Housing Sites on Behalf
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FOCUSED ADDITIONAL INFORMATION IN RESPONSE TO INSPECTOR’S ISSUES AND MATTERS FOR HEARING SESSION 4 – HOUSING SITES ON BEHALF OF WELLSTRIDE LIMITED REPRESENTATION NUMBER 2630.D1, D2, D3 AND D4 SITE E70 LAND AT BEDWELLTY ROAD, ABERBARGOED 1.The following provides a summary note addressing the issues and matters raised by the Inspector and also in response to the Council’s consideration of our client’s site at Bedwellty Road, Aberbargoed within SB58. HEARING SESSION 4 – HOUSING SITES - Allocated sites objected to by other parties • Is the Council’s decision to allocate the site for housing based on a robust and rational site selection process? 2.As identified in relation to Session 2, we have concerns over the Council’s decision to allocate a significant number of sites for housing due to the lack of robust and rational information. Appendix 1 provides a schedule of sites where we have concerns/questions over the robustness, deliverability and availability of sites which are included in the LDP. • Why is the deletion of the site concerned required in order to make the Plan sound? 3.We would recommend deleting those sites that are not deliverable or available within the assumed timescales, or to provide a more realistic timescale for delivery. Leaving them as they are is unsound as there are significant concerns over their deliverability. Alternative sites put forward by other parties • Is the Council’s decision not to allocate the site for housing based on a robust and rational site selection process? 4.Our client’s site is located at Land at Bedwellty Road, Aberbargoed. (Appendix 2) The overall site was promoted as four potential land parcels for housing development at the Preferred Options and Deposit Plan stages. In response to the representations the Council reviewed our client’s sites and concluded in the Report to Council on 15th September 2009 that the sites were not suitable for housing. (SB58) Having reviewed the Council’s assessment of our client’s site we have identified a series of inaccuracies and inconsistencies in the process which we address below. 18891/BS 2 1st April 2010 Ecology 5.The Council’s assessment identifies that our client’s sites are located in close proximity to the Aberbargoed Tip and Aberbargoed Grasslands Special Area of Conservation and therefore should be discounted for development on this basis. 6.This is factually incorrect. Our client’s sites are over 500m from the SAC and separated from the SAC by the Aberbargoed Tip which is not within a SAC. Indeed the tip is identified in the existing Unitary Development Plan for re-profiling. In light of this issue, EDP have evaluated the site for it’s potential impact on the SAC (Appendix 3) and concluded that the proposals will have not any impact on the SAC. 7.The Council’s assessment refers to “important wildlife corridors and bio-diversity features” being present on the site but are not identified. Responding to this issue, EDP have evaluated the site and concluded that it is well maintained agricultural grazing land with little bio-diversity value. Any value is contained within the field boundaries comprising mature hedgerows, trees and stone walls which could retained in the development proposals. Landscape, Archaeology and Heritage 8.The Council discount the site as it “would result in encroachment into the open countryside.” No other justification is provided. In response, EDP have undertaken a Landscape Assessment (Appendix 4) which shows that development of the site would be seen within the context of the overall Aberbargoed urban area, would not be unduly prominent in the landscape and would be contained by surrounding topography. Additionally the site would have no impact on features of archaeological or heritage importance. Access Consideration – Bedwellty Relief Road 9.The sites were also discounted due to “cumulative impacts” which development of these sites would have on the surrounding road network. However the transport impact assessment for the planning permission for our client’s site to the west of Bedwellty Road allocated in the UDP as (H1(8) and which will deliver 108 dwellings showed that the local network was only at 40-60% saturation during peak periods and could support upto 300 dwellings without needing highway improvements. Accordingly there is residual capacity in the local network to support a further 200 dwellings. 18891/BS 3 1st April 2010 10.With regards to the Relief Road, if this is considered necessary the proposed development at Bedwellty Road could assist in delivering this highway improvement through appropriate and proportional S106 contributions. Alternatively if this route is no longer deemed necessary our client would be prepared to provide a contribution to suitable, necessary, and appropriate improvements to the local network or measures to encourage more sustainable modes of travel. Aberbargoed Tip Reclamation 11.The sites were also discounted by the Council, as it is suggested that they are the only location in the immediate area where spoil arisings from the Council’s desired tip re-profiling works could be deposited. However the same assessment identifies that “no firm proposals exist for the extent and detail of the reclamation works”. It is therefore unacceptable to reject our client’s site due to the potential impact it could have on an unplanned, unconfirmed project for which no funding is available. 