Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin

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 Adj.
Neuadd, Llanybydder (LDP Ref. No. SeC13/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 10 residential units.

Plan A
(Extract of Proposal Map for Llanybydder and Land Adj. Y Neuadd 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 SeC13/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 SeC13/h1.”
It is clear from the above therefore that the Council considers that the site is deliverable for the purposes of 10 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 an overgrown state. The topography of the site then slopes gently from the west to the east. The northern boundary of the site is bordered by residential properties, while the southern boundary is bordered by what seems to be a derelict building. Both eastern and western boundaries are bordered by roads, those being Heol y Neuadd and the A485, 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 Heol y Neuadd, that being a very narrow road off the A485 being the main road running north to south through Llanybydder (see below).

Photograph 2
(Streetscene of Heol Y Neuadd)

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 (T3/11/h1) as well as the Carmarthenshire Unitary Development Plan (2006) (as can be seen below).

Plan B
(Extract of current LDP proposal map for Land to r/o Dolcoed (Adopted 2014))

Plan C
(Extract of Carmarthenshire UDP proposal map for Allocation (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 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 Blossom
Garage, Pencader (LDP Ref. No. SeC14/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 20 residential units.

Plan A
(Extract of Proposal Map for Pencader and Blossom Garage 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 SeC14/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 SeC14/h2.”
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. However, on both the LDP 2nd Deposit Written Statement and the Proposal Map, this allocation is referenced as SeC14/h1 - that being separate to the adjoining SeC14/h2.

The allocation itself is brownfield in nature and is currently a large garage/workshop known as ‘Blossom Garage’. The topography of the site is then generally level. The northern and eastern boundaries of the site are bordered by mature vegetation and trees while the western boundary is bordered by the B4459. Directly to the south is a separate housing allocation referenced SeC14/h2, as can be seen from the aerial photograph below (allocation outlined red).

Photograph 1
(Extract from Google Earth – June 2021)

Access to the allocation is currently gained via the B4459, that being the main road running north to south through Pencader (see below).

Photograph 2
(Streetscene of B4459)

A Full Planning Application was made to the Council for the Proposed Residential Development of 16 Dwellings with Access and Parking (W/39283) which was subsequently refused in August 2019. The application was refused for a number of reasons including the applicant not signing a Section 106 agreement as well as the site being within a Special Area of Conservation (Afon Teifi). The failure of the applicant to commit to signing the S106 Agreement in itself puts the deliverability of the site in serious doubt.
The site has not been allocated in either the Carmarthenshire Local Development Plan (2014) or the Carmarthenshire Unitary Development Plan (2006) for the purposes of residential development.
Despite seeking permission for the residential development of 16 dwellings, the application was refused and therefore 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?
An application has been made relating to the allocation in question, however, the application was refused for a number of reasons including the applicant not signing a Section 106 agreement as well as it being within a Special Area for Conservation. This indicates that the allocation is not deliverable as a site for residential development.

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 adj
Maescader, Pencader (LDP Ref. No. SeC14/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 Proposal Map extract below and is
proposed for the allocation in the 2nd Deposit LDP for the purposes of 24 residential units.

Plan A
(Extract of Proposal Map for Pencader and Land adj. Maescader 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 SeC14/h2 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 SeC14/h2.”
It is clear from the above therefore that the Council considers that the site is deliverable for the purposes of 24 houses, although it is not clear on what basis this conclusion has been made.
The allocation itself is greenfield in nature and is currently an open field to the rear of residential propserties. The topography of the site is then generally level. The northern, eastern and southern boundaries of the site are bordered by mature vegetation and trees while the western boundary is bordered by residential properties, as can be seen from the aerial photograph below (allocation outlined red).

Photograph 1
(Extract from Google Earth – June 2021)

Access to the allocation is currently gained via the B4459, that being the main road running north to south through Pencader (see below).

Photograph 2
(Streetscene of B4459)

As can be seen from Photograph 2 above, the access point along the B4459 is a very narrow, single track which would not be suitable for residential development. The poor access point to the site should therefore deem the allocation undeliverable.
There have been no planning applications made in relation to the allocation in question to date. The site made up part of the residential allocation SC20/h5 within the Carmarthenshire Local Development Plan (2014) as can be seen below.

Plan B
(Extract of Current LDP Proposal Map for Pencader and Land adj. Maescader Allocation)

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 Maes y Bryn,
Capel Iwan (LDP Ref. No. SuV38/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 6 residential units.

