Second Deposit LDP

Remove the site from the Plan

Objection to Policy HOM1 on behalf of Evans Banks Planning Ltd
Site PrC3/h36 – Betws Colliery, Betws, Ammanford
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 of Betws Colliery,
Betws (LDP Ref. No. PrC3/h36) 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 66 residential units.

(Extract of Proposal Map for Betws and Betws Colliery Allocation)
As part of the current consultation process into the 2nd Deposit LDP, the Council have again
published a “Site Assessment Table” (2023), which provides details of the Council’s analysis
of each received Candidate Site submission and existing allocations within the current
adopted LDP. Proposed allocation PrC3/h36 was considered as part of this process and as
a result the Council concluded as follows:
“Part of the site to be retained as a residential allocation, with site reference PrC3/h36. The
site has partly been developed.”
It is clear from the above therefore that the Council considers that the site is deliverable for
the purposes of 60 houses, although it is not clear on what basis this conclusion has been
made. This is particularly as whilst the southern part of the former allocation site (south of
Ffordd y Glowyr) has been developed, the remaining element (Allocation PrC3/h36)
continues to remain undeveloped.
The allocation itself is brownfield in nature and is currently in an overgrown state. The
topography of the site slopes gradually from east to south. The site is surrounded by mature
woodland to the north and to the west with Ffordd y Glowyr making up the southern
boundary, as can be seen from the aerial photograph below (allocation circled red).
see attachments

Remove allocation from the Revised LDP.

Objection to Policy HOM1 on behalf of Evans Banks Planning Ltd
Site PrC3/h22 – Adj. to Pant y Blodau, Penygroes
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. to
Pant y Blodau, Penygroes (LDP Ref. No. PrC3/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 79 residential units.

see attachment

Removal of allocation from the Revised LDP.

Site PrC3/h14 – Nant Y Dderwen, Drefach, Cross Hands
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 Nant Y
Dderwen, Drefach, Cross Hands (LDP Ref. No. PrC3/h14) under the provisions of Policy
HOM1. The proposed allocation has been fully assessed and in considering its context and
background (summarised below) it is considered that its continued inclusion will lead to the
Plan failing the 3 Tests of Soundness for the reasons set out below.
Site Background and Context

The allocation relates to the land shaded brown on the Proposals Map extract below and is
proposed for allocation in the 2nd Deposit LDP for the purposes of 33 residential units.

Plan A
(Extract of Proposals Map for Drefach and Nant Y Dderwen Allocation)
As part of the current consultation process into the 2nd Deposit LDP, the Council have again
published a “Site Assessment Table” (2023), which provides details of the Council’s analysis
of each received Candidate Site submission and existing allocations within the current
adopted LDP. Proposed allocation PrC3/h14 was considered as part of this process and as
a result the Council concluded as follows:
“Site to be allocated for residential development with site reference PrC3/h14.”
It is clear from the above therefore that the Council considers that the site is deliverable for the purposes of 33 houses, although it is not clear on what basis this conclusion has been
made, particularly in view of its current biodiversity value.
The allocation is greenfield in nature with its topography being relatively level. Much of the
allocation is covered with mature vegetation, trees and hedgerows, as can be seen from the
aerial photograph below (outlined in red below).

Access to the allocation is currently gained from Nant Y Dderwen, a narrow road, served by
a single or no footway for its extent (see below).

An application seeking Full Planning Permission was made to the Council in 2008 for the
Residential Develeopment of 33 houses. However, this application was withdrawn in 2014,
with no planning applications being made for the allocation since that date.

The site was allocated in the Carmarthenshire Local Development Plan (2014) under
Allocation (GA3/h53), and previously under Allocation GR3/35 of the Carmarthenshire
Unitary Development Plan (2006) (as can be seen below).

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.

Please see accompanying letter

Remove the site from the Plan

Site SuV23/h2 – Adjacent Little Croft, Five Roads
Further to the publication of the above document, we have been asked by our Clients to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so we consider it necessary to
make a formal representation to the “soundness” of the Carmarthenshire Deposit Local
Development Plan in relation to the allocation for residential development at land Adjacent
Little Croft, Five Roads (LDP Ref. No. SuV23/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 25 residential units.
Plan A
(Extract of Proposals Map for land Adjacent Little Croft 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 SuV23/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. Site will be allocated with reference
SuV23/h2.”
It is clear from the above that the Council considers that the site is deliverable for the
purposes of 25 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 southern
boundary is bordered by residential development. The B4309 borders the western boundary
of the allocation, with agricultural land being located to the north and the east 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 unknown, however as previously mentioned, the western
border of the allocation borders the B4309, that being the main road running through Five
Roads as can be seen below.
Photograph 2
(Streetscene of B4309)
There have been no planning applications made in relation to the allocation site in
question to date.
The site made up part of an allocation in the Carmarthenshire Local Development Plan
(2014) under allocation SC37/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.
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.

