Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin

No change to the Plan

1. Introduction
1.1 This representation has been prepared in relation to Carmarthenshire County Council’s consultation on the ‘Second Deposit Revised Carmarthenshire Local Development Plan’ (2018-2033). The representation is submitted on behalf of NBA Developments Ltd in regard to ‘Land off Heol Y Parc, Cefneithin`.
1.2 The representation is accompanied by the requisite Representation Form and is submitted to the Authority within the statutory consultation period (by the deadline for representations of 14th April 2023).
1.3 A submission was made by NBA Developments Ltd in regard to land off Heol Y Parc, Cefneithin over the course of the preparation of the Revised Carmarthenshire LDP, including most recently, a letter submitted to Carmarthenshire’s Forward Planning department concerning the proposed allocation of this site in the deposit Revised LDP to the First Deposit Revised Plan in March 2020. All representations have been made in close liaison with the Authority, with partnership working characterising the positive progression of the proposed allocation through the LDP process. In continuation of this approach, further representations are submitted to the Second Deposit Revised LDP.
1.4 It should be noted that this Second Deposit Revised LDP representation is to be followed by the submission of further site/allocation-specific documents (comprising Concept Plan; Development Viability Model and accompanying Viability Statement; and Statement of Common Ground). This has been discussed and agreed with officers.

2. Overview
2.1 Within the First Revised Deposit LDP, the site (referred to as ‘Land off Heol Y Parc, Cefneithin`) which was allocated for residential use under PrC3/h8 which makes a provision for 18 units during the plan period.
2.2 Within the Second Revised Deposit LDP, the site continues to be identified as residential allocation under PrC3/h8 for the same quantum of development.
2.3 As per the representation submitted to the First Revised Deposit LDP, the site’s inclusion as a residential allocation in the Second Revised Deposit LDP is supported.
2.4 In summary, NBA Developments Ltd continues to support the Second Deposit Revised Plan on the basis that the Council have accepted the principle of residential use development. NBA Developments Ltd looks forward to working in partnership via a Statement of Common Ground with the Council and delivering this site for much needed residential development within the settlement of Cefneithin which forms part of the Ammanford/Cross Hands principal centre.
2.5 The client, NBA Developments Ltd are a well-established local developer who have consistently provided high quality housing projects around Cross Hands over several years, and have liaised with the local authority to provide several affordable units as part of their work. There is an urgent need to secure continuity of work for the business and the site itself is owned by the developer, who has all infrastructure available and assures the site can be delivered within the plan period.
2.6 In terms of housing allocations within the deposit plan under Policy HOM1, there are a number of allocations in Cross Hands which have been built out and completed providing nearly 200 dwellings (PrC3/h11, PrC3/h12 and PrC3/h13). In fact, allocation PrC3/h12 (Land adjoining A48 and Heol y Parc) has now been completed by the client in addition to the Central Garage allocation in nearby Tumble (PrC3/h29). In order to ensure business continuity, maintaining this site as an allocation is critical. The site owner is keen for the site to developed in the short term, and this will provide much needed housing in the settlement of Cefneithin

3. Update/Progress Following Representations to the First Revised Deposit LDP
3.1 NBA Developments Ltd are now in the process of commissioning a significant amount of further supporting work to inform the proposed allocation since the previous iteration of the Deposit Plan was published in March 2020.
3.2 The following further site-specific information is to be submitted (in follow up to this Second Deposit Revised LDP representation) to further inform, and allow for a robust site allocation to be included in the Revised LDP:
• Updated Site Plan;
• Updated Ecology Report;
• Outline drainage strategy;
• Development Viability Model and Supporting Viability Statement;
• Statement of Common Ground.
Updated Site Plan
3.3 A layout was previously prepared showing a mixture of dwellings totalling 18 units. There was scope to increase this number if detached dwellings are replaced with 2 and 3 bed semi-detached units.
Viability
3.4 NBA Developments Ltd will seek to purchase the Burrows Hutchinson viability assessment model and commission an independent viability study. The completed DVM and supporting Viability Statement will be submitted to the LPA.

