Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin

Remove the 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 at Cae
Linda (LDP Ref. No. SeC8/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 45 residential units.

Plan A
(Extract of Proposals Map for Cae Linda 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 SeC8/h2 was considered as part of this process and as a result the Council concluded as follows:
“Site Allocation to be reduced in size. Parts of the site has planning permission. Site to be allocated with reference SeC8/h2.”

It is clear from the above that the Council considers that the site is deliverable for the purposes of 45 houses, although it is unclear on what basis this conclusion has been made. No justification is put forward as to how a figure of 45 units is arrived at?
The allocation is greenfield in nature with its topography sloping from south to the north. The southern and eastern perimeters of the site are bordered by residential properties. The northern and western boundaries are then bordered by open green space and 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 Cae Linda, that being a residential street as cam be seen below.

Photograph 2
(Streetscene of Cae Linda)

Outline Planning Permission was granted in September 2020 for the Residential Development (S/37639). An approval of Reserved Matters was them granted for Approval of Reserved Matters on S/37639 (Phase 1 – 12 x 5 bedroom dwellings, 2 x 2 bedroom dwellings) in May 2022. However, this application only amounts for 14 dwellings on a site allocated for 45 dwellings.
The site is allocated in the Carmarthenshire Local Development Plan (2014) under allocation T3/4/h6 as well as the Carmarthenshire Unitary Development Plan (2006) under allocation T9/c (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 have been delivered to date. It is submitted that the allocation to be removed given that the site is within settlement limits, but the rate of build at the site would not be in line with that of the plan period.

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 housing allocation SeC8/h3 from the Plan.

Further to the publication of the above document, we have been asked by our Clients to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so we consider it necessary to
make a formal representation to the “soundness” of the Carmarthenshire Deposit Local
Development Plan in relation to the allocation for residential development at land at Golwg
Gwendraeth (LDP Ref. No. SeC8/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 141 residential units.

Plan A
(Extract of Proposals Map for Golwg Gwendraeth 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 SeC8/h3 was considered as part of this process and as a result the Council concluded as follows:
“Allocation carried forward. The site is part of the large scale Ffos Las development with two developers on board to deliver the site during the plan period. Site has been broken up into 2 and will be allocated with reference SeC8/h1 and SeC8/h3.”

It is clear from the above that the Council considers that the site is deliverable for the purposes of 141 houses, although it is unclear on what basis this conclusion has been made.
The allocation is greenfield in nature with its topography being generally level. The northern boundary is bordered by a modern residential development. Heol Waunhir borders the southern boundary of the western part of the allocation, with open green space being located to the south of the eastern part of the allocation 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 Heol Waunhir, that being a residential street as can be seen below.

Photograph 2
(Streetscene of Heol Waunhir)

Outline Planning Permission was first granted in June 2012 for the Residential Development (up to 280 dwellings) (W/20882) which included the separate allocation (SeC8/h1) north of the allocation in question. A variation of condition application (PL/02850) was granted to allow additional time for the submission of reserved matters, which were then submitted and granted (PL/03790) in September 2022 for 141 dwellings.
The site made up part of an allocation in the Carmarthenshire Local Development Plan (2014) under allocation SC40/h3 (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 on this part of the Ffos Las Development Site. We would submit that the level of housing to be absorbed by the local housing market has been exhausted and consequently there is no further demand for more housing at the site.

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.

Deallocate PrC2/h1 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 Beech
Grove, Pwll (LDP Ref. No. PrC2/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 10 residential units.

Plan A
(Extract of Proposals Map for Pwll and Beech Grove 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/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. Site to be allocated with reference PrC2/h1.”

It is clear from the above 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. What evidence in the absence of any planning applications on the site warrants such a conclusion?
The allocation is greenfield in nature with its topography sloping from east to west. The southern and eastern perimeters of the site are bordered by residential properties while the western boundary is bordered by Beech Grove and northern boundary is bordered by further greenfield land 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 western perimeter borders Beech Grove (see below).

Photograph 2
(Streetscene of Beech Grove)

There have been no planning applications made relating to the allocation in question to date. We find this surprising given the high quality of exectutive homes built in recent years upon the mid-hillslopes of Pwll. We would question whether the Council, as landowners, has commited to any marketing strategy for the site, and if not, why not?
The site makes up par of an allocation in the Carmarthenshire Local Development Plan (2014) under Allocation GA2/h1 (as can be seen below).

Plan B
(Extract of current LDP Proposal Map for Beech Grove (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.

Deallocate PrC2/h4 from the Plan.

Further to the publication of the above document, we have been asked by our Clients to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so we consider it necessary to
make a formal representation to the “soundness” of the Carmarthenshire Deposit Local
Development Plan in relation to the allocation for residential development at land at North
Dock (LDP Ref. No. PrC2/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 210 residential units.

Plan A
(Extract of Proposals Map for North Dock 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/h4 was considered as part of this process and as a result the Council concluded as follows:
“Site to be retained as an allocation - but specifically for residential development as opposed to mixed use as a reflection of planning application S/38285. The development limits in the vicinity will be amended so that they are drawn tightly around the allocation. Site to be allocated (based on S/38285) with reference PrC2/h4.”

It is clear from the above that the Council considers that the site is deliverable for the purposes of 210 houses, although it is not clear on what basis this conclusion has been made. We suspect it is purely upon an outline permission granted by the Council as Local Planning Authority also acting as landowners.
The allocation is brownfield in nature with its topography being generally level. The southern perimeter of the site is bordered by residential properties while the western boundary is
bordered by Llanelli Beach. The northern boundary is bordered by a train line 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 Traeth Ffordd, that being the road that surrounds Llanelli’s North Dock (see below).