12.The Council’s desire to re-profile the tip also illustrates the inconsistent approach taken in terms of discounting our client’s site for housing due to its proximity to the SAC, even though the tip itself adjoins the SAC. In contrast, our client’s site is separated from the SAC by the tip and is well managed and grazed agricultural land. Sewerage, Water and Drainage Overloading 14. Reference is made by the Council to the potential lack of sewerage capacity in the area, however during the development of the adjacent housing off Bedwellty Road, Aberbargoed, Welsh Water completed a hydraulic assessment of the existing sewers. The assessment report concluded that the sewers were able to support 108 dwellings without need for any works and a simple form of attenuation would allow an additional 142 properties to be developed. Any additional development could be met through upgrades to the local system provided for by the developer in association with Welsh Water’s statutory obligations. Concluison It is therefore apparent that the Council’s decision not to select this site for potential housing development was not based upon a robust and sound site selection process. We have also identified in Session 2 a range of issues regarding the deliverability and availability of the specific sites identified by the Council as well as the significant reliance upon unidentified windfalls etc. 18891/BS 4 1st April 2010 • Why is the allocation of the site concerned required in order to make the Plan sound? CONFORMITY WITH STRATEGY 15. As identified in relation to Session 2 we consider that the Plan is unsound because it relies upon a significant number of sites for housing which are not deliverable/available or are unidentified windfall sites. In addition to which the Plan does not provide for the anticipated household growth which is expected to occur within Caerphilly on the basis of the most upto date household projections by the Welsh Assembly Government. Accordingly there is a need to rectify this situation by allocating suitable, available, and deliverable alternative sites for housing in the Plan. Our client’s sites at Bedwellty Road represent such an opportunity. 16. The sites are located in close proximity to Bargoed which is a Principle Town. Given it’s status the town and environs should be a focus for significant housing and employment growth in order to support the planned expansion and regeneration of the town centre. Accordingly there is a need to identify and provide suitable sites for housing within the Bargoed area. 17. The LDP identifies that there are six sites in the Greater Bargoed Area potentially providing 816 dwellings over the plan period. However 636 dwellings are located on previously developed sites (the bulk at Aberbargoed Plateau – 413 – which the Council removed and then reinserted into the Plan). There appear to be questions over the suitability of the Aberbargoed Plateau for housing development. Additionally despite it’s status as a Principle Town the Greater Bargoed area receives only 13% of the residual housing requirements of the County to 2021. This seems contrary toit’s status as a Principal Town. 18. Additionally all of the sites, apart from one, are brownfield sites, which typically have longer lead in periods and are typically more time consuming to develop than Greenfield sites. 19. Given the above and the need to deliver development in order to support the regeneration efforts at Bargoed and to reflect its Principle Town classification in the LDP there needs to be a complementary stream of available and deliverable and suitable sites. Our client’s site fulfils this requirement. 18891/BS 5 1st April 2010 SUSTAINABILITY 20. Our client’s sites are sustainably located adjoining Aberbargoed which contains a range of local facilities including shops, schools, Dr’s Surgery, Youth and Community Centre including sports pitches, tennis courts, etc. 21. The site is within 1km of Bargoed town centre which offers, a wide range of shops, community facilities, other employment opportunities and is a focus for regeneration efforts in the Plan. Development of our client’s sites would benefit from it’s close relationship to Bargoed and would crucially introduce additional expenditure into it’s catchment area, this would assist in the ongoing regeneration of the town centre and wider area. The sites are also within 400m of existing bus services on Lewis Street which run to Bargoed town centre and the surrounding wider area.