4. Second Revised Deposit LDP – Integrated Sustainability Appraisal (February 2023)
4.1 The Integrated Sustainability Appraisal (February 2023) undertaken by the Authority in relation to the Second Revised Deposit LDP indicates that the residential allocation at land off Heol Y Parc, Cefneithin performs well against the defined sustainability criteria, with a number of ‘positive’ and ‘very positive’ outcomes identified (as shown in the extract from the ISA Report below). Figure 1: ISA Summary – land off Heol Y Parc, Cefneithin (PrC3/h8)
4.2 It is the case that a ‘negative’ outcome is identified in relation to ISA 2 (Biodiversity), and ISA 7 (Soil). It is noted that all greenfield allocations perform negatively against the ISA 2 and ISA 7 criteria.
4.3 Previous ecological surveys have not shown any constraints that pose barriers to the allocation of this parcel of land for housing or future development as all ecological issues can be dealt with through reasonable mitigation, compensation and enhancement measures.
4.4 Category 2 sandstone covers just under half of the site, however the resource at this site is considered to be already largely sterilised as it is within 200m of sensitive development. Whilst no major issues have been flagged up within the SFCA, part of this site is at risk of Surface Water Flooding caused by a small watercourse running through the site. It is considered likely that a suitable site layout and detailed drainage design can be produced which seeks to mitigate any risk through good engineering design and if necessary locates highly vulnerable development outside of the area at risk of flooding.

5. Consideration of Tests of Soundness
5.1 It is considered that the Second Revised Deposit Plan meets the three Tests of Soundness, which must be satisfied in order for a development plan to be considered ‘sound’ and able to be recommended for adoption.
5.2 The proposals for the land off Heol Y Parc, Cefneithin are in conformity with the three Tests of Soundness as discussed below in the context of the site and the proposals involved.
Does the Plan Fit? (i.e. is it consistent with other plans?)
5.3 The proposals are compatible with the National Development Framework, and particularly ‘Policy 24 – Regional Centres’ which states that Cefneithin forming part of the Ammanford/Cross Hands principal centre, along with the other identified towns in Mid and South-West Wales, will be the focus for managed growth, reflecting their important sub-regional functions. Regional and local development plans should recognise the roles of these settlements.
Is the Plan appropriate? (i.e. is it appropriate for the area in the light of evidence?)
5.4 The proposals have been derived from evidence submitted with the earlier Candidate Site together with previous engagement with the Council and earlier evidence which formed part of the adopted LDP evidence base which is still relevant.
Will the Plan deliver? (i.e. is it likely to be effective?)
5.5 NBA Developments Ltd are very keen to deliver the site as promised. They have been responsible for developing several plots of land within Cross Hands and it`s surrounding areas, including allocations for 24 and 9 dwellings respectively in Tumble and Cefneithin within the deposit plan (PrC3/h29 & PrC3/h12 ). The client is committed to developing the Cefneithin allocation as it will ensure business continuity for them, whilst providing a valuable contribution towards housing in the area.
5.6 In summary:

• The Second Revised Deposit LDP policy and allocation relating to site PrC3/h8 is founded on robust evidence and provides an appropriate planning framework to deliver modest new homes within the context of the village of Cefneithin where new development has been limited over recent times, in accordance with the overarching vision and objectives of the Plan, as part of a development to come forward over the Plan period. It is imperative that this housing allocation is delivered as it is the sole one within Cefneithin for the deposit plan.

• The policy and allocation allows for the controlled and sustainable development of the site and is supported by a detailed technical review of relevant settlement boundaries and landscape characteristics, as well as of the individual opportunities and constraints relating to the site.

• NBA Developments Ltd consider that the Second Revised Deposit LDP is sound and entirely appropriate in so far as it relates to the site. The proposals for the site are consistent with LDP policy, and capable of delivering a financially viable, sustainable form of development.