Photograph 2
(Streetscene of Traeth Ffordd)

Outline Planning Permission was granted in 2021 for the Construction of a residential development of up to 210 units with associated landscaping and infrastructure works (S/38285). However there have been no applications made to further this development to date.
The site makes up part of an allocation in the Carmarthenshire Local Development Plan (2014) under Allocation GA2/MU7 as well as the Carmarthenshire Unitary Development Plan (2006) under allocation PDB10 as can be seen below. Mixed uses of Housing, Employment and Leisure were promoted in those plans, but without firm planning permissions being secured. We find this surprising given the fine coastal position of the site adjoining a high quality housing development.

Plan B
(Extract of current LDP Proposal Map for Beech Grove (Adopted 2014))

Plan C
(Extract of Carmarthenshire UDP Proposal Map for Beech Grove (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.
We are led to believe that the 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.

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 Cwm y
Nant, Dafen (LDP Ref. No. PrC2/h22) 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 202 residential units.

Plan A
(Extract of Proposals Map for Cwm y Nant 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/h22 was considered as part of this process and as a result the Council concluded as follows:
“Part of the allocation was not included in candidate site submission SR/086/025. Part of the remainder to be retained as a residential allocation as part of a wider area at Cwm Y Nant. Reference is made to site SR/086/025 et al below. Site to be allocated (part) with reference PrC2/h22.”
“Site(s) to be retained as a residential allocation. Reference is made to site GA2/h30 above. Site to be allocated with reference PrC2/h22 (only part of GA2/h30).”

It is clear from the above that the Council considers that the site is deliverable for the purposes of 202 houses, although it is not clear on what basis this conclusion has been made.
The allocation is greenfield in nature with its topography sloping gently from the south to the north. The southern perimeter of the site is bordered by residential properties while the
western and northern boundaries are bordered by industrial uses. The eastern boundary is then bordered by further greenfield land 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 north western perimeter of the site borders Nant y Gro (see below).

Photograph 2
(Streetscene of Nant y Gro)

Outline Planning Permission was first granted for the Proposed Residential Development for 26 Bungalows (S/25729) in the southernmost part of the allocation. Outline Planning Permission was also granted for the whole site in 2021 for the Proposed Construction of up
to 202 Units with Associated Landscaping and Infrastructure Works (S/40692). However there have been no applications made to further this development to date.
The site makes up part of an allocation in the Carmarthenshire Local Development Plan (2014) under Allocation GA2/h3 as well as the Carmarthenshire Unitary Development Plan (2006) under allocation GR2/18 as can be seen below.

Plan B
(Extract of current LDP Proposal Map for Cwm y Nant (Adopted 2014))

Plan C
(Extract of Carmarthenshire UDP Proposal Map for Cwm y Nant (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. 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.

Remove housing allocation PrC2/h23 from the Plan.

Further to the publication of the above document, we have been asked by our Clients to review its contents, policies and proposals and advise them of any aspects we believe would unreasonably affect their aspirations and interests. In doing so we consider it necessary to make a formal representation to the “soundness” of the Carmarthenshire Deposit Local Development Plan in relation to the allocation for residential development at land at Dafen East Gateway (LDP Ref. No. PrC2/h23) under the provisions of Policy HOM1. The proposed allocation has been fully assessed and in considering its context and background (summarised below) it is considered that its continued inclusion will lead to the Plan failing the 3 Tests of Soundness for the reasons set out below.

Site Background and Context
The allocation relates to the land shaded brown on the Proposals Map extract below and is proposed for allocation in the 2nd Deposit LDP for the purposes of 150 residential units.

Plan A
(Extract of Proposals Map for Dafen East Gateway Allocation)

As part of the current consultation process into the 2nd Deposit LDP, the Council have again published a “Site Assessment Table” (2023), which provides details of the Council’s analysis of each received Candidate Site submission and existing allocations within the current adopted LDP. Proposed allocation PrC2/h23 was considered as part of this process and as a result the Council concluded as follows:
“Site to be retained as a residential allocation. Pending application 150 dwelling has been submitted. Site to be allocated with reference PrC2/h23.”

It is clear from the above that the Council considers that the site is deliverable for the purposes of 150 houses, although it is not clear on what basis this conclusion has been made.
The allocation is greenfield in nature with its topography sloping gently from the east to the west. The southern perimeter of the site is bordered by industrial warehouses while the eastern boundary is bordered by further greenfield land. The western boundary is then bordered by the A4138 as can be seen from the aerial photograph below (outlined in red below).

Photograph 1
(Extract from Google Earth – June 2021)

Access to the allocation is currently gained off Industrial Park Roundabout north of the site, that being off the A4138 (see below).

Photograph 2
(Streetscene of Industrial Park Roundabout)

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

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

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

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

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

Tests of Soundness
Based on the above information and the guidance documents provided by the Welsh Government and Council itself, it is considered that the inclusion of the adoption of the LDP in its current form with the inclusion of the allocation in question, would result in it failing to meet the requirements of the Tests of Soundness, for the reasons summarised below.

Test 1 – Does the Plan Fit?
The allocation fails the test of soundness as its inability to be delivered is in conflict with Paragraph 4.2.2 of Planning Policy Wales (Edition 11) requirements of national planning policy.

Test 2 – Is the Plan appropriate?
The allocation fails the test of soundness as its inability to be delivered would fail to address key issues set out by the Plan (housing supply). The Council’s decision to allocate the land appears to not have been done so on credible or robust evidence.

Test 3 – Will the Plan deliver?
The allocation fails to test the soundness as the site is clearly unable to deliver any new housing. The Welsh Governments Development Plans Manual (Edition 3) is quite clear with regard to rolling forward allocations and states that allocations “… rolled forward from a previous plan will require careful justification for inclusion in a revised plan, aligning with PPW. There will need to be substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered”. No evidence has been presented to demonstrate a change in circumstances to indicate the allocation will now be deliverable and so its continued allocation would lead to the plan being deemed unsound on this basis.

