Testun llawn:
Land between Bryn & Brynglas, Capel Iwan
We are instructed by Mr K. Thomas to make a formal representation with regards to the
above land and the Second Deposit Draft of the Carmarthenshire Local Development Plan.
Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/019/007, 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 a rectangular-shaped grazing paddock set off the western
flank of the minor road that runs north to south from the centre of the village of Capel Iwan.
The proposals seek inclusion of the well-defined enclosure to provide a modest development
of detached and semi-detached houses to complement established properties which lie
directly alongside the road off the western flank of the road. It therefore represented a logical
opportunity for infilling within the settlement and providing a much-need and deliverable
residential opportunity which can generate 9 dwellings. Its extents are illustrated by the site
edged in red, being a site location plan, at Figure 1 below.
The Council published a First Deposit Draft of the Replacement Local Development Plan in
January 2020. At that time, the Council revealed its analysis of each submitted Candidate
Site within a “Site Assessment Table” (January 2020) We noted at that time that our Clients
land was considered as part of this process and as a result the Authority concluded that the
site had successfully passed through all four 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. Accordingly at Stage 4 the Council reported “Site to be allocated with
reference SuV38/h2”
Figure 1 – Location plan of Candidate Site at Capel Iwan
As a result of the above Council assessment, Figure 2 presents an extract of the First
Deposit LDP Proposals Map for Capel Iwan, which clearly identified part of our clients’ land
as within the defined development limits and allocated for Residential Development.
Figure 2 – Extract of Proposals Map for Capel Iwan with site included within
settlement limits as shown by a red arrow
Our clients are therefore astonished to discover that upon publication of the Second Deposit
Draft of the LDP, the Council have sought to amend the draft settlement limits, to only
include a field frontage strip within the proposed settlement limits, and accordingly
exclude the rear portion of the field. That new Draft Plan for this northern part of Capel Iwan
is reproduced as Figure 3 below. A new Site Assessment Table, dated January 2023, now
indicates that the Council conclude that “Part of the site is suitable as small-scale infill,
for the remainder of the site, it is considered that there are more appropriate sites
elsewhere within the settlement.”
Figure 3 – Second Deposit Draft extract of Capel Iwan limits at Brynglas
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 4. The land should be appropriately allocated for housing under Policy HOM1
“Housing Allocations.”
Figure 4 – Extent of Representation Site 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
- Completed Sustainability Appraisal 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 between Brynglas
and Bryn 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 utilise and reform the existing vehicular access 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 9 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 5 below provides an extract of the indicative site layout plan for this
Representation site. The proposals can provide a mix of 3 and 4 bed detached and
semi-detached dwellinghouses about a cul-de-sac formation.
Figure 5 – 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 6 below). We would submit in the first instance that the
addition of an additional allocated site of 9 units will not lead to an over-supply of
dwellinghouses within the Cluster, nor the defined Capel Iwan settlement supply.
Figure 6 – 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 7
below.
Figure 7 - 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 8
below provides a snapshot of the three allocations in the town.
Figure 8 – 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 sites such as that promoted by our
client at Brynglas, which should be allocated 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 9 dwellinghouses will
not appear at odds to the prevailing spatial pattern of development in Capel Iwan. The
proposals will provide a modern cul-de-sac development 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, as a Residential Allocation in the Proposals Map of the adopted Local
Development Plan.