• Such a development is considered to accord with the requirements of the Well-being of Future Generations (Wales) Act 2015, and provides an opportunity to contribute towards delivering economic, social, and environmental improvement.

6. Conclusion
6.1 This Second Revised Deposit Plan submission document has been prepared in order to accompany the Representation Form completed in respect of land off Heol Y Parc in Cefneithin. It is submitted on behalf of NBA Developments Ltd.
6.2 The proposed residential land allocation under Policy PrC3/h8 which provides for a modest scale of new residential development, is supported, as is the overall soundness of the Plan.
6.3 This Second Revised Deposit Plan submission fully supports the proposed allocation. Furthermore, the development of other allocations within the deposit plan in nearby areas puts added emphasis on the delivery of this housing allocation. 3 allocations within Cross Hands have been built out recently, whilst another was completed recently by the client in Tumble. This further emphasis that the client has great credentials when it comes to delivering housing allocations within the area.
6.4 The submission of further site/allocation-specific documents, comprising an updated site plan and ecological appraisal, Development Viability Model and accompanying Viability Statement; and Statement of Common Ground, is to follow this overarching representation of support on the Second Revised Deposit Plan, which will further detail and reinforce the viability of the proposed allocation.
6.5 NBA Developments Ltd looks forward to working in partnership with the Council on a Statement of Common Ground, so that the site allocation can be developed aligned with the aspirations of both parties.

Amend Plan to include the site

Carmarthenshire Local Development Plan 2018-2033 – Second Deposit Draft
Objection on Behalf of NBA Developments Limited
Land part of Tirlan Farm, Off Bethania Road, Upper Tumble

We are instructed by NBA Developments Limited to a make a formal representation to the
“soundness” of the Second Deposit Draft of the Carmarthenshire Local Development Plan.
Our clients own an agricultural holding which is set to the rear of residential properties and
fronting the southern flank of Bethania Road, on the eastern edge of Upper Tumble. The
land comprises low-grade, rough pasture which also borders detached and semi-detached
housing which are orientated to front that highway. Our clients are currently redeveloping the
Tirlan Farmyard with four dwellinghouses, which are being constructed in place of former
agricultural outbuildings which lie off the near side of highway.

Our client’s land interests at the eastern edge of Upper Tumble benefit from an edge-of
settlement location, immediately adjoining established housing, and set only 200 metres
from established semi-detached housing which marks the western edge of Cross Hands.
Tirlan Farm includes two open field enclosures which have their highest point fronting the
A476 Bethania Road, before falling southwards to other farm properties east of Tumble.
The Tirlan Farm site lies within walking distance of the settlement’s community facilities,
including convenience shops, primary school, a medical surgery and pharmacy, and regular
public bus service between Cross Hands and Llanelli. It can be regarded as inclusive within
the settlement form.
Our client therefore seeks inclusion of their land as an Alternative Site for a future
Residential development within the defined settlement limits of Upper Tumble within the
Replacement Local Development Plan.

The Site comprises a single rectangular-shaped field frontage, and generally level to gently sloping grazing field set off the immediate southern flank of Bethania Road. The field is marked by a roadside hedgerow which extends the field length, but is punctured by an agricultural access gateway, from where an unmade farm track leads off to a recently completed agricultural outbuilding set in the eastern field of Tirlan. The Representation Site is currently being used as a contractors’ storage area as the four houses at Tirlan are being constructed. Figure 1 below provides a Google Earth image of the site, whilst Figure 2 provides a detailed Ordnance Survey map extract of the site.
Figure 1 – Google Earth – April 2021 – of Representation Site
Figure 2 – Ordnance Survey Map extract of Representation Site
We have noted that the draft settlement limits have been wrapped around the former Tirlan Farm yard, before crossing to established development off the northern flank of Bethania Road, in the form of Llechyfedach. That estate is predominately local-authority-built in origin, but with a small grouping of three modern bungalows about its junction with Bethania Road.