In summary, we object to the inclusion of the allocation in question on the basis of the above and that its inclusion within the Plan would result in the document being ‘unsound’.

We therefore respectfully request that this Representation be given careful examination, and that the allocation be removed to ensure that the document passes all the relevant tests of soundness.

That the allocated site be reduced in size to total only 300 units.

1.0 I NTRODUCTION
1.1 Evans Banks Planning Limited act for a number of landowners and have made formal representations in respect of those clients’ land interests in relation to the Carmarthenshire Replacement Local Development Plan (2018-21): Second Deposit Draft. Within those Representations, we have referred to previous Candidate Site submissions made in August 2018. The Council in response to those Candidate Site submissions have published a Site Assessment Table (January 2023). We have noted in rejecting Candidate Sites, the Council has on multiple occasions concluded that a Candidate Site should not progress and be allocated as “there is sufficient land allocated for housing growth elsewhere in the Plan.”
1.2 Policy HOM1 “Residential Allocations” refers to the schedule of sites put forward by the Council as draft residential allocations to meet housing growth over the Plan Period.
1.3 This Statement will focus upon a significant allocated site with the Carmarthen Cluster (Cluster 1) that being Site PrC1/MU1 at West Carmarthen. The Schedule of Residential Allocations at Policy HOM1 indicates that 700 residential units are proposed and anticipated to be brought forward over three “Delivery Timescales”, namely over Years 1-5 (2018-23), Years 6-10 (2024-28) and Years 11-15 (2029-33). The Schedule, however, indicates for 291 “units beyond the Plan Period.”
1.4 On behalf of our clients, we herewith lodge a formal representation in objection of the Residential Allocation. We submit that the Council’s expectations for the delivery of this site are unachievable based upon its lack of progress since allocation within the adopted Carmarthenshire Local Development Plan 2008-21. This Statement will focus upon the slow progress of the site evidenced by not only lack of applications for full planning permission, but also the low build rates upon the modest areas on the site where works have been completed. A noticeable lack of active site marketing further compounds the argument that the level of allocation is unrealistic.

2.0 SITE CONTEXT IN SECOND DEPOSIT DRAFT
2.1 The West Carmarthen Strategic Residential Site (PrC1/MU1) is part of a Mixed-Use Allocation, made under the provisions of Policy SG1 “Regeneration and Mixed-Use Sites” which in the case of West Carmarthen states that the site is provided for “Mix of uses consisting of residential (an allowance for 700 new homes within this plan period), employment, community facilities and amenity. A key deliverability indicator is the Carmarthen West Link Road which is now completed and open.”
2.2 The site is shown upon the Proposals Map for Carmarthen as reproduced below as Figure 1, and extends over several dozen hectares of open, undulated, former pasture, set off the northern flank of the A40 Trunk Road, extending west from Old St Clears Road to Travellers Rest.
Figure 1 – Extract from Proposals Map showing extent of Site PrC1/MU1
2.3 The southern extent of the allocation shows it wrapping about newly constructed dwellinghouses known as Maes Pedr. To the east of that series of cul-de-sacs, lies further residential cul-de-sacs, known as Maes Macsen and Clos Elen, which extend off Ffordd Pentre, being the main spine distributor road running south to north off its roundabout junction with Llysonnen Road. The road was built in recent years and provides a link about West Carmarthen linking north to junction with College Road and Job’s Well Road some two kilometres to the north-east of the above-named residential cul-de-sacs. Figure 2 below provides a Google Earth image of the residential development as of April 2021, whilst Figure 3 shows the state of development progress back in June 2018, which coincides with the start of the Replacement LDP Plan Period.
Figure 2 – Google Earth – April 2021 – illustrating extent of development at southern part of West Carmarthen at that time
Figure 3 – Google Earth – June 2018 – illustrating extent southern part of West Carmarthen at that time at start of Replacement LDP Period
2.4 The above Google Earth images reveal that extent of housing building at had taken place up to June 2018, and what had been developed up to the latest image in April 2021. We have calculated that from the start of the Plan Period in 2018 to September 2021, a total of 90 units were completed. Therefore, from the LDP allocation capacity of 700 units, there remains a balance of 610 units at this time. Construction of new units has ceased since September 2021, and has not continued since.

3.0 Progress since Adoption of Local Development Plan in 2014
3.1 The Carmarthenshire Local Development Plan was adopted in December 2014. The Plan is scheduled to run over a Plan Period from 2008 to end of 2021. The Site at West Carmarthen was allocated for Mixed Use in that Plan for a total of 1100 residential units (referenced GA1/MU1). Figure 4 below illustrates the extent of the allocation for the current adopted Plan.
Figure 4 – 2014-adopted Local Development Plan for Allocation GA1/MU1
3.2 We have calculated that of that 1100 units only a total of 141 were constructed between the Plan Adoption date of December 2014 and start of this Replacement
LDP Plan Period of 2018. Since 2018, a further 90 units have been constructed. Land Registry records that the last completed unit was sold at Maes Macsen in September 2021 (18 months ago). “Rightmove” provides details of selected new house sales over the last 20 years in this part of Carmarthen. The last new house transaction with the last property being at Maes Macsen in September 2021, as shown in Figure 5 below.
Address
Postcode
Last recorded date of ‘New Build’ property being sold
Maes Macsen
SA31 3DA
SA31 3FA
24/09/2021
Ffordd Pendre
SA31 3FD
11/12/2020
Maes Elen
SA31 3FB
24/09/2021
Pen y Cae
SA31 3SD
28/05/1999
Parc y Odyn
SA31 3SE
24/07/1998
Allt Ioan
SA31 3SB
03/03/2000
Maes Pedr
SA31 3BW
SA31 3BR
30/08/2018
Figure 5 – Sales Transactions in West Carmarthen from Rightmove – March 2023
3.3 Therefore, since adoption of the 2014 LDP, only a total of 231 units have been completed, equating to a build rate over that 7-year period of only 33 units per annum. This build rate is considerably lower than the anticipated and much promised
delivery of 1100 units in the Plan Period of 2014 to 2021, which would have expected an annual build rate of 157 units. An actual return of 33 units per annum equates to only a 21% build rate return on that anticipated for delivery in the 2014-21 Plan.
3.4 Only 39 of those units were built in 2017-18 accordingly to the Joint Housing Land Availability Study 2018. The 2019 Study reveals that only a further 5 units were constructed in 2018-19. The August 2019 Study reports that none were under-construction at that time.
During 2020 and 2021 when Covid-19 restrictions were at their peak, more units were constructed than at any other time in that LDP plan period. Therefore, we would submit at this point in our formal objection that low build rates cannot be held, and probably will be subsequently argued by the Council, to be reduced as a consequence of Covid-19 restrictions.
3.5 It is equally noteworthy that at a time when the housing market and sales values were at their most buoyant in 2022, that the only housebuilder with a track record on the site (Permission Homes) had ceased construction and sold their last completion (September 2021). We submit that this is testament to the weak marketability and sales demand of the West Carmarthen Site.
3.6 Only 231 units out of 1100 units of the MU1 Strategic Site have therefore been completed in the 2014-21 LDP period, which equates to only 21% of that allocated total.

