Include the site as a housing allocation within the RLDP.

Carmarthenshire Local Development Plan 2018-2033 – Deposit Draft
Representation on Behalf of Miss L and Mr A Edwards
Land adjacent to Ger-Y-Llan, Llanarthne
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 that the
proposed provisions of Policy HOM1 are of particular interest to our Clients. As a result, we
offer the following for the Authority’s consideration, and Inspector’s in due course.

Our clients made a formal Candidate Site Submission in August 2018, which was referenced
SR/076/003, seeking the allocation of their land for future residential development within the
defined settlement limits of Llanarthne as part of the Replacement Local Development Plan.
The Candidate Site is edged red below in Plan A.
Plan A
The Candidate Site comprised part of a single enclosure that adjoined the existing
residential development of Ger y Llan, located to its east, with its southern and eastern
boundaries then being defined by established field boundaries. Access to the site is then
obtained from the public highway that runs along the southern boundary of the site.

Following its due consideration, the Council then excluded the Site from the proposed
development limits for Llanarthne in its 1st Deposit LDP, published in January 2020 (Plan B).
Plan B
In explaining its decision to exclude the site and not allocate it for residential purposes, the
Council advised in its ‘Site Assessment Table’ (January 2020) as follows:
“There is sufficient residential land opportunity within the settlement. Development would
lead to an unnecessary extension of the settlement.”
At the time of publication of the 1st Deposit LDP therefore, the principle reason presented by
the Council for the exclusion of the site from the development limits and its non-allocation for
residential development, was on the basis that the Council considered there to be sufficient
alternative sites within the settlement to accommodate the housing need. This is somewhat
puzzling, as construction on all plots of the only allocation present in the settlement had by
the time of the assessment been commenced or completed, as illustrated by the aerial
photograph below of the time.

Photograph 1
As a result, at the time of the publication of the 1st Deposit LDP, there was no opportunity for
further development in the settlement.
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. We note that our Client’s land was considered
as part of this process and as a result the Council concluded as follows:
“There is sufficient residential land opportunity within the settlement. Development would
lead to an unnecessary extension of the settlement.”

As can be seen, the rationale of the Council for the exclusion of the Site as an allocation in
the LDP has remained the same. This is somewhat puzzling and illogical. In terms of
‘alternative sites, in the 2nd Deposit LDP, Llanarthne no longer has any housing allocations
that will facilitate further development. This seems an extremely erroneous decision,
particularly in terms of (a) the sustainable attributes of the settlement, (b) the clear support
from local developers (see accompanying letter) for further development in the area to
respond to the high demand for housing and (c) the number of undeliverable allocations
being put forward by the 2nd Deposit LDP and so further sites are required (see below).

The second reason given for the exclusion of the site is completely illogical and inconsistent
with other decisions taken by the Council in the preparation of its 2nd Deposit LDP. By their
very nature, any new greenfield allocation will extend beyond the existing built form of a
settlement, as well as going beyond the existing development limits and so into the ‘open
countryside’. On this basis alone, the reason given for the exclusion of the Alternative Site is
incredulous.
In addition to the above, the inconsistency of the decision is in itself an indication that the
Plan is unsound, as the process of assessment of sites undertaken by the Council has
clearly been a flawed one. The examples below (although there are numerous throughout
the Plan) provide an indication of where the Council has allocated housing sites beyond the
existing built form, making it impossible to understand why they should then apply a
completely counter logic with regards to the exclusion of our Client’s land.

Plan C Plan D
(Allocation PrC3/h4) (Allocation PrC3/h18)
The allocation of the Alternative Site would be in line with established planning principles
(i.e. not lead to the coalescence of settlements) and be consistent with it and the
assessment approach of the Council in relation to proposed allocations.
On the basis of the above, we consider the sites exclusion to be an illogical and erroneous
decision by the Council and consider therefore that the LDP as it stands is “unsound” and
fails to meet the required Tests of Soundness.

In addition, we consider that alternative allocations within the wider Cluster that Llanarthne
forms part of (discussed below) are neither appropriate nor deliverable. We consider
therefore that the land edged red in Plan A, should be allocated for residential development
under the provision of Policy HOM1 of the Carmarthenshire Local Development Plan. This
formal representation letter therefore supplements the following documents, which comprise
a complete submission to the 2nd Deposit LDP Consultation stage:

- Completed Deposit LDP Representation Form
- Completed Integrated Sustainability Appraisal form
- Copy of Candidate Site Submission Report (August 2018)
- Letter of Support from Morgan Construction Wales

Response to Council’s Reasons for Non-Allocation of Site
Sufficient Residential Land Allocated Within Settlement
As detailed above, we are deeply concerned with the Council’s decision to not allocate the
land in question and understand that this may be because the Council holds the view that
alternative allocations within the wider Cluster it forms part of will deliver sufficient housing
for the area during the Plan period. This is in our view wholly incorrect.
Under the current provision of the Deposit LDP, the Cluster has a range of proposed
residential allocations. Having undertaken a comprehensive review of the proposed
allocations put forward by the 2nd Deposit LDP for the Cluster in question, it has been
identified that a number have significant questions over their ability to be delivered within the
Plan period, including the following:

Ref. No. Site Name Units
PrC1/h4 Land off Parc y Delyn 17
PrC1/MU1 West Carmarthen 700
PrC1/MU2 Pibwrlwyd 247
SeC1/h4 Cae Canfas, Heol Llanelli, Pontyates 8
SuV4/h1 Adjacent Fron Heulog, Cynwyl Elfed 6
SuV12/h1 Adj. Gwyn Villa, Llanpumpsaint 20
Table 1

As a result of the above – all of which have been allocated in previous development plans -
separate objections to their inclusion with the LDP have been made. This is due to the fact
that to continue to allocate such sites for residential development results in the Plan being
unsound. Alternative sites, such as that put forward by our Clients, must therefore be
considered and brought forward in order to address this deficiency and ensure that the Plan
is sound in all respects.

In conclusion, this Representation to the 2nd Deposit Draft of the Revised LDP has sought to
examine the Council’s reasons for non-allocation of a Candidate Site. It has successfully
addressed the reasons put forward by the Authority for its exclusion and has highlighted that
currently proposed allocations are undeliverable.
We therefore respectfully request that this Representation be given careful examination, and
consequently the land in question be allocated for residential development as part of the
Carmarthenshire Local Development Plan to ensure that the document passes all the
relevant tests of soundness.