Our clients consider the LDP is “unsound” and should be changed, as it fails to meet the tests for “soundness,” in that the Plan “is not appropriate,” and “will not deliver,” as defined by the Planning Inspectorate’s LDP Examinations Procedural Guidance.
Specifically, our clients consider that the draft settlement limits for Upper Tumble, as defined under Policy SD1 “Settlement Limits”, should be amended to include the land as edged in red upon the extract of the Proposals Map for Upper Tumble, as reproduced below in Figure 3. The land should be appropriately allocated for Housing under Policy HOM1.
Figure 3 – Extract from Proposals Map with Representation site edged in red
This formal representation letter supplements the following documents which comprise a complete submission to the Second Deposit Draft Consultation stage:
- Completed Deposit LDP Representation Form
- Completed Sustainability Appraisal form
- Location plan and Indicative Masterplan
Reasons for Allocation as Residential Development within Settlement Limits

1.0 Position within Residential Setting at Bethania Road
1.1 The Council within the Settlement Framework of the LDP, have categorised Upper Tumble as part of the Cross Hands / Ammanford Principal Service Centre, given it lies only one kilometre from Cross hands town centre, and its range of extensive employment, retail and community facilities and has good public transport links to the nearby Principal Service Centres of Ammanford and Llanelli. In such circumstances, the introduction of a modest residential allocation to the edge of Upper Tumble certainly meets the spatial criteria for locating new dwellings as part of the settlement form.
1.2 In terms of its physical location, the Representation Site is flanked on one side by residential development being the redevelopment of the Tirlan Farmyard, the site layout plan for which is reproduced below as Figure 4. The adjoining field enclosure extends over a field frontage of some 95 metres and terminates at an established mature field hedgerow which separates it from the eastern field at this part of the farm holding.
1.3 Bethania Road itself continues from this point for only a few hundred metres to join Heol Bryngwili and the range of community facilities at nearby Cross Hands including public bus stops. In the context, the site is directly related to the settlement, with proposed occupants able to easily access facilities and public transport. Consequently, the proposals would meet the relevant initial criteria of the Policy SP16 where new residential development should seek to be placed in sustainable locations, accessible on foot / cycle to the settlement’s range of community and commercial facilities and services.
Figure 4 – redevelopment of Tirlan Farmyard curently under construction

2.0 Representation Site Proposals
2.1 This submission is accompanied by an Indicative site layout plan which indicates an indicative setting for a frontage of detached, two-storey dwellinghouses to be orientated to front the public highway and thus complementing the newly forming residential properties being formed at Tirlan, and also orientated to front Bethania Road. Figure 5 below provides a reproduction of that Plan which seeks to provide paired accesses onto the A476 road, and dwellings set back to allow for adequate parking and turning facilities. Traditional rear gardens of a minimum of 10 metres depth would be typically arranged, with the rear perimeter of the site denoted with new hedgerow planting.
Figure 5 – Indicative Site Layout Proposals
2.2 The Representation proposals would ensure that massing of scale was sensitively designed with buildings not rising to more than two storeys. The development of the field frontage will necessitate partial re-modelling of ground levels of the field when forming access driveways. However, the footprints of the proposed dwellings themselves would be sited upon a plateau in the enclosure, so that new development would correspond to the ground levels of adjoining Tirlan Farm properties, as shown in the photographs below.
Photo 1 – view looking west along Bethania Road with field frontage to left and established agricultural access to the farm holding
Photo 2 – view eastwards along public highway with new residential construction evident and immediately adjoining the Representation Site
Photo 3 – the site has limited ecological value being semi-improved grassland