4.0 CARMARTHENSHIRE UNITARY DEVELOPMENT PLAN 2001-16
4.1 The Carmarthenshire Unitary Development Plan was adopted in June 2006. The land at West Carmarthen was allocated as a Strategic Site under Policy E15 and referenced as Site PDB2. A Development Brief was to be prepared with an emphasis on a mixed-use including housing, employment, link road and community facilities. Figure 6 below provides an illustration of the Proposals Map from the UDP.
Figure 6 – Unitary Development Plan Extract of West Carmarthen
4.2 It is therefore abundantly clear that the West Carmarthen site has featured as a Strategic Development Site for the last 22 years, and in that time, the number of new housing constructed has amounted to only 241 units at Maes Pedr and Maes Macsen.

5.0 OBJECTION TO OVER-ALLOCATION IN SECOND DEPOSIT DRAFT LOCAL DEVELOPMENT PLAN
5.1 The Replacement LDP seeks to delivery 700 units over a Plan Period from 2018 to 2033. The extract from the Proposals Map for Carmarthen reveals that the figure includes for 90 units constructed between 2018 and 2021, leaving a balance of 610 units envisaged in the remainder of the Plan Period to 2033. That would equate to a build rate of 61 units per annum over a 10-year period. Based upon previous build rates at this site, such a predicted build rate can be described as overly optimistic, being nearly double that actually achieved on the site to date.
5.2 We noted that planning permissions have been granted by the Council on part of the LDP allocation. Figure 7 provides a breakdown of planning applications submitted over the West Carmarthen site over the last 8 years since adoption of the LDP in 2014. The applications are coloured coded, and those colours correspond to the Google Earth extract at Figure 8 overleaf, which illustrates where each application site was situated.
Figure 7 – Planning Applications at Carmarthen West 2014-2023
Figure 8 – Location of Planning Applications 2014-2023
5.3 The details reveal that the initial 110 houses granted in 2015 (red area) have all been completed and are not part of the 700-unit allocation in the Second Deposit Draft. The grey coloured area totals 100 units and has been completed, 90 units of which took place during the current Years 1-5 of the Replacement LDP.
5.4 The orange area and green areas formed part of the larger 1100 units allocated on a larger allocated area under the 2008-21 LDP. They have been subsequently completed totalling 31 units. However, as calculated above, do not form part of the draft allocation for 700 units in the current Second Draft.
5.5 The purple and pink areas to the northern side of the allocation have not been developed, but have been subject to applications for planning permission since 2018.
The purple area achieved outline planning permission in May 2018 under W/27776. It was valid for three years, and therefore lapsed in May 2021 – some two years ago. However, a Section 73 application to extend the time period for receipt of Approval of Reserved Matters was submitted in March 2021, just before it was due to otherwise lapse. The submission was registered as PL/01626. Yet, after a period of some 24 months, it has yet to be determined. We note that the land is owned by the Applicants, “Carmarthen Promotions Limited” based in Nottingham, according to Land Registry Title records.
5.6 The pink land is currently the subject of an application for full planning permission for 92 dwellinghouses by Persimmon Homes. Application PL/04627 was registered on 14th September 2022, yet at the time of writing remains undetermined. If that development does achieve permission and is completed within the Pan Period, it would only raise the build total at West Carmarthen to 182 units since 2018. A figure which represents only 26% of the 700 capacity quoted in Policy HOM1.
5.7 We note that the Council has been marketing their land holdings for sale. Figure 9 below is a reproduction from Sales Particulars where the Council were seeking “Expressions of Interest” on a 3.4-hectare field enclosure north of the red area. That area has never benefitted from any planning permission, let alone application submitted upon it for residential development. It is not clear as to what feedback and actual completed questionnaires were received by the deadline in February 2023. However, it is surprising that it has taken the County Council some 9 years to begin to market their land asset at West Carmarthen. The land has been part of the GA1/MU1 allocation since adoption in 2014, and there has been no attempt to seek a Developer Partner throughout all this time. We submit that such a sales practice is now only emerging as a consequence of the current Second Deposit Draft Plan, which has jolted the landowners into some form of initial action on the site.
The field in question is relatively level and assuming the LDP capacity expectation of 35 units per hectare is achievable, the 3-hectare site could achieve a total of 115 units. Yet, no firm proposals have yet to materialise on this part of the Strategic Site
allocated in the Second Draft. There is uncertainty and lack of progress in bringing this part of the allocated site to fruition.
Figure 9 – Sales Particulars of land north of Maes Pedr

