Vale of Grwyney Community Council Comments on Additional Housing, Mixed Use and Employment Allocations, Matters Arising and Changes Sustainability Appraisal Report Addendum Statements on CS66 and SALT 050 ‘Former’ Army Camp Cwrt-Y-Gollen

The Vale of Grwyney Community Council and indeed the residents are extremely disappointed with the Inspector’s directive to include Cwrt Y Gollen in the Local Development Plan. Regardless of the glaring errors made during the Inquiry (regarding issues such as sustainability, unnecessary vehicle journeys, availability for development) the fact nevertheless remains that the unsuitability of the site is and has been very apparent. You will be aware that a previous application was rejected, the appeal was rejected and the site was deemed inappropriate for inclusion in the LDP by the BBNP.

Tests of Soundness

We would contend that Cwrt Y Gollen on an individual basis conflicts with the tests of soundness in almost all respects.

P1 Community consultation has been thorough and local opposition to the development is united as shown by the three public meetings held by the Community Council and the National Parks. The WAG appointed Inspector at the public appeal was scathing regarding the total disregard of community wishes. It would appear that this is a case of déjà.

P2 It is doubtful that any other site is less sustainable than Cwrt Y Gollen. There are no facilities for day to day living such as shops, doctors schools etc. All we have in the small village is a pub, a village hall and a chapel that opens 12 times per annum and has a congregation of 8, one of which is local. Glangrwyney has been classified a level 4 settlement and Cwrt Y Gollen as a level 5. There would be a reliance on car journeys (estimate 600 per day) which makes it environmentally unsound. It is on a flood plain and therefore not future proofed. Without a major sewage improvement scheme to Crickhowell, onsite treatment would be in the vicinity of both the rivers Usk and Grwyney. The land is classed as a “high risk” contamination site. From a sustainability and an environment viewpoint this is an exemplar of why not to build on a site.

C1 Inclusion of the site would contravene many of our National Park principles and policies, not least by ignoring the real heritage and cultural impacts. C2 Nationally, the site flaunts many of the recommendations of Planning Policy Wales. C3 Again, a conflict arises re sustainability and listening to the community. C4 Contravenes many of the principles of the National Park Management Plan

With regard to coherence and effectiveness it would seem that judgement of housing sites has not been based on any robust and creditable evidence, rather on the sustained comments of Agents seeking financial gain.

Previous Planning Application and Appeal

The site was refused outline planning consent resulting in Crickhowell Estates appealed against this decision and a Public Inquiry was held in February 2011. In July 2011 the Inspector recommended that the Appeal was dismissed and this was endorsed by the Minister for Environment and Sustainable Development in November 2011. It should be noted that not only were the local community totally opposed to development on this site, the following organisations and bodies also objected at the Public Inquiry: • Crickhowell Town Council • Campaign for the Protection of Rural Wales • Kirsty Williams AM • County Councillor John Morris • Brecon Beacons Park Society • Llanelly Community Council • Campaign for National Parks • Crickhowell and District Civic Society We would also like to highlight items mentioned in the Inspector’s report that in his opinion had specific relevance to the site’s inclusion in the UDP as follows: • Evidence suggested that the Cwrt y Gollen site was included in the draft UDP as a windfall brownfield opportunity that would fortuitously make up for a possible lack of readily identifiable housing sites in Crickhowell. However, there was no evidence that the process of deciding that 7.4ha of land at Cwrt-Y-Gollen should be identified for residential development involved any systematic comparative analysis of the potential availability of alternative sites for housing development to meet the needs of Crickhowell and the surrounding area, or any serious consideration of how well the allocation compared with other possible ways of meeting the identified housing need, having regard to wider planning objectives including fostering sustainable communities and having regard to the statutory purposes of Park designation. • The Inspector stated that the land appeared to have been requisitioned during World War 2 and/or acquired pursuant to compulsory purchase powers and then reverted to the original the owner under the Crichel Down Rules and queried whether the owner should benefit from the brownfield “preference” when the previous development occurred only as a result of the requisition and Crown prerogative.

