Model Representation Form for Local Development Plans
Total Page：16
File Type：pdf, Size：1020Kb
Office Use Only Cardiff County Council Date Received Local Development Plan 2006 - 2026 Representor Number Alternative Site Representation Form
In response to consultation on Cardiff Council’s Deposit Local Development Plan (LDP) formal comments have been received for policy boundary modifications, for new site allocations or for the deletion, modification or for a change of use of sites proposed in the Plan. These are known as Alternative Sites (also termed Site Allocation Representations) and are detailed in the Alternative Sites Register. This is your opportunity to support or object to any of the Alternative Sites proposed.
Please use this form to make your comments on the site allocation representations received. Your comments should be about alternative sites only. If you are unable to complete the online form you can photocopy this form or download copies from the website at www.cardiff.gov.uk.
All completed forms should be returned by midnight Friday 4th April 2014 to: LDP Team, Room 132, City Hall, Cardiff, CF10 3ND or email [email protected]
Please note that these site proposals are not being put forward by Cardiff Council, they have been submitted by the public or by organisations having an interest in Cardiff.
PART 1: Contact details
Your/ your Client’s details Agent’s details (if relevant)
Title: Mr Name: David Barnard Job title: (where Clerk relevant) Organisation: St Fagans Community (where relevant) Council Address: 4 Leamington Road Rhiwbina, CARDIFF, CF14 6BX Telephone no: 029 2061 0861 Email: [email protected]
Please note that all representations will be made available for public inspection and cannot be treated as confidential. However to ensure data protection we will remove personal details from publically accessible documents
1 4 April 2014 Signed: Date: David Barnard
PART 2: Commenting on Alternative Sites
Which Alternative site(s) are you supporting or objecting to? (Please refer to Alternative Sites Register)
Alternative site reference number(s)/name(s)
AS (N) 1 NORTH OF LLANTRISANT ROAD : OBJECT
AS (N) 3 BRUMMEL DRIVE, CREIGIAU : OBJECT
AS (N) 10 LAND AT SNOWDEN ROAD, ELY : OBJECT
AS (N) 14 FORMER ARJO WIGGINS, ELY BRIDGE : OBJECT
AS (B) 1 ROOKWOOD HOSPTIAL : OBJECT
AS (B) 2 HENSTAFF COURT : OBJECT
AS (B) 3 SOUTH OF JUNCTION 33 ON THE M4 : OBJECT
AS (B) 5 CWM FARM, RADYR : OBJECT
AS (B) 6 STRATEGIC SITE NW CARDIFF : SEE COMMENTS
AS (A) 6 MAES Y LLECH FARM : SUPPORT
AS (A) 8 SOUTHERN BOUNDARY OF STRATEGIC SITE C : SUPPORT
AS (A) 11 LAND NORTH OF JUNCTION 33 ON M4 AND SOUTH OF CREIGIAU : SUPPORT
AS (D) 1 STRATEGIC SITE C – NORTH WEST CARDIFF : SUPPORT
AS (D) 2 STRATEGIC SITE D – NORTH OF JUNCTION 33 ON M4 : SUPPORT
AS (D) 3 STRATEGIC SITE E – SOUTH OF CREIGIAU : SUPPORT
AS (D) 7 GREEN BELT : OBJECT
AS (D) 8 LAND AT DAN-Y-GARTH, PENTYRCH : SUPPORT
St Fagans Community Council requests that our comments on the Alternative Sites are taken in the context of the evidence that we have already presented that the Deposit Local Development Plan (DLDP) is fundamentally flawed and unsustainable. Cardiff Council claim to have the vision that “Cardiff will be a world class European capital city with an exceptional quality of life and at the heart of a thriving city region”. We support the vision, as we expect everyone with a real interest in Cardiff to do. But we do not believe that the DLDP will help to deliver the vision; rather, we believe that it will have the opposite effect, and adversely affect the quality of life of many existing residents.
2 The DLDP proposes 11,500 houses on greenfield sites in NW Cardiff. These sites have no, or very poor, infrastructure. Transport is a major issue but sewerage and drainage are also major concerns. The roads are already congested, and particularly in and around St Fagans village are suitable only for a rural environment, not urban development. The area is served only by an infrequent bus service. There is no funding in place for infrastructure. The plan is led by landowners and developers who argue against contributing to fund the infrastructure. Their only proposal for a development of 5,000 houses at Strategic Site C is a new bus service – hardly adequate to prevent several thousand extra cars on congested country roads.
