Town & Country Planning Act 1990 Your Ref: 17/0411/OUT Proposed Development at Gwern y Domen by PMG Ltd and Persimmon Homes Ltd I of am against the proposed development for a number of reasons which are detailed below. In brief: The Caerphilly Basin has seen unprecedented growth of its population over recent years and does not have the necessary infrastructure to support further growth on the scale proposed by PMG/Persimmon. The [withdrawn] replacement Deposit LDP from which figures have been referred to in the planning application, was seriously flawed in respect of its housing need and population growth forecasts. The proposed development site is ancient Greenfield land which includes rare wildflower meadows and grasslands which support a wide range of scarce species of mammals, invertebrates and birds and is widely used by the local community for walking, riding and enjoying the natural environment. The proposed development will have a serious negative effect on the ecological integrity and biodiversity of the immediate and wider areas and result in an impoverished living environment for residents. The proposed development is outside the settlement boundary, within a Special incursion into a long established Special Landscape Area and adjacent to a Visually Important Local Landscape. It will represent the spread of the urban area beyond the well-defined physical edge of the established built-up settlement and into open countryside to the serious detriment of the distinctive visual character, quality and sense of our rural surroundings. It represents a linear extension to an existing settlement which is not acceptable in planning terms nor in accordance with Planning Policy Wales. There is no local need for development on this scale in the Caerphilly basin. According to Caerphilly County Borough Council (CCBC) there were 486 empty properties in the Caerphilly basin on 4th November 2015. On 29th May 2017, the number of empty properties in the Caerphilly basin was 555. This represents an increase in empty properties in the Caerphilly basin over an 18 month period of 14% and does not indicate acute housing pressure nor does it indicate considerable housing need. The evidence clearly suggests there is no need for additional housing of the proposed nature in the Caerphilly basin other than for the developers needs to satisfy their shareholders. The proposed development will have an adverse impact on the setting of local historic monuments including Gwern y Domen Castle Mound, Van Mansion and its Historic Park and Caerphilly Castle as previously advised by Cadw. The current infrastructure is not sufficient to manage the existing demand. The proposed development will result in an unacceptable level of additional traffic to the strategic highway network of the Caerphilly Basin which currently operates at over-capacity during peak periods, thereby aggravating existing congestion problems. The proposed development will increase pollution within our community through greater trips particularly by car with serious consequences for our children and future generations. It doesn t help to promote sustainable modes of transport, and compact settlement patterns 1 P a g e
that are intended to help avoid sprawl and support a more sustainable, resource efficient and less polluting built environment going forward. There are sufficient sites already with the benefit of planning permission to enable the Caerphilly basin area to meet its predicted housing needs well beyond 2031. 1. The proposal specifically fails to meet the following LDP aims and objectives: a) Accommodate sustainable levels of population growth. b) Ensure that the County Borough is well served by accessible public open space and accessible natural green space. c) Ensure the effective and efficient use of natural and built resources while preventing the unnecessary sterilisation of finite resources through inappropriate development. d) Ensure that the environmental impact of all new development is minimised. e) Encourage the re-use and / or reclamation of appropriate brownfield and contaminated land and prevent the incidence of further contamination and dereliction. f) Concentrate new development in appropriate locations along existing and proposed infrastructure networks that are accessible to pedestrians, cyclists and to public transport in order to sustain and complement the role and function of individual settlements. g) Identify, protect and, where appropriate enhance, valuable landscapes and landscape features and protect them from unacceptable development. h) Reduce congestion by minimising the need to travel, promoting more sustainable modes of transport and making the most efficient use of existing transport infrastructure. i) Protect and enhance the overall quality of the historic natural and built environment of the County Borough. 2 The development fails to support the following LDP policies. SP3: A, B, C, D & E including paragraphs 1.60 & 1.61 SP5: A, B, C & D SP10: paragraphs 1.72 & 1.73 CW1: A CW2: A, B, C & D CW4: A & B CW6: A, C & D including paragraph 2.15 CW15: C development outside settlement boundaries is NOT permitted 3. With regard to the Southern Connections Corridor the proposed development does not meet with the following key points. 1.15 a large part of the area has been shown to be highly valued and sensitive environmentally and as a consequence 76% of the surrounding countryside is subject to environmental protection 1.16 the Plan seeks to consolidate development with existing settlement boundaries Development to be directed to parts of the County Borough that have the environmental capacity to accommodate it without causing undue harm to areas that are valued for their intrinsic value in terms of biodiversity, landscape, historic or conservation interest. 2 P a g e