3.0 Sustainable Location
3.1 The Site at Bethania Road lies off a public highway which extends as a principal distributor road between Upper tumble and Cross Hands. Public bus stops lie only some 300 metres distant from the site access at Llechyfedach School. Main public bus services call at these bus stops, and in particular:
- Service 128 – Llanelli to Ammanford, via Llannon and Tumble
- Service 129 – Ammanford to Carmarthen via Tumble and Cross Hands
3.2 Strategic Industrial Estates at Cross Hands are a 15 minutes’ walk from the Site, or 5 minutes by bus.
3.3 The Alternative Site lies within a 3 minutes’ walk of Llechyfedach Primary School which is located further west along Bethania Road. Ysgol Cwm Gwendreath lies a 10 minutes’ walk in the opposite direction through Cross Hands.
Tumble contains a post office, range of convenience stores, hot food take-aways, medical surgery, pharmacy, play facilities, community hall, public houses and cafés.
3.4 Cross Hands centre provides a whole range of large food supermarkets, comparison shops, public houses / cafes, offices, industrial estates and leisure / recreation facilities.
Figure 6 below provides an indication of the proximity of the Alternative site to Tumble village centre at Heol-y-Bryn, and nearby Cross Hands town centre and Business Park and strategic road network.
The red star denotes the position of the Representation Site.
Figure 6 – proximity of Site to Tumble village centre, Cross Hands town centre and major road network

4.0 INFRASTRUCTURE CONSIDERATIONS
4.1 Development of the Alternative Site for residential units would be served by mains water, gas, public sewer and electricity connections, which lie within the adjoining stretch of Bethania Road.
4.2 The public highway itself is equipped with roadside gullies and drainage which aid to discharge run-off from the extended carriageway. The Site comprises of former agricultural pasture. There are no areas of water-logging evident, and therefore at first inspection, it appears that the site benefits from good ground percolation of rainwater and discharge to existing perimeter drainage ditches.
Soakaways would be the most sustainable means of disposing of surface water from individual buildings. If required, attenuation measures can be deployed on site to control surface water run-off during extreme storm events, which could also allow for additional capacity, making allowances for climate change. The field enclosures are served by a series of drainage ditches along the field’s boundaries, which eventually combine and inter-connect discharging surface water to minor watercourses flowing eventually to discharge into the River Gwili. It is considered that as a result of on-site features, there would be several options available to a future development of the site in terms of surface water disposal.
4.3 We have also referred to The Coal Authority Map detailing “Development High Risk Areas” and the location of historic mine entries. Figure 7 below is an extract from that map, and which confirms that the site lies close to two seams of coal, however, the road frontage appears free from any mining legacy.
Figure 7 – extract from Coal Authority interactive map with site highighted

5.0 Housing Land Availability in Tumble
5.1 Despite being part of the Cross Hands Principal Service Centre Cluster, Policy HOM1 indicates only two sites allocated for housing in the whole of Tumble. An extract from that HOM1 schedule is reproduced below.
Figure 7 – Housing Allocations at Tumble
5.2 The re-development at the former central Garage have already been completed by NBA Developments, whilst the site at Bethesda Road has lain undeveloped since demolition of the commercial unit was completed several years ago. Therefore, for a settlement with several thousand residents, there are no modestly sized residential development opportunities. The development of the Alternative Site for only five additional dwellings will not place any burden whatsoever, or indeed compromise housing land supply.

6.0 Conclusion
6.1 This Representation to the Second Deposit Draft of the Revised LDP has sought to promote the inclusion of an Alternative Housing allocation on land off Bethania Road in Upper Tumble.
6.2 Our client has illustrated that their indicative proposals to develop a small site of frontage dwellings to complement that currently in existence adjoining at the farmyard redevelopment on the adjoining section of road frontage. Accordingly, the development of the field frontage with five detached dwellinghouses will not appear at odds to the prevailing spatial pattern of development in Tumble. The locality has numerous examples of modern frontage development being completed at edge of settlement locations, which in turn, advocates that the form of development proposed for modest housing numbers is no different, resulting in it being respectful to the character and setting of the locality.
6.3 We respectfully request that this Representation be given careful examination, and consequently the defined settlement limits of this part of Tumble realigned to include the Representation Site in the Proposals Map of the adopted Local Development Plan.