We do not believe that any development in this area should be considered until AFTER the required infrastructure is in place. The Metro may provide an opportunity for new communities to be developed along the route, providing easy access to public transport for residents, and so become a realistic alternative to the car. This will help Cardiff achieve a 50:50 modal split. Wishful thinking and development without infrastructure will not bring about the. 50:50 modal split.
Specifically on the Alternative Sites consultation, we are concerned that additional sites are being put forward so that they may be developed in advance of the allocations already in the DLDP. This is not in the public interest. A site should not be included in the DLDP unless it conforms to the sustainable strategy.
The Alternative Sites proposed add to the scale of proposed developments and consequently, by creating further urbanisation of the City’s environs, threaten to destroy many of the qualities that make Cardiff an attractive place to live. The developments will certainly destroy the unique qualities of the historic and environmentally important area of St Fagans. Cardiff requires an integrated strategy that protects and enhances these qualities for the future. It must not be ruined by unsustainable housing developments.
If you are objecting to an Alternative Site it would be helpful if you could in- dicate which Test of Soundness you consider it to fail (Please refer to guid- ance note).
Primarily P2, C1, C2, C4, CE1, CE2, CE3 and CE4
Please note if you do not identify a test it will not mean your comments will not be considered.
PART 3: Your Response
Your comments should be set out in full. This will help the Authority and the Inspector to understand the issues you raise. You will only be able to submit further information to the Examination if the Inspector invites you to address matters that he or she may raise.
Please indicate if you are submitting other material to support your comments.
Please use the space provided to set out your representation. Please be
3 explicit as to which site your comments relate to. (Continue on a separate sheet/expand box if necessary)
Proposed Alternative Sites - New Sites
AS (N) 1 NORTH OF LLANTRISANT ROAD for Barratt Homes. Residential. Submission requests site is:- • considered either as stand alone site and identified in Policy H1 as a non strategic housing site • or as an extension to Strategic Site D North of J33 on M4. • excluded from the Green Belt boundary Policy KP3(A) • included in the Settlement Boundary Policy KP3(B)
If allocated would also require changes to:- • SLA boundary to exclude site Policy EN3
We strongly oppose the addition of AS (N) 1. It is a misrepresentation to present this as an extension to Strategic Site D. The site is on the north side of Llantrisant Road and has no common boundary with Strategic Site D. Access to Strategic Site D will be via junction 33. The proposed new site will be accessed via Llantrisant Road, which is already heavily congested and would not be safe. The proposed new site will only add to the congestion. Llantrisant Road cannot be widened on the south side; widening elsewhere will reduce the size of the site and make it unviable. The site is above Llantrisant Road and would visually dominate the area. . We support the extension of the Green Belt which is counter to the inclusion of N1.
This fails P2, CE1, CE4: - Additional traffic congestion is not compatible with a sustainable community - The site is not a logical extension to Strategic Site D - There is no flexibility in the proposal
AS (N) 3 BRUMMEL DRIVE, CREIGIAU : residential. Submission requests site is:- • considered either as a stand alone site and identified in Policy H1 as a non strategic housing site • or as an extension to Strategic Site E South of Creigiau • excluded from the Green Belt boundary Policy KP3(A) • included in the Settlement Boundary Policy KP3(B)
If allocated would also require changes to:- • SLA boundary to exclude site Policy EN3 • Limestone Safeguarding Area to exclude site Policy M9 6 We strongly oppose the inclusion of AS (N) 3. It is inconsistent with the stated objective to achieve a 50/50 modal transport split as even the developer acknowledges that this site will lead to an increase in car journeys. The site will be detrimental to the environment, the added car traffic adversely affecting air quality. It will threaten the identity of Creigiau village and put an impossible demand on the village facilities. We support the extension of the Green Belt which is counter to inclusion of AS (N) 3.