Please see accompanying letter.

Remove the site from the Plan

Site SeC1/h4 – Cae Canfas, Heol Llanelli, Pontyates
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 Cae Canfas,
Heol Llanelli, Pontyates (LDP Ref. No. SeC1/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 8 residential units.

Plan A
(Extract of Proposals Map for Pontyates and Cae Canfas, Heol Llanelli 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 SeC1/h4 was considered as part of this process and as a
result the Council concluded as follows:
“The site is a relatively new allocation, and it will remain in the plan with a good possibility of
being developed. Site to be allocated with reference SeC/h4.”
It is clear from the above that the Council considers that the site is deliverable for the
purposes of 8 houses, although it is not clear on what basis this conclusion has been made.
The Council refer to it as a “new allocation”, although our research reveals it has appeared
for the last 9 years within an Adopted Local Development Plan without any attempt by the
landowners to seek planning permission thereon.
The allocation is greenfield in nature with its topography being generally level. The allocation
site is surrounded by residential dwellings in all directions as can be seen from the aerial
photograph below (outlined in red below).

Access to the allocation is currently gained off an existing access point off Heol Llanelli, that
being the amin road running through Pontyates (see below).

There have been no planning applications made relating to the allocation in question to
date.
The site makes up par of an allocation in the Carmarthenshire Local Development Plan
(2014) under Allocation T3/5/h7 (as can be seen below).

Plan B
(Extract of current LDP Proposal Map for Cae Canfas (Adopted 2014))
Despite having almost 10 years of support for the principle of residential development at the
historic allocation from the Council, not a single housing unit has been delivered to date.
Tests of Soundness
Based on the above information and the guidance documents provided by the Welsh
Government and Council itself, it is considered that the inclusion of the adoption of the LDP
in its current form with the inclusion of the allocation in question, would result in it failing to
meet the requirements of the Tests of Soundness, for the reasons summarised below.
Test 1 – Does the Plan Fit?
The allocation fails the test of soundness as its inability to be delivered is in conflict with
Paragraph 4.2.2 of Planning Policy Wales (Edition 11) requirements of national planning
policy.
Test 2 – Is the Plan appropriate?
The allocation fails the test of soundness as its inability to be delivered would fail to
address key issues set out by the Plan (housing supply). The Council’s decision to allocate
the land appears to not have been done so on credible or robust evidence.

Test 3 – Will the Plan deliver?
The allocation fails to test the soundness as the site is clearly unable to deliver any new
housing. The Welsh Governments Development Plans Manual (Edition 3) is quite clear
with regard to rolling forward allocations and states that allocations “… rolled forward from a
previous plan will require careful justification for inclusion in a revised plan, aligning with
PPW. There will need to be substantial change in circumstances to demonstrate sites can be
delivered and justify being included again. Clear evidence will be required that such sites
can be delivered”. No evidence has been presented to demonstrate a change in
circumstances to indicate the allocation will now be deliverable and so its continued
allocation would lead to the plan being deemed unsound on this basis.
In summary, we object to the inclusion of the allocation in question on the basis of the
above and that its inclusion within the Plan would result in the document being ‘unsound’.
We therefore respectfully request that this Representation be given careful examination, and
that the allocation be removed to ensure that the document passes all the relevant tests of
soundness.

Remove site from 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 Adjacent
to Brittania Terrace, St Clears (LDP Ref. No. SeC18/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 60 residential units.

Plan A
(Extract of Proposals Map for St Clears and land Adjacent to Brittania Terrace
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 SeC18/h1 was considered as part of this process and as
a result the Council concluded as follows:
“Whilst the site has been included in previous development plans, its connection to the
adjacent site and a potential dual access point could see this site being brought forward. Site
to be allocated with reference SeC18/h1.”

