NEATH PORT TALBOT COUNTY BOROUGH COUNCIL LOCAL DEVELOPMENT PLAN (2011-2026) DEPOSIT LDP REPRESENTATION FORM Please complete in BLOCK CAPITALS and in Black Ink only. All forms must be returned by midnight on Tuesday 15th October 2013. Representations received after the deadline will not be accepted. By post to: Nicola Pearce Head of Planning, Neath Port Talbot County Borough Council, The Quays, Brunel Way, Baglan Energy Park, Neath, SA11 2GG. Or e-mail to: [email protected] (an editable version in Word is available to download at www.npt.gov.uk/ldp ) Alternatively, you can submit your comments directly online at www.npt.gov.uk/ldp/consultation Please note that guidance notes can be found at the back of this representation form. Please use separate forms for each topic you wish to comment on. This form may be photocopied. Please note that representations cannot be treated as confidential. All representations will be made available for public inspection and placed on the Council’s website. Separate forms are available to make representations on the Sustainability Appraisal (incorporating Strategic Environmental Assessment) and on the Habitat Regulations Appraisal. PART 1: CONTACT DETAILS You / Your Client’s Details Agent’s Details (if relevant) Title / Name: Cilybebyll Community Council Rowland Lanchbury Organisation: As above Clerk to the Council (if relevant) Address: 13 Heol y Parc 13 Heol y Parc Alltwen Alltwen Pontardawe Pontardawe Swansea Swansea Postcode: SA8 3BN SA8 3BN Tel: 01792 864061 01792 864061 E-mail: [email protected] [email protected] PART 2: COMMENTING ON THE PLAN An independent Inspector appointed by the Welsh Government will examine the Neath Port Talbot Local Development Plan (LDP). It is the Inspector’s job to consider whether the Plan is sound. There is no legal definition of ‘sound’ but in this context we use its ordinary meaning of ‘showing good judgement’ and ‘able to be trusted’. The questions or ‘tests’, which the Inspector will consider in deciding whether the Plan is sound, are set out below. It may help you to read them and the guidance notes in Part 5 before you tell us what you think of the Plan and its policies. TESTS OF SOUNDNESS [1] The purpose of the examination of a Local Development Plan (the Plan) is to consider whether it is ‘sound’. This means that anyone who wants to comment on or object to the Plan should seek to say how it is unsound and what is needed to make it sound. Sound may be considered in this context within its ordinary meaning of ‘showing good judgement’ and ‘able to be trusted’. To assess the Plan 10 tests are used. These tests are set out in Part 2 of this form. [2] Where you propose a change to the Deposit Plan it would be helpful to make clear which test(s) of soundness you believe the Plan fails. The tests are in 3 groups – ‘procedural’ (2 tests); ‘consistency’ (4 tests); and ‘coherence and effectiveness’ (4 tests). [3] If you wish to comment on the way in which the Authority has prepared the Plan, it is likely that your comments or objections would fall under one of the procedural tests. [4] If you wish to comment on or object to the content of the Plan, it may help to look at the ‘consistency’ and the ‘coherence and effectiveness’ tests. [5] Failing to identify a test will not mean that your comments will not be considered, providing it relates to the Plan (or part of the Plan) and it is clear what change(s) you are seeking. You should include all your comments on the Plan and set out your full case on the form, using accompanying documents where necessary. If you seek more than one change and consider that the Plan fails to meet more than one test of soundness it is not necessary, but may be helpful, to complete separate forms, particularly where the matters are not directly related. It would help if you use separate forms if you wish to make comments objecting to part of the Plan and in support of other parts of the Plan, but again only one form is necessary to express support for different parts of the Plan. Before you set out your comments in detail, it would be helpful to know whether you think the plan is sound, or if you think that all or parts of it are unsound and where it needs changing. I think the LDP is sound I think the LDP is unsound and should be changed X TESTS OF SOUNDNESS: If you consider the LDP to be Unsound, please indicate (3) which Test(s) it does not meet. 3 Procedural Tests P1 It has been prepared in accordance with the Delivery Agreement including the Community Involvement Scheme. P2 The plan and its policies have been subjected to Sustainability Appraisal including Strategic Environmental Assessment. Consistency Tests C1 It is a land use plan which has regard to other relevant plans, policies and strategies X