This fails P2, CE1, and CE4. - Added car traffic will not contribute to achieving a 50:50 modal split and fails sustainability test - This is not a coherent strategy as it fails the sustainability test that underlies the DLDP. - There is no flexibility in the proposal Summary
4 Table AS (N) 10 LAND AT SNOWDEN ROAD, ELY landowners St Fagan's No 1&2 Trust. Residential
If allocated would also require changes to:- • Settlement boundary to include site Policy KP3(B) • SLA boundary to exclude site Policy EN3
We strongly object to the addition of AS (N) 10. This site is public open space that is continuously used by residents for recreation, including football, exercise and dog walking. It would encroach into the Special Landscape Area in the Ely Valley and be very visible on the sky-line from the north.
Rather than providing access to open spaces and improved recreation facilities, as the developers argue, development of this site will remove 12.8ha of well used sports pitches and open space from community use. A plan to maintain and improve the existing facilities and open space, working with local residents, would bring more benefit to local residents than 270 houses.
This fails C1, C2, C3, C4 and CE4. - The proposal takes no account of national strategies to promote healthier lifestyles and encourage active community involvement. - Destroying recreation areas, including football pitches is against national efforts to encourage exercise and reduce obesity - There is no flexibility in the proposal
AS (N) 14 FORMER ARJO WIGGINS, ELY BRIDGE for Ely Bridge Development Company. Residential (Strategic Housing site). Submission requests that:- • Policy KP2 is amended to identify former Arjo Wiggins as a strategic housing site (750 homes) and not as commitment as currently shown in Deposit LDP
We strongly object to the site’s removal from the 5 year housing land supply. This is a brownfield site that has remained undeveloped for many years even though it has been the subject of considerable remediation and preparatory work at public expense. A planning application, for 760 houses, retail and offices, was approved by Cardiff’s Planning Committee on 26 February 2014. The site is an area that is already well served by public transport and should become part of the 5 year land supply.
Proposed Alternative Sites – Boundary Amendments
AS (B)1 ROOKWOOD HOSPTIAL – Residential on larger site. Submission requests:- • site boundary is amended from 2.9 ha to 3.4 ha.
We object strongly to intensification of use of this site and to its potentially adverse impact on the integrity and setting of the listed buildings, including the unique 17th Century Gothic Summerhouse. It will add to local traffic congestion at the junction with Llantrisant Road for which there is no solution.
This fails P2 - Additional traffic congestion is not compatible with a sustainable community .
5 AS (B) 2 HENSTAFF COURT : Residential. Residential as part of enlarged Strategic Site D, North of J33 on M4. Submission requests:- • boundary of Strategic Site D, Land north of J33 is amended to include land at Henstaff Court
We strongly object to the inclusion of B2. Site D is already larger than can be developed within the Plan period. Allocating yet more land at this stage risks another sporadic car-based development accessed directly off Llantrisant Road. The addition of this site would increase car trips and is coded red in the Sustainability Appraisal for adjacent Strategic Site D. It would take Cardiff further away from the 50:50 modal split. Addition of this site will add to air quality problems, coded orange in the Sustainability Appraisal for adjacent Strategic Site D. We support the extension of the Green Belt to include Sites D and E which is counter to inclusion of B2.
This fails P2, C2 and CE4 - Additional traffic congestion is not compatible with a sustainable community; air quality and consequently health of the area will suffer. - It will make achieving a 50:50 modal split more difficult. .
AS (B) 3 SOUTH OF JUNCTION 33 ON THE M4 Residential as part of enlarged Strategic Site D, North of J33 M4. Submission requests:- • altering Strategic Site D to include land south of Junction 33, M4
We strongly object to the inclusion of B3. This parcel of land is divided from Site D by a motorway junction. It has substandard lane access and would not be possible to reach on foot, cycle or via public transport. Access to the site is also off a particularly dangerous stretch of the A4119 Llantrisant Road onto Heol St y Nyll. It should be ruled out as unsustainable.
Junction 33, M4 is currently undergoing alteration to allow a dedicated left hand lane from the west- bound M4 onto the A4232, thus preventing any additional access or egress from where the slip road or A4232 abuts the site.
The addition of this site would not meet the sustainable transport target for the LDP of a 50:50 modal split and would increase the reliance on cars. It would, therefore, add to air quality problems, coded orange in the Sustainability Appraisal for adjacent Strategic Site D.
