Remove site from Plan

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 Adjacent
Fron Heulog, Cynwyl Elfed (LDP Ref. No. SuV4/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 8 residential units.

Plan A
(Extract of Proposals Map for Cynwyl Elfed and land Adjacent Fron Heulog 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 SuV4/h1 was considered as part of this process and as a result the Council concluded as follows:
“Site to be allocated for residential development with site reference SuV4/h1.”
It is clear from the above that the Council considers that the site is deliverable for the purposes of 8 houses, although it is not clear on what basis this conclusion has been made.

The allocation is both greenfield and brownfield in nature with its topography being generally level. The southern and northern perimeters of the site are bordered by residential properties while the western perimeter is bordered by mature vegetation, trees and hedgerows 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 an existing access road into the site off the B4333, that being the main road running through Cynwyl Elfed (see below).

Photograph 2
(Streetscene of B4333)

Full Planning Permssion was granted for the eastern half of the site in 2009 for a Road and Plot Layout for 4 Dwellings (W20990). The new road was developed, however, since that date only 1 dwelling has been completed under application W/39955 in 2019. The western half of the site then has outline planning permission for Housing Developemnt (W/39856).
However, this outline permission fails to provide a detailed site layout plan showing the plans for future development.

The site makes up part of an allocation in the Carmarthenshire Local Development Plan (2014) under Allocation SC9/h1 as well as the Carmarthenshire Unitary Development Plan (2006) under allocation CL9/b as can be seen below.

Plan B
(Extract of current LDP Proposal Map for land Adjacent Fron Heulog (Adopted 2014))

Plan C
(Extract of Carmarthenshire UDP Proposal Map for land Adjacent Fron Heulog (Adopted 2006))

It can then be said that despite having almost 20 years of support for the principle of residential development at the historic allocation from the Council, only 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 as its inability to be delivered 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.