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 Opp.
Village Hall, Cwmifor (LDP Ref. No. SuV51/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 Cwmifor and land Opp. Village Hall 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 SuV51/h1 was considered as part of this process and as a result the Council concluded as follows:
“The site represents a longstanding residential allocation and there are concerns over the deliverability of the whole site. Allocation to be reduced in size with reference SuV51/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, especially as the Council state that there are concerns over the deliverability of the site as well as it being a longstanding residential allocation.
The allocation is greenfield in nature with its topography being relatively level. The eastern and southern perimeters of the allocation are covered with mature vegetation, trees and hedgerows. The western boundary is bordered by further agricultural land while the northern boundary is bordered by residential dwellings 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 agricultural access off the C2162 that being the main road running through Cwmifor (see below).

Photograph 2
(Streetscene of Access to Allocation Site)

Outline Planning Permission was saught after in 2007 for Residential Development and Community Car Park (E/16584). Outline planning was granted in 2013 however there have been no follow up applications relating to the granted outline consent. Full Planning Permission was then saught in 2019 for the Construction of Three dwellings (Phase 1 of larger scheme) including community car park, estate road, and associated detail (E/39651). This application was refused in February 2023 as the scheme had failed to address and satisfy the recently intorduce phosphate regulations with respect to foul water generation.
The site makes up part of an allocation in the Carmarthenshire Local Development Plan (2014) under Allocation (SC30/h1), and previously under Allocation CL34/a of the Carmarthenshire Unitary Development Plan (2006) (as can be seen below).

Plan B
(Extract of current LDP Proposal Map for land Opp. Village Hall, Cwmifor (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.