This fails P2, C2 and CE4. - Additional traffic congestion is not compatible with a sustainable community, and will not contribute to achieving a 50:50 modal split. - This is a potentially dangerous proposal because of location; it lacks a clear means for implementation. - There is no flexibility.
AS (B) 5 CWM FARM, RADYR for Waterstone Homes – Include within settlement boundary. Submission requests:- • Settlement Boundary is amended to coincide with Mineral buffer zone
We strongly object to the inclusion of B5. It would not be sensible to squeeze housing right up to the buffer zone in particular because the previous rail formation provides a sense of enclosure and protection to the existing modern estate. The existing exclusion zone already means that current residents find the quarry’s blast vibrations alarming. The remaining green space abuts a SSSI, is of increasing local importance, and should not be reduced further.
This fails P2 and CE2. - This will not create a sustainable community - It is clearly not founded on a robust evidence basis as the proposal lacks logic
6 AS (B) 6 STRATEGIC SITE NW CARDIFF for Plymouth Estates. Strategic Site C, North West Cardiff. Amend boundary to exclude Site. Submission requests:- • Exclusion of Site in ownership of Radyr Farm
We strongly oppose the proposal to enlarge Strategic Site C by adding what is actually a detached piece of land close to Radyr (identified in the submission as land at Goitre Fawr Radyr). We also oppose the implication that further increases in the scale of development can be achieved without advance investment in infrastructure. Our view on the need for advance infrastructure is supported by the findings of the independent Strategic Environmental Assessment of the LDP which have not been given sufficient weight in influencing the Deposit Plan.
Plymouth Estates have used the opportunity to put forward proposals for their Plasdwr development in a 222 page submission. They argue in favour of early release of land both within Site C and on further land in their ownership and identified in the DLDP for ‘flexibility’ in case demand for housing is higher than expected. They argue that developers may not be able to meet the housing completion rates required by the DLDP. Their solution to that is to open up more land to development.
Close reading of the developer’s submission suggests that this Alternative Site submission may be an attempt to 'soften up' the opposition in advance of an early planning application. We object very strongly to this land coming forward now, or at any stage in future, as it would be entirely contrary to the sustainability principles enshrined in Planning Policy Wales and the LDP. This submission appears to be a backdoor mean of advancing the main interests of Plymouth Estates.
We strongly oppose early development before adequate infrastructure is in place and we oppose the development of the 10% ‘flexible’ overflow sites before the Strategic Sites are completed. Cherry-picking by developers of sites that best meet their needs, and not those of the existing and new communities, threatens to create disjointed unsustainable communities.
Plymouth Estates also argue that Strategic Site C should be zero charged for Community Infrastructure Levy and propose the use of s106 agreements for provision of infrastructure. Sporadic development of small sites will not produce adequate community return via s106 agreements or CIL, nor will it provide a fair and necessary contribution towards the major transport and other infrastructure required to support major expansion of the City. A piecemeal approach through developer-led early applications will not deliver the ambitious outcomes set out in the DLDP’s Masterplanning approach.
The Plymouth Estates’ Masterplan includes a dual carriageway linking Llantrisant Road and St Fagan’s Road. It passes through the district shopping centre and caters for traffic within the new estate and accessing the new shopping centre. This shows little understanding of existing traffic conditions. It would clog surrounding access roads. Plymouth Estates assess St Fagan’s Road as capable of being widened to accommodate a single bus lane with two lanes of general traffic. They do not mention that this would create adverse conditions for current and future pedestrians, cyclists and bus users. Their bus-based public transport solution uses St Fagan’s Road and Western Avenue to link with the already congested Cowbridge Road East. The existing bus lane from Western Avenue to Victoria Park results in narrow lanes for other vehicles and cyclists. Additional buses using this lane, plus back-up of general traffic, will mean deteriorating travel conditions in future.
The bus travel times quoted from Creigiau to the City Centre are unrealistic. Actual bus travel times – even with some sections of bus priority – will not provide any motivation to use public transport. It frequently takes up to 45 minutes to travel from the City Centre to Llandaff at peak hours and thus 60 minutes or more to reach Creigiau. The Plymouth Estates’ proposals include an express bus for later phases. However, buses would need to use the same bus lanes as regular buses beyond the site on roads that are already congested and hard to improve.
