Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin

Remove site 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 off Parc y
Delyn (LDP Ref. No. PrC1/h4) 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 17 residential units.

Plan A
(Extract of Proposals Map for Carmarthen and Land off Parc y Delyn 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 PrC1/h4 was considered as part of this process and as a result the Council concluded as follows:

“Site to be allocated with reference PrC1/h4.”
It is clear from the above 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 is greenfield in nature with its topography sloping gradually from north to south. The eastern perimeter of the allocation is bordered by the Parc y Delyn residential estate while the remaining borders adjoin further greenfield land as can be seen from the aerial photograph below (outlined in red below).

Photograph 1
(Extract from Google Earth – June 2021)

Pedestrian access to the allocation is currently gained via Parc y Delyn, that being off Penlan Road (see below).

Photograph 2
(Streetscene of Access to Allocation Site)

There are also 2 trees located at the acces to the site that have Tree Protection Orders (TPO) placed upon them with reference W13 as can be seen in Photograph 3 below. This would therefore indicate that an adoptable road to the serve the Allocation would be impossible, which in itself would question its deliverability.

Photograph 3
(Map Showing TPO’s in 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. Given the important biodiversity features of the site and the two TPO’s at the sites
access point meaning that the site would not accessible by vehicles, the allocation in question would not be fit, nor sustainable for residential allocation.

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.

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 Adjacent
Fron Heulog, Cynwyl Elfed (LDP Ref. No. SuV4/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 Cynwyl Elfed and land Adjacent Fron Heulog 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 SuV4/h1 was considered as part of this process and as a result the Council concluded as follows:
“Site to be allocated for residential development with site reference SuV4/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.

The allocation is both greenfield and brownfield in nature with its topography being generally level. The southern and northern perimeters of the site are bordered by residential properties while the western perimeter is bordered by mature vegetation, trees and hedgerows 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 access road into the site off the B4333, that being the main road running through Cynwyl Elfed (see below).

Photograph 2
(Streetscene of B4333)

Full Planning Permssion was granted for the eastern half of the site in 2009 for a Road and Plot Layout for 4 Dwellings (W20990). The new road was developed, however, since that date only 1 dwelling has been completed under application W/39955 in 2019. The western half of the site then has outline planning permission for Housing Developemnt (W/39856).
However, this outline permission fails to provide a detailed site layout plan showing the plans for future development.

The site makes up part of an allocation in the Carmarthenshire Local Development Plan (2014) under Allocation SC9/h1 as well as the Carmarthenshire Unitary Development Plan (2006) under allocation CL9/b as can be seen below.

Plan B
(Extract of current LDP Proposal Map for land Adjacent Fron Heulog (Adopted 2014))

Plan C
(Extract of Carmarthenshire UDP Proposal Map for land Adjacent Fron Heulog (Adopted 2006))

It can then be said that despite having almost 20 years of support for the principle of residential development at the historic allocation from the Council, only 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.

Remove site 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 Adj. Gwyn
Villa, Llanpumsaint (LDP Ref. No. SuV12/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 20 residential units.

Plan A
(Extract of Proposals Map for Llanpumsaint and land adj. Gwyn Villa 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 SuV12/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 SuV12/h1, to reflect the existing allocation.”
It is clear from the above 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. We note that he site has not been the subject of any application for planning permission, and therefore its continued allocation must surely be questioned.

The allocation is greenfield in nature with its topography being generally level. The southern and eastern perimeters of the site are bordered by residential properties while the western and northern perimeters are bordered by mature vegetation, trees and hedgerows 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 unknown, however, the eastern perimeter borders the C1301, that being the main road running through Llanpumsaint (see below).

Photograph 2
(Streetscene of C1301)

There have been no planning applications made relating to the allocation in question to date.
The site makes up par of an allocation in the Carmarthenshire Local Development Plan (2014) under Allocation SC19/h3 (as can be seen below).

Plan B
(Extract of current LDP Proposal Map for land Adj. Gwyn Villa (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.

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 at Ynys
Las, Llwynhendy (LDP Ref. No. PrC2/h16) 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 33 residential units.

