Remove housing allocation PrC2/h23 from 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 at Dafen East Gateway (LDP Ref. No. PrC2/h23) 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 150 residential units.

Plan A
(Extract of Proposals Map for Dafen East Gateway 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 PrC2/h23 was considered as part of this process and as a result the Council concluded as follows:
“Site to be retained as a residential allocation. Pending application 150 dwelling has been submitted. Site to be allocated with reference PrC2/h23.”

It is clear from the above that the Council considers that the site is deliverable for the purposes of 150 houses, although it is not clear on what basis this conclusion has been made.
The allocation is greenfield in nature with its topography sloping gently from the east to the west. The southern perimeter of the site is bordered by industrial warehouses while the eastern boundary is bordered by further greenfield land. The western boundary is then bordered by the A4138 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 off Industrial Park Roundabout north of the site, that being off the A4138 (see below).

Photograph 2
(Streetscene of Industrial Park Roundabout)

There are no current planning applications that have been granted at the site. However, there is an application currently in with the council, that has yet to be determined, for the
Residential Development of 150 Dwellings along with Assosiated Landscaping and Infrastructure (PL/04082).
The site makes up part of an allocation in the Carmarthenshire Local Development Plan (2014) under Allocation GA2/h27 as well as being allocated for employment in the Carmarthenshire Unitary Development Plan (2006) under allocation GR2/E1 as can be seen below.

Plan B
(Extract of current LDP Proposal Map for Dafen East Gateway (Adopted 2014))

Plan C
(Extract of Carmarthenshire UDP Proposal Map for East Dafen Gateway (Adopted 2006))

Despite having almost 20 years of support for the principle of residential or employment development at the historic allocation from the Council, not a single housing unit or commercial unit has been delivered to date. We are led to believe that there is also no active marketing strategy for the development and the council being the landowners are merely seeking to secure an outline permission on their own land asset.
The allocation in question also is situated in an area that has a vast history of coal mining. As a result, there are a number of mine entries located within the site (as can be seen below) meaning that the remediation costs of clearing the land would result in the development being potentially costly, and unsustainable in terms of profit margins.

Map 1
(Extract from Coal Authourity Map showing coal mine entries within the area)

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.