7 The transport assessment pays scant regard to the already congested rural roads that will become even more gridlocked if any development goes ahead BEFORE infrastructure is in place. Crofft-y- Genau Road/Michaelston Road is used by traffic from Llantrisant, Pentyrch, Creigiau and further afield as the route to the city centre and Culverhouse Cross. The roads are narrow, and cannot be widened. The situation is made considerably worse by a level crossing which closes this route for 28 minutes in every hour, causing large queues of traffic to build up throughout the day.
In the course of their submission Plymouth Estates give scant attention to the historical and environmental importance of the area, including around St Fagans village. For example, they claim to have avoided the site of the Battle of St Fagans, but their proposals do not avoid Pentrebane Ridge, mentioned in documents from the time and the site of the Parliamentarian Army encampment. Recent investigations by the National Museum of Wales, including analysis of aerial photographs has shown that several old roads run under the fields in and around the National History Museum in St Fagans, including some fields included in Strategic Site C.
This submission fails tests P2, C1, C2, C4, CE1, CE2, CE3, and CE4 - This will considerably increase traffic congestion and car use: it fails sustainability tests. - A single additional road as proposed will not relieve the pressure on already gridlocked roads, only add to the problems. - Traffic may flow within the estate but there will be chaos when traffic exits the estate - The proposal has no regard for adjoining areas and strategies - There is no regard or awareness of existing local communities and the impact of the proposal. - There is complete disregard of community strategies - Additional traffic congestion is not compatible with a sustainable community - There is no prospect of achieving the 50:50 modal split
Proposed Alternative Sites – Amend Site Allocation Policy/Change of use
AS (A) 6 MAES Y LLECH FARM – Retain farm and omit from Strategic Site C. Submission requests:- • retaining Maes-y-Llech Farm in agriculture by removing from Strategic Site C North West Cardiff
If change accepted would require:- • changes to the boundary of Strategic Site C to exclude site Policy.
We believe that Strategic Site C should be removed from the LDP (see comments below). But aside from this we support the proposal to retain Maes Y Llech farm in agriculture.
This amended site allocation is not simply to protect open spaces but a working farm in the middle of Strategic Site C. The land should be retained for agricultural use and the farm retained. It will be important for the woodland bluebells (for which the UK has international responsibility) to be kept and protected as public open space.
Local people can confirm that much of this land has not been ploughed since the end of WWII and is a reservoir of biodiversity and historical interest that must be properly surveyed before any development.
Agriculture is of vital importance to the economy, of Wales and the Cardiff area. Cardiff is planning waste disposal facilities that will produce slurry by-products that can best be disposed of on land. Local farms will be the most carbon-lite and cost effective solution for this, so offering a sustainable solution.
8 A8 SOUTHERN BOUNDARY OF STRATEGIC SITE C – Retain as Green Corridor and omit from Strategic Site C. Submission requests:- • southern boundary of Strategic Site C is moved to provide a green corridor around St. Fagans Village
If change accepted would require:- • changes to the boundary of Strategic Site C to exclude site
We believe that Strategic Site C should be removed from the LDP (see comments below). But aside from this we strongly support the proposal for a Green Corridor to protect the historic village of St Fagans. Retention of a green corridor will protect the unique character of the area, including woodland and important ecological habitats and the old and listed buildings in the village. A green corridor will act as a buffer zone for the existing conservation area, which was established to protect St Fagans in a rural environment. Development on the scale proposed undermines the protection given to st Fagans by the existing conservation area.
The area is close to the Wales National History museum, an attraction visited by many locals and thousands of visitors every week. The setting and environment of the museum adds to its attraction, and should be preserved, particularly as the Museum is now subject to substantial investment by WG, aimed in part at increasing visitor numbers.
The area includes woodland that contributes significantly to the landscape value. The escarpment overlooking St Fagans Road is important and its loss would destroy the visual entrance to the Ely Valley.
AS (A) 11 LAND NORTH OF JUNCTION 33 ON M4 AND SOUTH OF CREIGIAU - Green Belt Submission requests:- • Strategic Sites D and E are designated as Green Belt
If change accepted would require:- • changes to Green Belt boundary Policy KP 3 (A) to include sites
We strongly support this. The importance of open spaces to the health of this area and its residents is well known (see comments below on AS(D)1. It will help to maintain the historic and cultural identity of the villages to the north-west of Cardiff. The land at A11 is unlikely to be built on because of its hilly contours.
