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 Trem y Ddol,
Newcastle Emlyn (LDP Ref. No. SeC12/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 Proposal Map extract below and is
proposed for the allocation in the 2nd Deposit LDP for the purposes of 17 residential units.

Plan A
(Extract of Proposal Map for Newcastle Emlyn and Trem y Ddol 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 SeC12/h1 was considered as part of this process and as a result the Council concluded as follows:
“Site to be allocated for residential use with reference SeC12/h1.”
It is clear from the above therefore that the Council considers that the site is deliverable for the purposes of 17 houses, although it is not clear on what basis this conclusion has been made.
The allocation itself is greenfield in nature and is currently in a state of pastureland. The topography of the site slopes gradually from south to the north. The northern boundary of the site is bordered by mature vegetation and trees while the southern boundary is bordered by a farm track. To the west of the site is further agricultural fields while the residential estate of Trem y Ddol is located to the east , as can be seen from the aerial photograph below (allocation circled red).

Photograph 1
(Extract from Google Earth – June 2021)

Access to the site is currently gained via Trem y Ddol (see below), that being a residential site located to the eat of the allocation.

Photograph 2
(streetscene of Ffordd y Glowyr)

Full Planning Permission was sought under application W/18258 for the development of 17 Dwellings, Site Layout and Access Road in 2008. This application was refused due to the land being within a Special Area for Conservation (Afon Teifi) as well as the applicant failing to enter a Section 106 agreement. Since this application, no other planning applications have been made relating to the land in question.
The site was allocated in the Carmarthenshire Local Development Plan (2014) as part of a larger allocation (T2/4/h1), and Allocation S6/ of the Carmarthenshire Unitary Development Plan (2006) as can be seen below.

Plan B
(Extract of current LDP proposal map for Betws Colliery (Adopted 2014))

Plan C
(Extract of Carmarthen UDP Proposal Map for Allocation Site (Adopted 2006))

Despite having almost 20 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.

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.