6.0 CONCLUSION
6.1 The Allocated Site at West Carmarthen is substantial in overall size. The Carmarthen Cluster is expected to deliver 1690 units over the Plan Period, and thus the Mixed-Use site contributes 41% towards that overall total. After 5 years of the Plan Period, only 90 units have been completed, representing only 5.3% of the Cluster 1 entire total. If that trend continued over the remaining 10 years of the Plan Period, it would contribute only a further 180 units. None of the site currently benefits from any form of planning permission, despite 9 years of being allocated in the 2008-21 LDP Plan. Only Persimmon Homes have contributed to the site, and only they have prepared and lodged an application for any future housing phase, being the current application for 92 units.
6.2 We submit that the Allocated Site be dramatically reduced in scale to total only 300 units. A total of 90 of those 300 units have been completed, leaving a further 210 units split over two field enclosures, and those being the current northern field, subject of the 2022 Persimmon application (pink area) and the Council’s 3-hectare western enclosure, where another 110 units are achievable. The remaining field enclosures should be omitted from the allocation, that being all land north and east of Ffordd Pentre.
6.3 Clearly, there is no historic demand for a site of this scale in this part of Carmarthen. More physically challenging sites, such as the Roman Park site in Llangunnor by Redrow Homes, and the Mount Pleasant site (Maes Lewis Morris), also in Llangunnor, by Lovell Homes have come forward, and been fully completed, long before West Carmarthen.
6.4 The overwhelming majority of the allocation has underdelivered. We would refer and advocate to the Inspector to heed Welsh Government’s Guidance provided in Development Plans Manual (Edition 3) (March 2020). Page 120 states: “Rolling forward allocations - 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. The sites should be subject to the same candidate site process requirements as new sites i.e., they must be demonstrated to be sustainable and deliverable. If an LPA wishes to retain such sites but cannot evidence, they will be delivered, i.e., for aspirational or regeneration purposes, they can still be allocated in the plan but not relied upon as contributing to the provision. It will not be appropriate to include such sites in the windfall allowance. They should be treated as ‘bonus sites’.”

Reduce and remove the housing element of the allocation.

1.0 I NTROD UCTION
1.1 Evans Banks Planning Limited act for a number of landowners and have made formal representations in respect of those clients’ land interests in relation to the Carmarthenshire Replacement Local Development Plan (2018-21): Second Deposit Draft. Within those Representations, we have referred to previous Candidate Site submissions made in August 2018. The Council in response to those Candidate Site submissions have published a Site Assessment Table (January 2023). We have noted in rejecting Candidate Sites, the Council has on multiple occasions concluded that a Candidate Site should not progress and be allocated as “there is sufficient land allocated for housing growth elsewhere in the Plan.”
1.2 Policy HOM1 “Residential Allocations” refers to the schedule of sites put forward as draft residential allocations to meet housing growth over the Plan Period.
1.3 This Statement will focus upon a significant allocated site with the Carmarthen Cluster (Cluster 1) that being Site PrC1/MU2 at Pibwrlwyd. The Schedule of Residential Allocations at Policy HOM1 indicates that 247 residential units are proposed and anticipated to be brought forward over only one “Delivery Timescales”, namely over Years 11-15 (2029-33), therefore being very late in the Plan Period.
1.4 On behalf of our clients, we herewith lodge a formal representation in objection of the Mixed-Use Allocation. We submit that the Council’s expectations for the delivery of this site are unachievable based upon its lack of progress since allocation within the adopted Carmarthenshire Unitary Development Plan 2001-16, and Carmarthenshire Local Development Plan 2008-21. This Statement will focus upon the slow progress of the site evidenced by not only lack of applications for full planning permission, but also the “sea-change” in local planning policy from adopted Supplementary Planning Guidance dated 2014. In that SPG, the Council expressly stated that any form of residential development upon the site would be resisted.
A noticeable lack of active site marketing further compounds the argument that the level of mixed-use allocation is unrealistic.

2.0 SITE CONTEXT IN SECOND DEPOSIT DRAFT
2.1 The Pibwrlwyd Strategic Residential Site (PrC1/MU2) is part of a Mixed-Use Allocation, made under the provisions of Policy SG1 “Regeneration and Mixed-Use Sites” which in the case of Pibwrlwyd states that the site is provided for “Includes a mix of uses reflecting its strategic location and contribution to Carmarthen. Uses include employment, commercial leisure, education associated with Coleg Sir Gâr and residential (an allowance is made for 247 new homes)”.
2.2 The site extends over several hectares of open, undulated, former pasture, set off the eastern flank of the A484 Carmarthen to Kidwelly Road, extending east by several hundred metres to the eastern boundary with the A48 trunk road. Coleg Sir Gar is to be found in the southern extremity of the allocation, and Parc Pensarn Retail and Employment Park in the northern portion.
Figure 1 – Extract from Proposals Map showing extent of Site PrC1/MU2
2.3 The southern extent of the allocation shows it also includes educational uses off the southern flank of Pibwrlwyd Lane, which lies off the roundabout interchange with the
A484, and where a handful of established houses are to be found extending eastwards to where that minor road terminates near the A48 embankment.
2.4 Figure 2 below provides a Google Earth image of the retail, employment and educational uses as of April 2021, whilst Figure 3 shows the state of development progress back in June 2018, which coincides with the start of the Replacement LDP Plan Period.
Figure 2 – Google Earth – April 2021 – illustrating extent of development about Pibwrlwyd at that time
Figure 3 – Google Earth – June 2018 – illustrating extent development about the start of Replacement LDP Period
2.4 The above Google Earth images reveal that extent of new commercial office units constructed at Cabna Court off Heol Glyndwr that has taken place since June 2018. It is notable that the wide, open expanses of undulating fields stretching south for a distance of some 360 metres have remained in their agricultural state for generations, with no signs of any form of built development. It is also notable in that time, that the extent of educational buildings at the Pibwrlwyd Campus have remained unchanged, with little progress in terms of expansion and / or redevelopment. In other words, the majority of the Strategic Site has lain dormant for many years.