We support extending the Green Belt on all land north of the M4 and want to make the M4 the natural boundary for the Green Belt. We know that there are calls to extend the Green Belt up to the conservation area in St Fagans and support this. As Cardiff Council itself recognized, Cardiff’s green spaces are part of its distinctiveness and should be protected. This becomes urgent in the face of the scale of development proposed by the LDP.
Proposed Alternative Sites – Delete Site Allocation
AS (D) 1 Strategic Site C – North West Cardiff : Delete We vigorously support this. The area consists of fields and wooded areas that provide recreational facilities for local residents from different communities – including Pentrebane, Fairwater, Rhydlafar and St Fagans. Local people can confirm that much of this land has not been ploughed since the end of WWII and is a reservoir of biodiversity and historical interest that must be properly surveyed before any development. The area provides recreation for residents of these areas and quick easy access to open spaces so beneficial to health, wellbeing and economy of the area (as detailed in the National Ecosystem Assessment and the March 2012 NHS Wales Report “Green space, reduction of health inequities, and cost effectiveness of interventions.”)
The area provides physical separation from large housing areas which are of much more recent origin than most of St Fagans.
9 Strategic Site C is of considerable environmental and historic importance, being close/adjacent to the historic area of St Fagans and vicinity: an area described as “rich in biodiversity” (St Fagans Circular Walk leaflet.) The development is close to SINCs, SSSIs and habitats for protected flora and fauna (including some on the European Protected Species list.). It is fatuous to suggest that these will not be damaged by such large scale destruction of green fields.
The roads in and around St Fagans, and therefore the proposed development, are already unable to cope with the volume of traffic. The infrastructure of the area is designed for a rural environment, and is totally unsuitable for an urban development. A significant issue is not simply the number of cars, but that traffic movement is impacted severely by a level crossing that stops traffic moving for 28 minutes in every hour on the main thoroughfare linking the area to Culverhouse Cross and the A4232. Development on these sites should not even be contemplated until after new infrastructure is in place.
We are aware of discussions about the Metro for South Wales but seriously question the relevance of the Metro to this LDP. Planning for the Metro is still at an early stage; reports suggest that the first stage will run from Cardiff Bay to central Cardiff, so there is little prospect of the Metro running through NW Cardiff by 2026 when the LDP ends.
Even if the Metro is in place it will not solve all the infrastructure problems already faced by the area. People will still use their cars – on roads that are already gridlocked.
This development is proposed at a time that the National History Museum, located in St Fagans, the most popular tourist attraction in Wales is undergoing a major development, partially funded by public money, with the aim of increasing visitor numbers by up to 400,000 every year. This will create further congestion problems (a recent study showed that approximately 50% of visitor cars enter or exit via St Fagans village; increasingly the village is used by visitor coaches). It is already the case that some visitors have difficulty getting to the Museum and some even give up trying (the latest example being the 2014 St David’s Day event.)
AS (D) 2 Strategic Site D – North of Junction 33 on M4 : Delete
We strongly support the deletion of site D, north of junction 33 on M4 because, this taken in conjunction with Site E will lead to development on both sides of the A.4119, leading not so much as an extension to Creigiau village but its envelopment. The Welsh Language has not been taken into account. A massive house building programme as proposed would triple the size of the village and lead at the very least to dilution of Welsh as valued by the community and required in TAN 20 guidance.
It is absolutely vital that the LDP anticipates and is consistent with the City Region approach to planning being developed by Welsh Government. The LDP is heavily dependent and links closely with the Metro scheme being developed by the Welsh Assembly. However, the timing of both projects is incompatible with the LDP in 2015, and the Metro suggested to be done for 2025 at the earliest. This links in with our phasing argument which is detailed below.
Phasing: The first phase should be for those sites in which the infrastructure is already better placed to cope with the additional demands which are pre-dominantly in the east of the city. Following this, later phases should include those sites where considerable infrastructure has been secured and which could also link to the Metro Scheme project in future years.
10 AS (D) 3 Strategic Site E – South of Creigiau : Delete
We strongly support the deletion of site E, South of Creigiau because, this taken in conjunction with Site D will lead to development on both sides of the A4119, leading not so much as an extension to Creigiau village but its envelopment. The Welsh Language has not been taken into account. A massive house building programme as proposed would triple the size of the village and lead at the very least to dilution of Welsh as valued by the community and required in TAN 20 guidance.