Plan A
(Extract of Proposal Map for Capel Iwan and Maes y Bryn 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 SuV38/h1 was considered as part of this process and as a result the Council concluded as follows:
“Part of the site to be allocated for with reference SuV38/h1 to allow for small scale development. Large scale development within Capel Iwan is limited due to the village falling within the phosphate sensitive SAC catchment.”
It is clear from the above therefore that the Council considers that the site is deliverable for the purposes of 6 houses, although it is not clear on what basis this conclusion has been made, especially due its position within the phosphate sensitive SAC catchment.
The allocation itself is greenfield in nature and currently hosts a number of what seems to be garden sheds. The topography of the site is then generally level. The eastern and southern boundaries of the site are bordered by mature vegetation and trees. To the north pf the site is a residential property while to the east is further open field, as can be seen from the aerial photograph below (allocation outlined red).

Photograph 1
(Extract from Google Earth – June 2021)

Access to the allocation is currently gained via an existing agricultural access point along the U5450, that being the main road running through Capel Iwan (see below).

Photograph 2
(Streetscene of the U5450)

There have been no planning applications made in relation to the allocation in question to date. The site made up part of the residential allocation SC7/h2 within the Carmarthenshire Local Development Plan (2014) as can be seen below.

Plan B
(Extract of Current LDP Proposal Map for Capel Iwan and Maes y Bryn Allocation)

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 Adj. yr
Hendre, Llanfihangel ar Arth (LDP Ref. No. SuV39/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 7 residential units.

Plan A
(Extract of Proposal Map for Llanfihangel ar Arth and land Adj. yr Hendre 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 SuV39/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 SuV39/h1.”
It is clear from the above therefore that the Council considers that the site is deliverable for the purposes of 7 houses, although it is not clear on what basis this conclusion has been made.
The allocation itself is greenfield in nature with the topography of the site sloping from the south to the north. The eastern, southern and western boundaries of the site are bordered by mature vegetation and trees. To the north of the site is a public house known as the ‘Eagle Inn’, as can be seen from the aerial photograph below (allocation outlined red).

Photograph 1
(Extract from Google Earth – June 2021)

Access to the allocation is currently gained via an existing agricultural access point along the B4459, that being the main road running through the village (see below).

Photograph 2
(Streetscene of the B4459)

Outline Planning Permission was sought under application W/39945 for the Proposed Development of 8 Residential Units back in 2019. However, this application was withdrawn in February 2022 meaning that there are no current planning application relating to the allocation in question to date.
The site made up part of the residential allocation SC20/h1 within the Carmarthenshire Local Development Plan (2014) as well as the Carmarthenshire Unitary development Plan under allocation CL19/d (2006) as can be seen below.

Plan B
(Extract of Current LDP Proposal Map for Llanfihangel ar Arth and land Adj. yr Hendre Allocation)

Plan C
(Extract of Carmarthen UDP Proposal Map for Llanfihangel ar Arth and land Adj. yr Hendre Allocation)

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 Cilgwyn
Bach, Pontyweli (LDP Ref. No. SuV41/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 Proposal Map extract below and is
proposed for the allocation in the 2nd Deposit LDP for the purposes of 14 residential units.

Plan A
(Extract of Proposal Map for Pontyweli and Cilgwyn Bach 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 SuV41/h2 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 SuV41/h2.”
It is clear from the above therefore that the Council considers that the site is deliverable for the purposes of 14 houses, although it is not clear on what basis this conclusion has been made.
The allocation itself is greenfield in nature with the topography of the site being generally level. The eastern and southern boundaries of the site are bordered by mature vegetation and trees. To the north of the site is a row of residential properties while to the west is the B4624 (Heol y Dderwen), as can be seen from the aerial photograph below (allocation outlined red).

Photograph 1
(Extract from Google Earth – June 2021)

Access to the allocation is currently gained via an existing agricultural access point along the B4264, that being the main road running through the village (see below).

Photograph 2
(Streetscene of the B4264)

Outline Planning Permission was sought and granted under application W/30682 for Residential Development in 2015. Since this date there have been a number of non-material amendments and variation of condition application submitted however, to this date, no residential development has taken place at the site.
The site made up part of the residential allocation SC21/h1 within the Carmarthenshire Local Development Plan (2014) as well as the Carmarthenshire Unitary development Plan under allocation CL23/a (2006) as can be seen below.

Plan B
(Extract of Current LDP Proposal Map for Pontyweli and Cilgwyn Bach Allocation)

Plan C
(Extract of Carmarthen UDP Proposal Map for Pontyweli and Cilgwyn Bach Allocation)

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 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 opp.
Llangadog C.P. School (LDP Ref. No. SeC17/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 16 residential units.

Plan A
(Extract of Proposals Map for Llangadog and Land opp. Llangadog C.P. School 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 SeC17/h1 was considered as part of this process and as a result the Council concluded as follows:
“Part of site taken up by a school car park. Remainder of site S/090/003 to be allocated for residential development with reference SeC17/h1.”
It is clear from the above that the Council considers that the site is deliverable for the purposes of 16 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. The northern, eastern and western perimeters of the allocation are covered with mature vegetation, trees and hedgerows. The southern boundary is bordered by the schools car park as can be seen from the aerial photograph below (outlined in red below) as well as Photograph 2 below.