3.0 Progress since Adoption of Local Development Plan in 2014
3.1 The Carmarthenshire Local Development Plan was adopted in December 2014. The Plan is scheduled to run over a Plan Period from 2008 to end of 2021. The Site at Pibwrlwyd was allocated for Mixed Use in that Plan and referenced GA1/MU2. Figure 4 below illustrates the extent of the allocation for the current adopted Plan.
Figure 4 – 2014-adopted Local Development Plan for Allocation GA1/MU2
3.3 Since adoption of the 2014 LDP, applications for full planning permission have been granted for a “swim centre”, dental surgery and two office suite units in the northern part of the allocation at Cabna Court. Whilst off the Pibwrlwyd Lane part, a single-storey animals testing unit has been formed. All those developments have been completed and implemented. A planning application for a manufacturing unit with warehouse was granted off Heol Glasdwr, adjoining Cabna Court in September 2021, but has yet to commence any on-site works.
3.4 PIBWRLWYD SUPPLEMENTARY PLANNING GUIDANCE
3.4.1 The Pibwrlwyd Supplementary Planning Guidance was adopted alongside the LDP in December 2014. It describes the vision and policy provision for Pibwrlwyd to include for “The proposed use for the site is for a business park centred around employment uses (Use Classes B1, B2 and B8), with uses associated with, and ancillary to the existing Coleg Sir Gâr. A development brief in the form of SPG has been prepared and adopted. This in setting out appropriate uses under Use Classes B1, B2 and B8 for the employment element of the site also explores other compatible uses. Residential use on this site is not considered appropriate”.
3.4.2 The SPG outlines proposed uses for the site, as follows:
“Due to the strategic location and the prominence of the site, any development on the site must be of high quality. Acceptable uses on the site include:
B1 Business: Offices not within A2.
Research and Development, studios, laboratories, high tech, light industry.
B2 General Industrial: Appropriate uses that don’t have an adverse impact on neighbouring uses.
B8 Storage or Distribution: Wholesale warehouse, distribution centres, repositories. D1 Non-residential Institutions: non-residential education and training centres – relating to the extension of the Coleg Sir Gâr campus.
Other suitable uses may include, subject to amenity considerations:
• Car showrooms and sales (sui generis);
• Hotel (C1);
Use Classes B1, B2 and B8 will be restricted to 15.5ha of the overall site.”
3.4.3 It is therefore abundantly clear that the focus throughout the entire SPG is to encourage B1, B2 & B8 uses from Parc Pensarn to the north, and Educational uses from the Coleg Sir Campus from the south. Due to the obvious potential for environmental conflicts with those industrial and commercial uses, any form of residential development was strongly resisted.

4.0 CARMARTHENSHIRE UNITARY DEVELOPMENT PLAN 2001-16
4.1 The Carmarthenshire Unitary Development Plan was adopted in June 2006. The land at Pibwrlwyd was allocated as a Strategic Site under Policy E15, referenced as Site PDB19. Figure 5 below provides an illustration of the Proposals Map from the UDP.
Figure 5 – Unitary Development Plan Extract of Pibwrlwyd
4.2 The site was also allocated in the Carmarthenshire Unitary Development Plan as a Planning and Development Brief Site, which sets out the vision of the site “as a Business Park centred on B1, B2 and B8 uses and will allow for the consolidation and redevelopment of the existing Carmarthen elements of Coleg Sir Gâr within the site. The Brief will evaluate the feasibility of other compatible uses, including car showrooms and some limited retail use...Residential uses are not considered appropriate for this site”.

