Include site within the 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 to r/o
Dolcoed, Newcastle Emlyn (LDP Ref. No. SeC12/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 Proposal Map extract below and is
proposed for the allocation in the 2nd Deposit LDP for the purposes of 20 residential units.

Plan A
(Extract of Proposal Map for Newcastle Emlyn and Land to r/o Dolcoed 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/h3 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/h3.”
It is clear from the above therefore that the Council considers that the site is deliverable for
the purposes of 20 houses, although it is not clear on what basis this conclusion has been
made.
The allocation itself is greenfield in nature and is currently used as agricultural land. The
topography of the site is then generally level. The northern boundary of the site is bordered
by residential properties along the A484 while the southern boundary is bordered by mature
vegetation and trees, as can be seen from the aerial photograph below (allocation circled
red).

Photograph 1
(Extract from Google Earth – June 2021)

Access to the allocation is currently gained via a rear access track (south of the allocation
site). However, the western boundary of the allocation also borders the A484 (see below).

Photograph 2
(streetscene of A484)

There have been no planning applications made relating to the site subject of this
allocation to date.
The site was allocated in the Carmarthenshire Local Development Plan (2014) as allocation
(T2/4/h1), as can be seen below.

Plan B
(Extract of current LDP proposal map for Land to r/o Dolcoed (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.

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.