of the Council’s analysis of each received Candidate Site submission, and in the case
of our clients’ submission, reasons why the site was not selected for inclusion within the draft
settlement limits of Capel Iwan as contained within the Deposit Draft.
We note that the submission successfully passed through all three Assessment Stages,
being Stage 1 (site compatible against the location of future growth presented in the
Preferred Strategy), Stage 2A (Initial Detailed Site Assessment), Stage 2b (Further Detailed
Site Assessment) and Stage 3 (Sustainability Appraisal and Habitat Regulation Assessment)
of the Council’s site assessment. It therefore crucially was adjudged acceptable in all
technical aspects of formal assessment, but was only rejected at the final selection stage,
with reasons for reported as follows:
“There is sufficient and more suitable land available for residential development within the
settlement to accommodate its housing need.”
Figure 1 – Google Earth image of Candidate Site at Capel Iwan
Our clients consider the LDP is “unsound” and should be changed, as it fails to meet the
tests for “soundness”, in that the Plan “is not appropriate”, and “will not deliver”, as defined
by the Planning Inspectorate’s LDP Examinations Procedural Guidance.
Specifically, our clients consider that the draft settlement limits for Capel Iwan, as defined
under Policy SD1 “Settlement Limits”, should be amended to include the land as edged
in red upon the extract of the Proposals Map for Capel Iwan, as reproduced below in
Figure 2.
Figure 2 – Extent of Representation Site in Second Deposit Draft Plan in centre
of Capel Iwan, and edged in red
This formal representation letter supplements the following documents which comprise a
complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
Response to Council’s Reasons for Non-Inclusion
of Site within Settlement Limits
1.0 Overall Housing Supply at Capel Iwan and Cluster 4 within Deposit Draft
1.1 The Council consider that the only reason for the Candidate Site south of Cruglwyd
farmyard as not being included within the draft Plan as a Residential Allocation is that
they believe that there are sufficient residential sites allocated elsewhere in the
settlement. On this basis, it must be accepted that the form of the Candidate Site set
as an infill opportunity between established properties which front the minor road
running north from the village towards Newcastle Emlyn, together with the proposals
to provide individual vehicular accesses onto that C class road is deemed
acceptable, and in accord with the spatial form and character of the settlement.
1.2 The proposals under this Representation merely seek the addition of 3 residential
units to the overall housing supply of Capel Iwan, which is regarded as a Tier 3
Sustainable Village, identified within the Teifi Valley Cluster within the draft LDP.
Figure 3 below provides an extract of the indicative site layout plan for this
Representation site. The proposals can provide for 3 bed detached bungalows, each
served off their own accesses with traditional rear garden space.
Figure 3 – Proposed Indicative Site Layout Plan for Representation Site
1.3 The Teifi Valley Cluster (Cluster 4) aims to provide an additional 218 residential units
over the Plan period to 2033, with Capel Iwan (Settlement SuV38) providing only one
allocated site at “Maes-y-Bryn” expected to provide only 6 units to that overall Cluster
total (reproduced at Figure 4 below). We would submit in the first instance that the
realignment of settlement limits to provide an additional 3 units will not lead to an
over-supply of dwellinghouses within the Cluster, nor the defined Capel Iwan
settlement supply.
Figure 4 – Extract from Policy HOM1 for Capel Iwan
1.4 We have examined and researched sites which have been brought forward as
Residential Allocations with the Deposit Draft. In Capel Iwan great emphasis within
the Draft Plan has been placed upon the continued allocation of the above proposed
housing site, which is still left allocated from the 2008-21 Local Development Plan.
The above table indicates that the Council expect that site to be delivered to the
market between LDP years 6-10, being 2023 to 2028. Therefore, given that it already
benefits from being allocated in the current adopted LDP, the landowner or
prospective purchase can seek planning permission in the knowledge of its
acceptance in principle. Indeed, when questioned by the Council as part of their
formal review of Allocated Sites from the 2014 adopted Plan they reported that “The
site was submitted as a candidate site and as such, the agent has provided evidence
showing its viability.”
1.5 However, we note that no application for planning permission has ever been
submitted on the site, despite it appearing in an adopted LDP for nine years. The
site made up part of the residential allocation SC7/h2 as reproduced at Figure 5
below.
Figure 5 - Extract of Current LDP Proposal Map for Capel Iwan
and Maes y Bryn Allocation
1.6 The site was also included with the Carmarthenshire Unitary Development Plan,
adopted in 2006, and accordingly it has laid undeveloped and not subject of any
planning application for a combined total of 17 years. We will lodge separate formal
representations seeking omission of this site, as it clearly is undeliverable, and
the landowner has no intent of bringing it forward for development.
2.0 Newcastle Emlyn
2.1 We have also examined Draft Allocations within the nearby town of Newcastle
Emlyn, which is regarded as a Tier 2 Local Service Centre in the new LDP. Figure 6
below provides a snapshot of the three allocations in the town.
Figure 6 – Newcastle Emlyn HOM1 Allocations
2.2 “Trem-Y-Ddol” allocated as SeC12/h1 for 17 dwellings. The site was allocated in the
adopted 2014 Local Development Plan, and also Carmarthenshire Unitary
Development Plan in 2006. Full Planning Permission was sought under application
W/18258 for the development of “17 Dwellings, Site Layout and Access Road” in
2008. The application lay undetermined until 2022 – a period of 15 years – until it
was finally refused due to the Applicants’ failure to commit to making a contribution
towards Affordable Housing.
2.3 It is clear that to leave a planning application continue for so long without a decision
is testament to a lack of desire and commitment by the landowner to implement a
development upon the site, and accordingly it is plainly undeliverable as a future LDP
allocation.
2.4 Finally, “Dolcoed” is allocated as Site SeC12/h3, apparently capable of providing 20
new homes, in two phases over the 10 years remaining of this new Replacement
LDP. However, upon closer examination, it is revealed that there have been no
planning applications made relating to the site subject of this allocation to date.
This is despite the site being allocated in the Carmarthenshire Local Development
Plan (2014) as allocation (T2/4/h1). After a period of 10 years, not a single dwelling
has been proposed at this edge of town site, and yet the Council persist in awarding
this inability to deliver by continuing the allocation in the new Replacement LDP.
2.5 We therefore highlight that a combined total of 37 dwellings upon two sites within 3
kilometres of our client’s site at Capel Iwan have remained stagnant and their
continued allocation in a new LDP for a further 10 years is undeniably questionable.
The Council should be seeking more deliverable small sites such as that promoted
by our client at Cruglwyd Farm, which should be included in settlement limits in
replacement of one if not all the above three sites.
In conclusion, this Representation to the Second Deposit Draft of the Revised LDP has
sought to examine the Council’s reasons for non-inclusion of a Candidate Site.
Our clients have illustrated that their indicative proposals to construct 3 dwellinghouses will
not appear at odds to the prevailing spatial pattern of development in Capel Iwan. The
proposals will provide a short frontage of bungalows respectful to the character and setting
of the locality.
We respectfully request that this Representation be given careful examination, and
consequently the defined settlement limits of this part of Capel Iwan realigned to include the
Representation Site, in a realigned settlement limits in the Proposals Map of the adopted
Local Development Plan.