5.0 OBJECTION TO RESIDENTIAL ALLOCATION IN SECOND DEPOSIT DRAFT LOCAL DEVELOPMENT PLAN
5.1 The Replacement LDP seeks to delivery “an allowance of 247 units” over a Plan Period from 2018 to 2033 at Pibwrlwyd, in complete disregard for the 2014 Supplementary Planning Guidance.
5.2 The bulk of the land at Pibwrlwyd lies under the freehold ownership of Coleg Sir Gar. The College have owned the site throughout the above UDP and LDP Plan Periods. During that Period, they not undertaken any marketing of the site to seek out commercial, leisure or industrial uses in line with the Local Planning Policy framework, particularly the Supplementary Planning Guidance. In contrast, the owners of Cabna Court to the north, namely Welsh Government, have embarked upon a marketing campaign (principally through appointed Land Agents Cushman & Wakefield) and successfully attracted several office and commercial interests to the commercial estate off Heol Glasdwr.
5.3 The Council have indicated that they expect the delivery of the Pibwrlwyd site to taken place in LDP Years 11-15, that being 2029-2033, and thus remains a further 5-10 years before the development potential is realised. That timescale equates to a period of over 25 years of allocations in the UDP and two LDPs without any prospect of even part of the allocation being fulfilled, and not even the subject of a planning application.
5.4 National Planning Policy in terms of the allocation of residential land in Local Development Plans is to be found in Planning Policy Wales (Edition 11) (February 2022). PPW has a long-standing policy provision that industrial and residential development should be segregated in order to avoid any potential for future conflicts between the ability of those existing businesses to properly function and trade, versus the rights and needs of occupiers of residential properties to be afforded a reasonable level of amenity. By siting new residential development near to commercial development, difficulties can arise in terms of complaints of excessive, vibration, dust and disturbance from the use of loud and heavy machinery and the movement of
heavy goods vehicles. Hours of operation of those commercial operations can be questioned, particularly of between the hours of 19:00 to 07:00 hours on week nights and at weekends when adjoining occupiers of residential properties tend to be more home based. Many modern businesses now require operating over longer shift patterns and accordingly the traditional hours of working strictly during the weekday have long been cast aside. HGV deliveries, for example, may be necessary during early morning and / or evening hours. Siting new residential development in close proximity to existing and proposed industrial development will undoubtedly create potential for conflict and disturbance to those new Pibwrlwyd residents upon the Pibwrlwyd Strategic Site.
5.5 We have noted at Pibwrlwyd that Heol Glasdwr has two access spurs leading off its west-east axis. The eastern-most access leads onto Cabna Court as shown at Photo 1 below, taken in March 2023. The extent of new build offices at Cabna Court is shown off both flanks of the estate road which terminates at the Coleg Sir Gar land.
Photo 1 – Cabna Court north of Pibwrlwyd
5.6 Photo 2 illustrates the other access spur off the western side of Heol Glasdwr, where industrial units are positioned off that carriageway. It graphically illustrates how new residents would have to negotiate past commercial vehicles to access their new homes and give rise to potential conflicts.
Photo 2 – access off Heol Glasdwr amongst commercial units
5.7 We note that the open fields at Pibwrlwyd comprise some 22 hectares below / south of the Cabna Court and Heol Glasdwr commercial uses. Assuming the LDP capacity expectation of 35 units per hectare is achievable, a total “allowance of 247 units” would require 7 hectares of land take, and thus equating to one-third of the site.
5.8 Given that no firm proposals have yet to materialise on this majority part of the Strategic Site, and also over the last 20 years, and yet it remains allocated in the Second Draft. It is likely that any residential development would appear “stand-alone” and remote from any integrated mixed-use development at Pibwrlwyd. The obvious and longstanding uncertainty and lack of progress in bringing this part of the allocated site to fruition will undoubtedly also reflect upon a residential element within that scheme. By the Council’s own admission, it only likely to come forward in the latter years of the new LDP, and thus such a prediction is hardly an endorsement of its potential creditability and deliverability.
5.9 Locational Remoteness
5.9.1 The site is completely and physically divorced from established housing at Pensarn and Llangunnor. It is physically separated by foot from local schools, community facilities and play facilities by the A40 / A48 trunk road network, with only a dark and insecure pedestrian underpass linking it to the Pensarn Commercial Area. Parents and their children would have to walk some two kilometres and up Rhiw Babell hill to access the nearest Primary School at Llangunnor. This is unlikely to occur and
instead, parents will resort to travelling to school by private car, which defeats sustainability principles and objectives inherent in development plan policy making.
New housing at this location would accordingly be quite alien in form to the long-established business and education uses at Pibwrlwyd. Figure 6 below illustrates the distances to the nearest local primary school and green space in the locality.
Figure 6 – Remote distance of Pibwrlwyd Site from nearest Primary School
Pibwrlwyd
Llangunnor Primary School and Public park

6.0 CONCLUSION
6.1 The Allocated Site at Pibwrlwyd is substantial in overall size. The Carmarthen Cluster is expected to deliver 1690 units over the Plan Period, and thus the residential element of the Mixed-Use site (247 units) contributes 14.6% towards that overall total. That equates to one new house in every seven in the Carmarthen Cluster is being promoted at an “out-of-town” location, divorced from community facilities.
6.2 After over 20 years of UDP and LDP Plan Periods, only Welsh Government have enacted upon the Mixed-Use allocation, as evidenced at Cabna Court. Coleg Sir Gar in contrast over this time have not even undertaken any known marketing campaign to realise the asset bestowed upon by the above two Development Plans.
6.3 We submit that the Allocated Site be dramatically reduced in scale to only include the area about Cabna Court and Heol Glasdwr for employment purposes (B1, B2 & B8). The area about Coleg Sir Gar at Pibwrlwyd Lane could benefit from perhaps one sole modest field enclosure to allow for educational expansion. The remaining field enclosures, being the bulk of central 20 hectares, should be omitted from the allocation. The proposed housing allowance should be re-allocated elsewhere in Carmarthen to more sustainable Candidate Sites.
6.4 Clearly, there is no historic demand for a Mixed-Use site of this scale in this part of Carmarthen. New commercial development is attracted to Cross Hands East and Parc Dafen in Llanelli, being located further east along the A48 / M4 corridor, and thus locationally superior. The Cillefwr Industrial Estate and area about the Carmarthen Livestock Mart are able to satisfy future employment growth for the town of Carmarthen.
6.5 The overwhelming majority of the allocation has underdelivered. We would refer and advocate to the Inspector to heed Welsh Government’s Guidance provided in Development Plans Manual (Edition 3) (March 2020). Page 120 states: “Rolling forward allocations - 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. The sites should be subject to the same candidate site process requirements as new sites i.e., they must be demonstrated to be sustainable and deliverable. If an LPA wishes to retain such sites but cannot evidence, they will be delivered, i.e., for aspirational or regeneration purposes, they can still be allocated in the plan but not relied upon as contributing to the provision. It will not be appropriate to include such sites in the windfall allowance. They should be treated as ‘bonus sites’.”

Amend Plan to include site within limits

Carmarthenshire Local Development Plan 2018-2033 – Deposit Draft
Objection to Policy SD1 on behalf of Evans Banks Planning Ltd

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, including in relation to the provisions of part of Policy SD1 (Development
Limits). As a result, we offer the following for the Authority’s consideration, and Inspector’s in
due course.

Through the provisions of Policy SD1, ‘development limits’ have been defined for all
settlements within Tiers 1, 2 and 3 of the Settlement Framework. The Policy then sets out
that “Proposals within defined Development Limits will be permitted, subject to policies and
proposals of this Plan, national policies and other material planning considerations.”.