Photograph 1
(Extract from Google Earth – June 2021)

Access to the allocation is currently gained via the A4069, that being the main road running through Llangadog (see below).

Photograph 2
(Streetscene of Access to Allocation Site)

There have been no planning applications made in relation to the allocation in question to date.
The site makes up part of an allocation in the Carmarthenshire Local Development Plan (2014) under Allocation (T3/10/h1), and previously under Allocation T4/a of the Carmarthenshire Unitary Development Plan (2006) (as can be seen below).

Plan B
(Extract of current LDP Proposal Map for Land opp. Llangadog C.P. School (Adopted 2014))

Plan C
(Extract of Carmarthen UDP Proposal Map for Allocation Site (Adopted 2006))

Whilst we do not object to the principle of the allocation for residential development, we do object to the number of units assigned to the allocation. Based on our experience elsewhere in areas affected by the phosphate regulations, sites within sewered areas have to forfeit 25% of their site area to accommodate the necessary foul water treatment infrastructure. When this and the requirements for a SUDS scheme are taken into account, it is clear that 16 units on the allocation is undeliverable and that a lower number of between 10-12 should be assigned.

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 to the level expected 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 to the level indicated 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 the level of new housing it is expected to.

In summary, we object to the inclusion of the allocation for housing 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 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.

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 Between
Clayton Road and Bronallt Road, Hendy (LDP Ref. No. SeC6/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 20 residential units.

Plan A
(Extract of Proposals Map for Land Between Clayton Road and Bronallt Road 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 SeC6/h2 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 an integrated scheme with site T3/7/h5 below. Reference is made to SR/069/009 below. Site to be allocated as an integrated scheme within the revised LDP with reference SeC6/h2.”

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.
The allocation is greenfield in nature with its topography sloping gently from north to south. The northern, eastern and western perimeters of the site are bordered by residential properties. The southern boundary is then bordered by further open pasture 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 Bronallt Road, that being a residential street running north to south through Hendy (see below).

Photograph 2
(Streetscene of Bronallt Road)

Full Planning Permission was granted in April 2018 for the Construction of 8 houses together with associated vehicular and pedestrian accesses, car parking, landscaping, drainage and other ancillary development (S/34537). However, to our understanding, this development is
yet to be completed. The application also only relates to part of the allocation, with no application made to the remainder of the site.
The site is allocated in the Carmarthenshire Local Development Plan (2014) under allocation T3/7/h5 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))

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, only 5 housing units has been delivered to date to a site allocated for 20 units. It is submitted that only 8 units should be allocated at this site to reflect the extent planning permission and the remainder omitted in the same manner as the Council omitted T3/7/h4 in the last Site Assessment Review.

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 Burry
Port Harbourside (LDP Ref. No. SeC4/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 364 residential units.

Plan A
(Extract of Proposals Map for Burry Port Harbourside 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 SeC4/h2 was considered as part of this process and as a result the Council concluded as follows:

“Site to be allocated for residential development. Reference is made to the planning history - notably references S/38106 and S/38251. Site to be allocated with reference SeC4/h2.”

It is clear from the above that the Council considers that the site is deliverable for the purposes of 364 houses, although it is not clear on what basis this conclusion has been made. We suspect it is purely upon the outline permission granted by the Council as Local Planning Authority with the Authority also acting as landowners.
The allocation is brownfield in nature with its topography being generally level. The northern, and western perimeters of the site are bordered by the B4311 and a separate road leading to the Lifeboat Station. The southern boundary is bordered by further brownfield use with the eastern boundary bordered by open grassland 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 exit off a roundabout located on the B4311 (see below).

Photograph 2
(Streetscene of B4311)

Outline Planning Permission was granted in 2015 for the demolition of existing buildings as well as the consturction of up to 134 residential units with assosiated infrastructure works (S/30598). A second, seperate Outline Planning Permission was then granted in 2016 for the construction of up to 230 homes (S/30678). Since these dates, there have only been variation of condition applications submitted and approved for the extension of time to submit Reserved Matters. There have been no further applications submitted to propose any firm
details for any further development of the site. We find this surprising given the fine coastal position of the site with panoramic views of the harbour and seascape.
We also note that there is a condition on Outline Permission S/30678, stating that the components of a scheme to deal with the risks associated with contamination of the site must be submitted and approved by the Council. This suggests that there might be a number of issues in terms of contamination of the land which could in turn affect the possibility for development.
The site makes up part of an allocation in the Carmarthenshire Unitary Development Plan (2006) under allocation GR2/E1 as can be seen below. The allocation was then removed from the Carmarthenshire Local Development Plan (2014) due to flooding concerns.

Plan B
(Extract of Carmarthenshire UDP Proposal Map for Burry Port Harbourside (Adopted 2006))

Despite having support for the principle of residential development at the historic allocation from the Council, not a single housing 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.

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.