It is clear from the above that the Council considers that the site is deliverable for the
purposes of 60 houses. However, it is unclear as to why and what evidence the Council has
received to believe beyond doubt that the sites “…connection to the adjacent site…”
provides absolute confidence that the site will be delivered.
The allocation is greenfield in nature with its topography being relatively level while gradually
sloping from west to east. Much of the perimeter of the allocation is covered with mature
vegetation, trees and hedgerows, as can be seen from the aerial photograph below (outlined
in red below).

Access to the allocation is currently gained via an access road off Tenby Road, that being
the main road running east to west through St Clears (see below).

Photograph 2
(Streetscene of Access to Allocation Site)
Outline Planning Permission was granted in 2010 for Residential Development including
Affordable Units (W/21675). In both 2013 and 2014, Variation of Conditions for an extension
of time for the outline planning permission were granted, but no further applications have
been made relating to the allocation site since 2014

The site was allocated in the Carmarthenshire Local Development Plan (2014) under
Allocation (T2/5/h4), and previously under Allocation S7/g of the Carmarthenshire Unitary
Development Plan (2006) (as can be seen below).

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.

See attachments

Remove residential allocation SeC18/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 Adjacent
to Cefn Maes, St Clears (LDP Ref. No. SeC18/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 100 residential units.

(Extract of Proposals Map for St Clears and land Adjacent to Cefn Maes 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 SeC18/h3 was considered as part of this process and as
a result the Council concluded as follows:
“Site to be allocated with reference SeC18/h3.

It is clear from the above therefore that the Council considers that the site is deliverable for
the purposes of 100 houses, although it is not clear on what basis this conclusion has been
made. It is also unclear how the allocation of a previously allocated ‘green wedge’, used in
order to protect local green spaces as well as to prohibit the coalescence of settlements,
would now be deemed to be appropriate for future housing development.

The allocation is greenfield in nature with its topography being relatively level. The site is
made up of two enclosures with much of the perimeter of the allocation being covered with
mature vegetation, trees and hedgerows, as can be seen from the aerial photograph below
(outlined in red below).

There have been no planning applications made relating to the allocation site in question to
date.
Although the site was not allocated for development in the Carmarthenshire Local
Development Plan (2014), the site was not included within the defined settlement limits of St.
Clears. As well as this, within the Carmarthenshire Unitary Development Plan (2006), the
allocation site was defined as a green wedge (as can be seen below).

The purpose of the ‘Green Wedge’ allocation from Plan C is clear – to prevent an instance
that could contribute towards the coalesance of settlements (Pwll and St. Clears).
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 due to its inappropriateness with regards to the
principles of sustainable growth and so 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 (protection of landscape quality). 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 fact that the site wasn’t allocated within the defined settlement limits on the current Carmarthenshire LDP demonstrates that the site is encroaching towards the open
countryside and does not reflect the layout of the town. Also, given that the site was once
allocated as a green wedge, within the Carmarthenshire UDP, indicates that the area is of
natural importance and that development in this area was not deemed acceptable due to it
resulting in a situation that could lead to the coalescence of settlements. Therefore, the
allocation of this site for the purposes of residential development 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 allocation SuV63/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 at
Woodend, Llanmiloe (LDP Ref. No. SuV63/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 28 residential units.


Plan A
(Extract of Proposals Map for Llanmiloe and Land at Woodend 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 SuV63/h1 was considered as part of this process and as
a result the Council concluded as follows:
“The site is under construction with a road and plot layout developed for self build
development. Site to be allocated with reference SuV63/h1.”

It is clear from the above that the Council considers that the site is deliverable for the
purposes of 28 houses. However, it is unclear as to the sustainability of the development of
self build plots for the purposes of the proposed Local Development Plan, or the reliability
that all plots will be completed during the plan period.
The allocation is brownfield in nature with its topography being relatively level in the southern
half of the allocation while the northern half slopes drastically from north to south. The
southern boundary of the allocation is bordered by the A4066, as can be seen from the
aerial photograph below (outlined in red below).

Access to the allocation is currently gained via the A4066, that being the main road running
between the villages of Pendine and Llanmiloe (see below).

Outline Planning Permission was granted for “Residential Development, together with associated vehicular and pedestrian accesses, car parking, landscaping and ancillary
development: site preparation, clearance, treatment, re-profiling and the installation of new services and infrastructure” on the site in Feburary 2016, under application reference W/32544. Since this date, individual plots have sought planning permission for their construction.

The site was allocated in the Carmarthenshire Local Development Plan (2014) under
Allocation SC13/h3 as well as the Carmarthenshire Unitary Development Plan (Allocation PDB41) as can be seen below.