relating to the area or to adjoining areas. C2 It has regard to national policy. C3 It has regard to the Wales Spatial Plan. C4 It has regard to the relevant community strategy/ies. X Coherence and Effectiveness Tests CE1 The plan sets out a coherent strategy from which its policies and allocations logically flow and/or, where cross-boundary issues are relevant, it is compatible with the development plans prepared by neighbouring authorities. CE2 The strategy, policies and allocations are realistic and appropriate having X considered the relevant alternatives and/or are founded on a robust and credible evidence base. CE3 There are clear mechanisms for implementation and monitoring. X CE4 It is reasonably flexible to enable it to deal with changing circumstances. PART 3: YOUR REPRESENTATION AND SUGGESTED CHANGES Please read the guidance notes in Part 5 before completing this part of the form. PLEASE NOTE: Your representation should cover succinctly all the information, evidence and supporting information necessary to support/justify the representation and the suggested change, as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage. After this stage, further submissions will be only at the request of the Inspector, based on the matters and issues he/she identifies for examination. 3(a): Amendment to the Wording of the Plan Does your required amendment to the wording relate to: 3 Where in the Plan? A new Policy A new Paragraph 3 Which Policy Number or Paragraph Number? Changes to a Policy Changes to a Paragraph Please state your representation, including your additional wording or proposed amended wording with your reasons (attach separate sheet if necessary): 3(b): Amendment to the Sites in the Plan Do you wish to: Amend the boundaries of No If Yes, please give the Site Reference: an existing site? Delete an existing site? Yes If Yes, please give the Site Reference: H1/25 Ynysymond Road Alltwen Add an additional site? No If Yes, please give the Site Location: If this site was previously submitted as a Candidate Site, please give the Candidate Site Reference: Please give your reasons (attach separate sheet if necessary): Council believes that the allocation of a site for 50 houses in Ynysymond Road Alltwen will represent an inappropriate extension of the built up area into a green space that has biodiversity value, and result in an unacceptable increase in traffic movements at a busy location in the village. The site has previously been considered and discounted by a Planning Inspector as a potential residential development site. The existence of the Double Line Moth and Purple Moor Grass/Rush has been recognised in the NPT Biodiversity Action Plan, and accordingly, site should remain undeveloped and the Deposit Draft proposal is inconsistent with the aspirations of that Action Plan in seeking to protect the habitats. Access and egress on to Ynysymond Road is proposed through a narrow gap in existing development with inadequate potential for appropriate sight lines along the road. Ynysymond Road itself is a heavily trafficked highway with speed reduction measures in place, and is used consistently as a means of accessing and egressing the village from and to the south. As such it is used by many as a “rat run” to avoid congestion that occurs in Pontardawe and on the A4067 Swansea Valley By-pass, but is itself a residential street subject to traffic conflicts. The allocation of this site, in conjunction with other ongoing developments and proposed allocations in the Deposit Draft, is likely to generate significant pressure on the limited services which are currently available in the community, thereby adversely affecting its character. In particular, the school is operating near capacity already and would need further investment to accommodate any expansion through development within its catchment. Whilst other strategies, particulary the NPT Valleys Strategy and the NPT Community Strategy, stress the need for an integrated approach to community provision so that communities are sustainable, the imposition of 150+ dwellings in Alltwen without comparable investment in facilities will unduly place the settlement under pressure. There does not appear to be any positive presumption in the Deposit Draft to address this deficiency in an integrated manner. Council recognises that some provision for development has already been made in Alltwen through a Landbank allocation currently being implemented (H1/LB/30), although it is clear that its implementation is hampered by deliverability issues. The proposed site at Ynysymond Road would not make a signficant contribution to housing provision, but it would contribute to pressures on existing services, and is inappropriate in both biodiversity and highway terms.