Plan A
(Extract of Proposals Map for Ynys Las, Llwynhendy 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/h16 was considered as part of this process and as a result the Council concluded as follows:
“Site to be retained as a residential allocation. Site to be allocated with reference PrC2/h16.”
It is clear from the above that the Council considers that the site is deliverable for the purposes of 33 houses, although it is unclear on what basis this conclusion has been made, as full planning permission has yet to be granted with any certainty.

The allocation is brownfield in nature with its topography being generally level. The southern boundary is bordered by open green space. Residential roads border the northern, eastern and western borders with residential properties running along each road 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 along an existing access point off Ynys Las, that being a residential street as can be seen below.

Photograph 2
(Streetscene of Ynys Las)

A Prior Notification Application for the Demolition of all school buildings was granted in 2011. Since then, full planning permission has been sought for the Proposed residential development comprising 33no. dwellings and 84-bed care home with associated access, car parking, landscaping and infrastructure works in January 2021. A decision has not been made by the council regarding this application due to them awaiting a S106 agreement.
The site made up part of an allocation in the Carmarthenshire Local Development Plan (2014) under allocation GA2/h41 as well as the Carmarthenshire Unitary Development Plan (2006) under allocation PDB5 as can be seen below.

Plan B
(Extract of Current Carmarthenshire LDP Proposal Map for Allocation Site (Adopted 2014))

Plan C
(Extract of Carmarthenshire 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.

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 at Box
Farm (LDP Ref. No. SeC7/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 7 residential units.

Plan A
(Extract of Proposals Map for Box Farm 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 SeC7/h1 was considered as part of this process and as a result the Council concluded as follows:
“Site to be retained as a residential allocation. Reference is made to SR/086/076 below. Reference is made to planning application S/33213 and PL/00012. Site to be allocated with reference SeC7/h1.”

It is clear from the above that the Council considers that the site is deliverable for the purposes of 7 houses, although it is clear that this conclusion has only been made based on a renewed outline planning permission.
The allocation is greenfield in nature with its topography being generally level. The northern and eastern perimeters of the site are bordered by residential properties. The southern western boundaries is then bordered by mature vegetation and hedgerow 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 Aber Llwchwr, that leads to an agricultural access point to the site (see below).

Photograph 2
(Streetscene of Aber Llwchwr)

Outline Planning Permission was granted in May 2017 for the Residential Development (S/33213). A variation of condition application was then submitted and granted for the extension of time to submit reserved matters in July 2022. This variation of condition application demonstrates the developers lack of desire to develop the site through the submission of a firm, detailed plan in an area that is highly desirable, marketable, and which is surrounded by high quality and executive residential development.
The site is allocated in the Carmarthenshire Local Development Plan (2014) under allocation GA2/h50 as well as the Carmarthenshire Unitary Development Plan (2006) under allocation GR2/3 (as can be seen below).

Plan B
(Extract of Current Carmarthenshire LDP Proposal Map for Allocation Site (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.

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 at Golwg
yr Afon, Llangennech (LDP Ref. No. SeC7/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 Proposals Map extract below and is
proposed for allocation in the 2nd Deposit LDP for the purposes of 50 residential units.

Plan A
(Extract of Proposals Map for Golwg yr Afon 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 SeC7/h3 was considered as part of this process and as a result the Council concluded as follows:
“Site to be retained as a residential allocation as per candidate site area. Site to be allocated with reference SeC7/h3.”
It is clear from the above that the Council considers that the site is deliverable for the purposes of 50 houses, although it is not clear on what basis this conclusion has been made, especially given the important biodiversity features as well as the Tree Protection Orders that surround the site boundary.

The allocation is greenfield in nature with its topography being generally level. The entire site is covered by mature vegetation and trees. The northern, southern and western perimeters of the site are bordered by residential properties. The eastern boundary is bordered by further mature vegetation, hedgerows and trees 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 unknown, however, the site adjoins Golwg yr Afon that being a residential site west of the allocation (see below).

Photograph 2
(Streetscene of Aber Llwchwr)

There have been no planning applications made relating to residential development at the allocation site. The eastern and southern boundaries of the allocation are lined with Tree
Protection Orders (TPO). This could indicte that the site is potentially undeliverable due to expanse and need to intergrate with those protected specimines and consequently the biodiversity features of the immediate area.
The site is allocated in the Carmarthenshire Local Development Plan (2014) under allocation GA2/h52 (as can be seen below).