Despite having almost 20 years of support for the principle of residential development at the historic allocation from the Council, only 3 housing units have been delivered to date on a site allocated for 28.

Given that the first plot was developed in 2019, and that to date there, are a total of 3 houses
that have been developed on the site, it seems that there has been a single plot developed
for each following year. At that build rate, it would take an estimated 25 years to complete the site therefore going beyond the proposed plan period. It is for this reason that the site should not be deemed as deliverable and that the allocation should be removed.

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 due to its inappropriateness with regards to the
principles of sustainable growth and so 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

Site SuV61/h1 – Land at Nieuport Farm, Pendine
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
Nieuport Farm, Pendine (LDP Ref. No. SuV61/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 Pendine and Land at Nieuport Farm Allocation)
As part of the current consultation process into the 2nd Deposit LDP, the Council have again
published a “Site Assessment Table” (2023), which provides details of the Council’s analysis
of each received Candidate Site submission and existing allocations within the current
adopted LDP. Proposed allocation SuV61/h1 was considered as part of this process and as
a result the Council concluded as follows:
“Site to be allocated in the revised LDP with reference SuV61/h1. The allocation includes a
parcel of land under candidate site SR/126/002.”
The “Site Assessment Table” 2023 also concluded Candidate Site SR/126/002 (making up
part of Allocation SuV61/h1) as follows:
“Part of the site to be allocated (site ref. SuV61/h1) to allow a more comprehensive
development associated with the current allocation SC13/h1. Otherwise, there is sufficient
and more suitable land available within the settlement to accommodate new growth;”
It is clear from the above that the Council considers that the site is deliverable for the
purposes of 10 houses. However, it is unclear as to why and what evidence the Council has
received to believe beyond doubt that the allocation of part of Candidate Site SR/126/002 to
an already undeveloped Allocation SuV61/h1 provides absolute confidence that the site is
deliverable.
The allocation is brownfield in nature with its topography being relatively level. The eastern
boundary of the allocation is bordered by the B4314 while the western boundary is
dominated by a large, metal shed and what seems to be a storage yard, 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 the B4314, that being the main road running
north into the Village of Pendine (see below).
Photograph 2
(Streetscene of B4314)
Outline Planning Permission was granted for residential development on the site in May
2004, under application reference W/07003. Since this date, reserved matters have been
granted in January 2010 (W/21251) while more recently a non-material amendment was
made to application W/21251 which was in turn granted in November 2011 (PL/02770).
The site was allocated in the Carmarthenshire Local Development Plan (2014) under
Allocation SC13/h1 (as can be seen below).
Plan B
(Extract of current LDP Proposal Map for Land at Nieuport Farm (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 due to its inappropriateness with regards to the
principles of sustainable growth and so 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 the site from the Plan.

Site SuV60/h1 – Land at College Bach, Llangynog
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
College Bach, Llangynog (LDP Ref. No. SuV60/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 6 residential units.
Plan A
(Extract of Proposals Map for Llangynog and Land at College 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 SuV60/h1 was considered as part of this process and as
a result the Council concluded as follows:
“Site to remain as an allocation with reference SuV60/h1.”
It is clear from the above that the Council considers that the site is deliverable for the
purposes of 6 houses, despite there being no clear evidence to support this decision.
The allocation is greenfield in nature with its topography being relatively level while gradually
sloping from north to south. Much of the perimeter of the allocation is covered with mature
vegetation, trees and hedgerows, as can be seen from the aerial photograph below (outlined
in red below).
Photograph 1
(Extract from Google Earth – June 2021)
Access to the allocation is currently gained via the College Bach (north of the allocation site),
via the property’s entrance. However, the western boundary of the allocation also borders
the C2081 (see below).
Photograph 2
(Streetscene of Drefach Road)
The allocation site is located directly off the eastern flank of the road, behind the hedgerow
(on the right in Photograph 2 above). As can be seen in the photograph, there is a sharp
bend in the C2081 some 50 metres north of the allocation, restricting the view of oncoming
traffic and so in turn, the visiblity of any access serving development on the site.
There are no planning applications relating to the allocation site in question to date.
Part of the site was allocated in the Carmarthenshire Local Development Plan (2014) under
Allocation SC15/h2 (as can be seen below).
Plan B
(Extract of current LDP Proposal Map for Land off Drefach Road (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 due to its inappropriateness with regards to the
principles of sustainable growth and so 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.