LDP CS66 Cwrt-Y-Gollen

Please see attachment Appendix (1) Glangrwyney Site Assessment CS66 Cwrt-Y-Gollen

Salt 050

All the factors that resulted in the rejection of the site remain. We do not feel it necessary to detail all the reasons as you are fully aware of them but as a synopsis: 1) 70 houses would generate approximately 600 unnecessary vehicle movements a day and should rightly be seen as environmental vandalism. 2) The site is in an isolated location with no facilities for day to day living. It is not in Crickhowell, no matter how inconvenient this may be. 3) Powys CC has stated that the land is considered a “high risk” of contamination due to unregulated weapon use and storage by the US Army during World War 2. 4) The only entrance is on a flood plain and does flood which could restrict Emergency vehicles and is in any event patently unsustainable. 5) The development would double the size of the existing community of Glangrwyney and would overwhelm the historical village core. 6) It is still an active and expanding army camp with the associated noise contamination from frequent weapon firing. 7) The street lighting over the “parkland” would be visually intrusive and form a hard edge along the western side of the A40. 8) The site is not sewered and Crickhowell treatment plant is at capacity. The Environment Agency does not want an onsite facility due to the proximity to the Usk and Grwyney Rivers. 9) Full consultation with residents showed that the houses are not needed and a petition of Glangrwyney householders shows that 97% are against development.

During the recent hearings, the Inspector claimed that the site was available for immediate commencement by the developer whereas in reality the landowner merely intends to sell it to a developer if he gets outline planning permission. This does not necessarily accord with an immediate start. Additionally, the issues of contamination and sewage preclude a speedy start and indeed may be a major obstacle to any development. Should the site be included in the LDP we will appeal on the above and specifically on the infringements of Planning Policy Wales and the statutory obligations of the National Park and its Management principles. Any housing deficit identified in the LDP should not weigh against the primary statutory purposes of the Park relating to conservation and cultural heritage factors. The following policies are applicable and the contraventions confirm the inappropriateness of the site for development:-

Planning Policy Wales states:

PPW para 4.6.8. Development in the countryside should be located within and adjoining those settlements where it can be accommodated. PPW para 4.8.1. Brownfield sites are not all suitable for development because of location. This certainly applies in National Parks. PPW para 5.5.6. There are no special or exceptional circumstances that apply for development. PPW para 8.6.2. The development would fail to conform to guidance due to traffic and transport implications.

Brecon Beacons Management Plan States:

NPMP para 1.3. Relating to the Sandford principles on conserving the natural beauty of the Park and its cultural heritage. NPMP para7.1.5 Conserving the Parks historical settlement patterns, particularly in the east of the Park. NPMP Doubling the size of Glangrwney would disrupt the “irreplaceable” settlement pattern identified.

The Sandford Principle

The Sandford Principle seeks to protect the natural beauty of the Park for the current and future generations and aims to ensure the vitality of local communities which is stated as tantamount with the conservation and enhancement of the Park and its resources. Careful regard must be given to the linkage between local communities and environmental conservation. As such the National Park has a duty to seek to foster social wellbeing of local communities which open market housing on any scale would destroy. Adding a large housing development onto a small historic village of 70 houses contravenes: • Principle 1) Category V Landscapes, by destroying the cultural values of our village • Principle 4) Recognises that management must be undertaken with and through local people and mainly for and by them. This principle recognises that the full involvement of local people is essential and that protected areas should never be planned against their long term interests. Given the size and location of our small historical nucleated settlement large scale housing would be inappropriate. The current planning application for this site seeks to more than double the size of our village • Principle 9) States that economic activities that do not need to take place within the protected landscape should be located outside it. A test for this is sustainability for which this site fails due to its isolated location without facilities and requiring the avoidable generation of many car journeys • Principle 12) Suggests success of management should be measured in environmental and social terms. A housing development on this site would generate unnecessary car journeys (600 plus per day minimum) and would change forever the cultural heritage of our village. This would also impact on the quality of life for local people

Conclusion

Houses should be built where they are needed and in a sustainable location. A development that doubles the size of our village would represent a fundamental breach of the special qualities of the National Park. The size and location of the proposed development would adversely affect the natural beauty of the Park and infringe on its cultural heritage. Given the sustainable sites already identified which would sufficiently address the predicted shortfall, we respectfully ask that Cwrt Y Gollen be excluded from the Local Development Plan.