It is absolutely vital that the LDP anticipates and is consistent with the City Region approach to planning being developed by Welsh Government. The LDP is heavily dependent and links closely with the Metro scheme being developed by the Welsh Assembly. However, the timing of both projects is incompatible with the LDP in 2015, and the Metro suggested to be done for 2025 at the earliest. This links in with our phasing argument which is detailed below.
Phasing: The first phase should be for those sites in which the infrastructure is already better placed to cope with the additional demands which are pre-dominantly in the east of the city. Following this, later phases should include those sites where considerable infrastructure has been secured and which could also link to the Metro Scheme project in future years.
We call for the total removal of Site E South of Creigiau as a strategic site. Creigiau as a village would need massive infrastructure investment to allow even this level of expansion due to the capacity of existing services such as sewerage and school. The 650 houses allocated to this site could be easily absorbed by the plan in other locations in particular Windfall Sites and better use of Brownfield Sites.
AS (D) 7 Green Belt : Delete We strongly object to the proposal to delete the Green Belt as we regard the introduction of the Green Belt as of great importance to the community. The Welsh Government’s own Planning Division claims that “other policies can be used to refuse inappropriate proposals” (Letter reference P:SDP:10:05/GL: Welsh Government dated 26 November 2013) however these policies are not as strong as Green Belt designation which would give permanent protection to an area and help to define and shape the City. The same letter envisages the Green Belt being “addressed outside of the LDP” in the proposed Strategic Development Plan for the City Region which is proposed in the draft Planning (Wales) Bill. However, it would be many years before such a Plan could come into force.
In the meantime, these green areas and open spaces, vitally important to local health of the area and the City as a whole, to the quality of life of its residents and recognised by Cardiff Council through its LDP designation as Green Belt would be at risk from development. The Green Belt was included in the DLDP after extensive public consultation which showed overwhelming support for it. The Summary of Preferred Strategy consultation findings, March 2013, shows a ‘particularly high level of support for a Green Belt in Cardiff’. In the Preferred Strategy public consultation 91.8% supported a Green Belt and within the Citizen Panel it was 82%. Public opinion expressed so strongly in a formal consultation should not be cast aside.
The Green Belt would make Cardiff a more attractive place to live and work as its inclusion in the LDP intends. Leaving land north of the M4 at risk of development is contrary to Cardiff Council’s own vision for a green backdrop to the city which is part of its distinctiveness.
This fails C1, C4 and CE2. - Deleting the green belt is inconsistent with what the City claims it wants to achieve in terms of quality of life and access to open spaces. - It is not compatible with building healthy communities. - This ignores all the evidence in favour of a green belt and defined open spaces..
11
AS (D) 8 Land at Dan-y-Garth, Pentyrch : Delete
The land at Dan y Garth, Pentyrch was not included in the LDP ~ Preferred Strategy and between the publication of the Preferred Strategy and the Deposit Plan, a planning application was made to CCC (Development Control) for the construction of 53 houses on the site. When the Deposit plan was published the site had then been included within the strategic housing allocation.
This Council has objected to the planning application, which is still under consideration and also subject to an emendation insofar as the number of houses planned has been reduced to 47. We also objected to the inclusion of the site in the Deposit LDP as it was adding additional housing to the north-west of Cardiff, which does not have the infrastructure to support any medium to large scale housing developments.
As a consequence we support the deletion of this site from the LDP and will also continue to object to the planning application.
12 PART 4: What Happens Next?
At this stage you can only make comments in writing (these are called ‘written representations’).
However, everyone who seeks a change to the Plan can appear before and speak to the Inspector at a ‘hearing session’ during the public Examination. If you are objecting to the inclusion of an alternative site you will be considered to be a supporter of the Plan and you will not be entitled to speak at a hearing.
4a) Do you want your comments to be considered by ‘written representations’ or do you want to speak at a hearing session of the Public Examination?
(Please tick one of the following)
I do not want to speak at a hearing session and am happy for my written comments to be considered by the Inspector.