Plan B
(Extract of Current Carmarthenshire LDP Proposal Map for Allocation Site (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.
The site is not being actively marketed by its owners (County Council), which is surprising since the location where executive housing has seen much sought in the last 10 years.

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.

Remove site from Plan

Further to the publication of the above document, we have been instructed 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 (LDP) in relation to the allocation for residential development of Tirychen
Farm, Penybanc (LDP Ref. No. PrC3/h4) 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 Penybanc and Tirychen 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 PrC3/h4 was considered as part of this process and as a result the Council concluded as follows:
Site to be retained as a residential allocation for a lower number of dwellings with the remainder of the site being delivered beyond the Revised LDP's lifetime. Site reference is PrC3/h4.
It is clear from the above therefore 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.
It should be noted that the site was also allocated in the Carmarthenshire Unitary Development Plan (2006), with an extract from the UDP’s Proposals Map showing the allocation in question shown below.

Plan B
(Extract of UDP Proposals Map for Allocation Site)

The allocation itself is greenfield in nature with an undulating topography. It consists of a series of enclosures, many of which contain mature vegetation, trees and hedgerows, 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 from Newtown Close, a narrow road, served by a single or no footway for its extent (see below).

Photograph 2
(streetscene of Newtown Road)

Full planning permission was first granted for residential development on the allocation as far back as 1992 (Application D6/19332), which subsequently lapsed. The site continued to be allocated however for the purposes of residential development within the Dinefwr Local Plan (1996), the subsequent Carmarthenshire Unitary Development Plan (2003) and finally the Carmarthenshire Local Development Plan (2014).
A number of outline planning permissions have been granted since the 1992 permission lapsed, but following a recent refusal of planning permission under Application PL/00919 (based on insufficient information to demonstrate no detrimental impact on biodiversity interests on the site), the allocation currently does not benefit from a ‘live’ planning permission. Despite therefore over 30 years of support for the principle of residential development at the site 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 produce 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, particularly in light of recent contrasting refusals for residential development relating to the impact of such development on biodiversity interests on the site.

Test 3 – Will the Plan deliver?
The allocation fails the test of soundness as the site is clearly unable to deliver any new housing. The 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 a 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 delivered.
In addition to biodiversity interest constraints, we understand from speaking with interested developers and housing associations who have expressed interest in the site that the landowners land value aspirations resulting in any development of the site being financially unsustainable. This is qualified by the lack of development on the site for over 30 years. The Council has failed to provide any evidence to the contrary.

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.

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 Heol Gelynen,
Brynamman (LDP Ref. No. SeC9/h2) 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 Brynamman and Allocation Site)

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 SeC9/h2 was considered as part of this process and as a result the Council concluded as follows:
“Site to be allocated with reference SeC9/h2.”
It is clear from the above therefore 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.
The allocation is greenfield in nature with its topography being relatively level while the site is raised above the road level. Much of the site is covered with mature vegetation, trees and hedgerows, as can be seen from the aerial photograph below (outlined in red below).

Photograph 1
(Extract from Google Earth – June 2021)

Access to the site is currently gained from Heol Gelynen, being a narrow, dead end road, located to the south of Brynamman (see below).

Photograph 2
(Streetscene of Heol Gelynen, Brynamman)

Prior notification for the Demolition of and removal of all rubble from six cornish houses was granted on the site in 2007, this being the only planning application relevant to the allocation.
Altough the site was not allocated for the purposes of residential development in the Carmarthenshire Local Development Plan (2014), the site was within the defined settlement limits of Brynamman (see below).

Plan B
(Extract of Current Proposal Map for Brynamman)

As of yet no planning application regarding residential development have been submitted at the site and therefore not a single housing unit has been delivered to date. This in turn, questions its deliverability and reliability as a housing allocation.

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 and reliability 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 and reliability 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 deliverability of the allocation site is of concern due to a number of factors. The first concern being that of the highway infrastructure along Heol Gelynen. The narrow road would not be satisfactory for the development of 8 new residential units along the street as well as issues being caused during the construction period. The second factor of concern is that of biodiversity. The construction of 8 new dwellings at this location would have detrimental impacts on the biodiversity interests on the site. As previously mentioned, the site is covered in mature vegetation, trees and hedgerows. The allocation of this site 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.

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.

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.