The Policy’s supporting text goes on to set out four situations that have influenced how the
proposed development limits have been set, with the first reading as follows: “Prevent
inappropriate development in the countryside and provide certainty and clarity as to where
exceptions proposals (adjacent to limits) may be considered appropriate;”. In order to ensure
‘certainty’ and ‘clarity’ from the Policy (and in turn ‘soundness of the Plan), there is an
assumption that all settlement limits have been drawn correctly and logically. However, as
has been seen from the numerous submissions made as part of the current consultation process with regards to the proposed settlement limits, this is not the case.
The submissions made on behalf of our Clients with regards to Policy SD1 and specific areas of land, and those made by other parties, highlights that the level of ‘clarity’ and ‘certainty – and indeed confidence – that Policy SD1 has sought to secure, has not been achieved.

The submissions highlight that residential gardens (as a whole or in part), natural infill plots and often domestic outbuildings have been illogically excluded from proposed settlement limits and in doing so, labelling them ‘open countryside’. As the aforementioned submissions clearly show, these areas of land and buildings are certainly not part of the ‘open countryside’ nor do they share their characteristics, and so should in fact be included within the defined development limits. However, under the current wording of Policy SD1 the above situations will in turn create confusion, with areas that quite clearly form a logical part of a settlement, in fact being defined by Policy SD1 as lying outside of it.

In order to secure greater consistency and clarity, it is proposed that Policy SD1 should be amended – either as part of its core text or supporting text – to allow for a ‘case by case’ assessment of the suitability of small areas of land or property for development at ‘edge of settlement’ locations. It is proposed that this could be done by including the same form of locational criteria as used by Policy HOM3, which are as follows:

• minor infill of a small gap between the existing built form; or,
• logical extensions and/or rounding off of the development pattern that fits in with the character of the settlement form and landscape; or
• conversion or the sub-division of large dwellings.

The above would then ensure that all edge of settlement locations with regards to appropriate development are assessed in a consistent and clear manner, compensating for any such instances that the Deposit Plan has done so in an erroneous manner.

We therefore respectfully request that this Representation be given careful examination, and that the above wording and provision should be included as part of Policy SD1 to ensure that the Plan adheres to the requirements of all three Tests of Soundness.

Amend Policy

Carmarthenshire Local Development Plan 2018-2033 – Deposit Draft
Objection on Evans Banks Planning Ltd

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 w consider it necessary to
make a formal representation to the “soundness” of the Carmarthenshire Deposit Local
Development Plan, including in relation to the provisions of Strategic Policy SP4 (A
Sustainable Approach to Providing New Homes). As a result, we offer the following for the
Authority’s consideration, and Inspector’s in due course.
Policy SP4 represents the Council’s strategic position with regard to the County’s provision
of new homes during the Plan period. It sets out that within the Plan period (2018-2033) the
document is expected to deliver “9,704 new homes to meet the identified housing
requirement of 8,822.” through a range of housing supply components, which are as follows:

• Housing Allocations (5+ homes)
o Land bank Commitments
o Completed Dwellings
• Windfall Allowance
o Small Site Component (less than 5 homes)
o Windfall Component (5+ Homes)
• Flexibility (+10%)

However, through our own examination and consideration, we have identified that two of the above components give rise for concern and in turn put into question the ability of the Plan to deliver the proposed ‘new homes’ figure cited above. These concerns are summarised as follows.

Housing Allocations (5+ homes)
Having reviewed all proposed housing allocations put forward by the Plan under the provisions of Policy HOM1, we have identified a significant number that are clearly in themselves undeliverable and these are in turn subject of separate individual submissions. Notwithstanding this, the sheer number of such sites is on its own a reason to question the ‘soundness’ of the Plan.

In addition to the above, we have concerns with regards to (a) how the number of units assigned to each allocation has been derived and (b) the ability of allocations in certain geographic areas of the County being capable of reaching those targets.

In its explanatory text of Policy SP4 at Paragraph 11.85, the Council advises that “Site numbers highlighted within the Policy HOM1 are intended to be indicative and been considered on a site by site basis. They will be subject to further consideration at application stage. Regard will also be had to the policies and provisions of this plan and other relevant design principles.”. Whilst it is recognised that such assigned figures are indeed often indicative to provide flexibility, there appears to be no clearly defined consistent process of assessment or assignment of such unit figures to individual sites. In the absence of this evidence and a clear account of how these unit figures have been reached, there is a question over the ‘soundness’ of the Plan in terms of the ability of the proposed housing allocations meeting the aforementioned ‘new homes’ target figure.

In addition to the above, we have concerns with regards to the assigned unit numbers for allocations within the river catchments of the Teifi and Tywi Special Area of Conservation (SAC). The challenges presented to all elements of the planning process as a result of the new regulations published by Natural Resources Wales (NRW) with regards to phosphates generated by proposed developments, particularly housing.
Through our own experience, solutions for overcoming the challenges raised by the aforementioned regulations have now been identified, in both sewered and non-sewered areas. However, in each case, there is a ‘land-take’ requirement, which has in turn significant implications for any proposed housing allocations within the two aforementioned SACs.

In a recent case this practice has been involved with at Cwmman (see accompanying layout), a site capable of physically accommodating 22 units is now only being proposed for 13, due to the on-site apparatus required to provide a satisfactory level of phosphate treatment.
Having examined those allocations being proposed in the two aforementioned SAC, it is clear that this potential 33%+ reduction in unit numbers has not been taken into account in assigning unit numbers as part of their inclusion in Policy HOM1. On this basis, again, there is significant doubt that these allocations will be capable of delivering anywhere near the number of new homes the Council expects. This in turn therefore questions the ‘soundness’ of one of the Plan’s strategic policies and in turn the Plan itself.

The above therefore clearly illustrates that there is significant concerns that the new homes figure quoted by Policy SP4 and the framework that supports its provision is undeliverable. As a result and on this basis, the 2nd Deposit LDP fails the required Tests of Soundness and consequently the Plan is ‘unsound’.

We therefore respectfully request that this Representation be given careful examination, and that the housing need figure be revisited to ensure that the document passes all the relevant tests of soundness.