1.29 - The Strategy promotes a more balanced approach to managing future housing and employment growth significant development opportunities on brownfield and greenfield sites are proposed for principal towns and local centres in the Northern Connections Corridor (NCC) and the Heads of the Valleys Regeneration Area (HOVRA) in order to spread prosperity throughout the County Borough. 1.33 - the Southern Connections Corridor is particularly well provided for in terms of large brownfield sites and the Plan aims to balance the need to redevelop these brownfield sites against the need to ensure that growth is managed across the whole of the County Borough in order to promote regeneration in the more deprived areas, where fewer significant brownfield opportunities exist. 1.35 settlement boundaries 1.42 promotion of higher density development along rail corridors 1.46 promotion of alternative modes of transport to the car 1.52 & 1.56 4. The proposed development specifically fails to address the following PPW areas. 1.1.6 site location, within the context of the authority s Single Integrated Plan 2.1.8 the development of the site prejudices the quality of life of the existing community (618 houses represents a significant extension of more than 35% to the existing community). 2.2.2 the choice of site does not represent a clear focus on planning for places; it wilfully ignores several key characteristics of the existing settlement and landscape, for the sole purpose of delivering a damaging and wholly unnecessary project. 2.2.3 There are real and sustainable alternatives that will enable better outcomes and with much less harm to the natural heritage and quality of life for existing residents. 2.3.1 the choice of site fails to provide for truly sustainable development, as there is sufficient scope to provide alternatives on previously developed land, or reduce the housing allocation to reflect the Policy Unit Wales predicted need for 5,700 homes in the borough (which equates to around 2,240 homes for the Caerphilly basin up until 2031). 2.3.4 the chosen site was subject to a sustainability appraisal as a candidate site for the withdrawn LDP which demonstrates that in planning terms it is one of the least favourable sites for development as considered by the LPA assessment. 2.3.7 development of this site would represent a failure to recognise the impacts of such large scale urban expansion on residents who choose to live in an area because of readily identifiable positive characteristics that have otherwise been overlooked the area is rural/ semi-rural as opposed to sub-urban and as such should be treated accordingly in planning terms. 3 P a g e
4.1.4 the chosen site fails to deliver on the seven well-being goals 4.1.6 the chosen site and its associated impacts will not deliver a sustainable development as defined in PPW 4.3.1 the gross over development of this area of Caerphilly is in direct conflict with the sustainable development principle 4.4.3 the proposed scheme does not promote resilient settlement patterns that minimise land-take and urban sprawl/ it helps produce irreversible harmful effects on the natural environment/ it fails to protect people s health & well being and equality of opportunity/ it will encourage the demand for travel, and does not outwardly promote low and zero carbon developments. 4.5.1 the chosen site, by virtue of its location, is highly unlikely to realise any meaningful changes in resident behaviour and contribute to a reduction in carbon emissions. 4.5.2 the chosen site perpetuates a model of urban sprawl, instead of utilising readily available brown-field sites to achieve a compact and sustainable urban form that can actively contribute to real reductions in CO2 emissions going forward. 4.5.5 & 4.5.7 the chosen site fails to actively address the causes of climate change as it promotes further increases in car use over the plan period. 4.5.11 the chosen site will not help reduce the ecological footprint of residents living in the new houses (too far to walk to town, work etc) 4.6.4 & 4.6.5 the chosen site fails to conserve the countryside, and the arguments for releasing green field land in the Caerphilly basin are not sound. There is sufficient brownfield land to accommodate the plan objectives, without resort to any loss of countryside at the present time. 4.7.2 the proposal fails to secure a sustainable settlement pattern that protects local character and cultural identity of the resident community/ it fails to encourage higher density development close to public transport corridors/ fails to foster an approach that recognises the mutual dependence between town and country 4.7.4 the proposal, by the nature and location of the site, fails to accommodate an increase in travel by modes other than the private car 4.7.8 The proposal is hardly a minor extension and would certainly not be of an appropriate scale and design that respects the character of existing settlement. 4.11.1 & 4.11.2 the elevation and conspicuous presence of the proposals within the landscape are such that no amount of design will mitigate the loss of a valuable natural heritage asset. 4 P a g e
5.1.1 the development of this area of open countryside would adversely affect the social well being of individuals and the existing community 5.1.3 the choice of site does not represent careful planning 5.2.9 & 5.2.10 the location of the development would have detrimental consequences on areas of ancient woodland due to the close proximity of houses to large stands of trees, and the removal of adjacent open land which might otherwise be used to enlarge the size of these important carbon sinks. 5.3.11 the extent of development does not constitute acceptable development within the SLA which would ordinarily be rural in character so as to maintain the overall appearance of the SLA. The extent of development into the SLA undermines the validity of the original assessments, and misinterprets the spirit of this particular PPW policy. 5.4.1 the proposed development of this site fails to appreciate the benefit these sites currently provide to local communities. 5.5.15 the site contains several areas classified as ancient woodland 7.2.4 Caerphilly town centre is very well placed to accommodate a significant regeneration initiative that includes a range of mixed use development opportunities which could better meet the areas needs for smaller properties. 7.4.1 ditto. The co-location of business, retail and leisure within the town centre would be a tremendous boost to the local economy. 9.1.1 the proposed development would not ensure that previously developed land is being used in preference to green-field sites 9.1.2 the nature and extent of the proposed development, fails to avoid large housing areas of monotonous character 9.2.3 the over development of housing land versus projected need during this plan period, may well prejudice a long term and sustainable land supply that best serves the needs of the local community whilst preserving the natural environment. 9.2.5 the fact that a house builder has bought land speculatively does not predetermine the suitability of the particular site for development, regardless of whether or not it can be delivered. 9.2.10 the recent candidate site assessments for sites within the Caerphilly basin clearly demonstrate that this greenfield site was one of the least favourable for development, and it has been promoted in advance of local authority owned, previously developed land which should be considered before greenfield. Signed print name date 5 P a g e