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 at Golwg
yr Afon, Llangennech (LDP Ref. No. SeC7/h3) 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 50 residential units.

Plan A
(Extract of Proposals Map for Golwg yr Afon 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 SeC7/h3 was considered as part of this process and as a result the Council concluded as follows:
“Site to be retained as a residential allocation as per candidate site area. Site to be allocated with reference SeC7/h3.”
It is clear from the above that the Council considers that the site is deliverable for the purposes of 50 houses, although it is not clear on what basis this conclusion has been made, especially given the important biodiversity features as well as the Tree Protection Orders that surround the site boundary.

The allocation is greenfield in nature with its topography being generally level. The entire site is covered by mature vegetation and trees. The northern, southern and western perimeters of the site are bordered by residential properties. The eastern boundary is bordered by further mature vegetation, hedgerows and trees 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 unknown, however, the site adjoins Golwg yr Afon that being a residential site west of the allocation (see below).

Photograph 2
(Streetscene of Aber Llwchwr)

There have been no planning applications made relating to residential development at the allocation site. The eastern and southern boundaries of the allocation are lined with Tree
Protection Orders (TPO). This could indicte that the site is potentially undeliverable due to expanse and need to intergrate with those protected specimines and consequently the biodiversity features of the immediate area.
The site is allocated in the Carmarthenshire Local Development Plan (2014) under allocation GA2/h52 (as can be seen below).

Plan B
(Extract of Current Carmarthenshire LDP Proposal Map for Allocation Site (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.
The site is not being actively marketed by its owners (County Council), which is surprising since the location where executive housing has seen much sought in the last 10 years.

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.