I do want to speak at a hearing session. * X * A representative of the St Fagans Community Council. Please note the Inspector will attach equal weight to written representations as to those representations heard in person.
4b) If you wish to speak, please confirm which part of your representation you wish to speak to the Inspector about and why you consider it to be necessary to speak at the Hearing
We wish to speak to the Inspector about development in the NW of Cardiff with particular focus on transport infrastructure and Masterplanning.
We wish to represent the views and experiences of the 2,700 residents of St Fagans. The proposed development in NW Cardiff will have a dramatic effect on our community and we believe that local knowledge is relevant to assessing the effectiveness of the LDP.
Please note the Inspector will determine the most appropriate procedure to adopt to hear those who have indicated that they wish to attend the Examination.
13 Cardiff County Council Local Development Plan 2006 - 2026
Alternative Sites Consultation Guidance Notes
Purpose of consultation
In response to consultation on Cardiff Council’s Deposit Local Development Plan (LDP) formal comments have been received for policy boundary modifications, for new site allocations or for the deletion, modification or for a different use of sites proposed in the Plan. These are known as Alternative Sites (also termed "Site Allocation Representations”).
The Town and Country Planning (Local Development Plan) (Wales) 2005 Regulations state that Site Allocation Representations that seek to change the Deposit LDP should be advertised for a six week period. During this time, anyone can make comments about these representations and submit them to the Local Planning Authority.
The Alternative Site Representations included in the Alternative Sites Register were received during the Autumn 2013 consultation on the LDP Deposit Plan which finished on 26th November.
There are four types of Alternative Site Representation: 1. Add a new site for a specified land use to the Deposit LDP 2. Alter the boundaries of a site allocated in the Deposit LDP 3. Delete a site allocated in the Deposit LDP 4. Amend site allocation policy/change of use
The Alternative Sites Register lists each site in relation to the above criterion.
The Alternative Sites Register is available on the Council website at: www.cardiff.gov.uk/localdevelopmentplan. Hard copies are also available for public inspec- tion during the consultation period at: City Hall, Cathays Park and County Hall, Atlantic Wharf, Monday to Friday between 9.00am and 4.30pm. They will also be made available at all local libraries and at the public meetings outlined in the letter.
Important - Please note that any comments you make at this stage should relate only to the Alternative Site Representations that have already been made during the Deposit LDP. They should not propose further changes to the LDP, or suggest new sites. Any such representations will be disregarded as they should have been made during the earlier stages of plan preparation.
Please provide your full details so we can contact you regarding your representation and at future stages of the development plan.
14 Tests of Soundness:
Cardiff County Council’s Local Development Plan (LDP) will be examined by an independ- ent Inspector appointed by Welsh Government. It is the Inspector’s job to consider whether the LDP is sound. There is no legal definition of ‘sound’ but its ordinary meaning is ‘show- ing good judgement’. The questions or ‘tests’ which the Inspector will consider in deciding whether the plan is sound are in Annex 1 of this form. If you are objecting to an Alternative Site it would be helpful if you could indicate which Test of Soundness you consider it to fail. In due course representations on Alternative Sites will be submitted to the Inspector together with a position statement from the Council.
What will happen to your representation?
All representations will be made available to the public to view. A summarised list of these will be posted on Cardiff Council’s website with details of where they can be viewed.
All representations received during the consultation period will be considered at an Exam- ination in Public held by an independent Planning Inspector, who will decide on any amendments that should be made to the Deposit Plan.
It is important to note that although the Council will inform the Inspector of its views on the issues raised through this consultation, only the Inspector is able to make changes to the Plan.
Additional Assistance
If you require assistance to complete the form or have any questions relating to your representation please contact:
LDP Team, Strategic Planning – Policy Cardiff Council Room 132 City Hall Cathays Park Cardiff CF10 3ND
Telephone: 029 2087 1297 E-mail: [email protected]
15 Annex1: Tests of soundness
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 relating to the area or to adjoining areas. C2 It has regard to national strategy. C3 It has regard to the Wales Spatial Plan. C4 It has regard to the relevant community strategy/ies (and National Park Management Plan).
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 considered the relevant alternatives and/or are founded on a robust and credible evidence base. CE3 There are clear mechanisms for implementation and monitoring. CE4 It is reasonably flexible to enable it to deal with changing circumstances.
16