Gwern y Domen Conservation Group

Transcription

1 Gwern y Domen Conservation Group PO Box 88 Caerphilly CF83 2ZW Head of Regeneration and Planning Caerphilly County Borough Council Tredomen House, Tredomen Park Ystrad Mynach CF82 7WF Your Ref: 17/0411/OUT 5 th June 2017 Dear Sir Town & Country Planning Act 1990 Proposed at Gwern y Domen by PMG Ltd and Persimmon Homes Ltd Gwern y Domen Conservation Group (GDCG) is a formally constituted community group currently awaiting confirmation of Charitable Status. It was established to protect, promote and preserve the natural environment in the area around the Gwern Y Domen hillside and farm for the benefit and amenity of present and future generations of local residents of Rudry, Porset, Badgers Wood, Mornington Meadows, Porset Park, Lansbury Park, Castle Park, the Van and the wider community of the Caerphilly Basin and the borough of Caerphilly. GDCG has over 500 members, various working committees and over 3,000 supporters. Our Patron is Iolo Williams, broadcaster, wildlife presenter and renowned naturalist. GDCG is against the proposed development for a number of reasons which are detailed below. In brief: 1. 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 The [withdrawn] replacement Deposit LDP from which figures have been referred to in the planning application, was seriously flawed in respect of its housing need and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. 2. 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. Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 1

2 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. 3. The proposed development is outside the settlement boundary, within a 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. 4. 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 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 or considerable housing need. The evidence clearly suggests there is no need for additional housing of the proposed nature in the Caerphilly Basin other than the need of the developers to generate profit for their shareholders. 5. 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. 6. 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. 7. The proposed development will increase pollution within our community through greater trips particularly by car with serious consequences for our children and future generations. 8. The Local Authority are currently looking at a strategic development plan in conjunction other local authorities with a wider more strategic view of South East Wales therefore this application is premature and may have a detrimental consequence and frustrate any future plans. Housing Requirement [local] Needs Assertions that the local plan has failed appear to hinge on the matter of housing land supply and the success of some previous appeals which, having used similar arguments, have led to the granting of permission for development outside established settlement boundaries. Whilst an argument may hold true for the borough as a whole it fails to acknowledge the fact that the Caerphilly Basin, forming by far the largest part of the Southern Connections Corridor (previously identified as an Area of Consolidation), is thus far on target to deliver the number of new homes identified in the 2010 LDP for this particular area. It is worth noting, in respect of the existing LDP, the Inspector s report on the EiP (6/10/10), where it was concluded the plan was sound. Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 2

3 The inspector stated that: (para 3.3) the SCC is under considerable pressure for development and has limited capacity for such without causing environmental harm. The existing Plan sought to consolidate and focus new development in the SCC within existing settlement limits, relying almost entirely on brownfield sites. I believe this can still be achieved; (para 3.6) the overall nature and direction of the Plan strategy is sound and well-founded in terms of its relationship to, and consistency with, national policy and the Wales Spatial Plan (WSP); (para 5.4) the evidence of recent years justifies the Council s confidence that brownfield sites will continue to come forward for housing development even where there are constraints. I find no evidence to contradict the Council s point that the current cases of developers showing reluctance to progress permitted brownfield development schemes is essentially due to the present economic downturn rather than any intrinsic underlying development viability issues, the recent accounts of the national developers and their exceptional profits attests to that concern; (para 5.5).directing development to brownfield land before looking to greenfield sites Is an important element of the Plan s wider focus on sustainable development and environmental protection and enhancement A thorough examination of the LDP allocated sites and subsequent additional sites benefitting from permission shows that the Caerphilly Basin has delivered 45% of the original allocation since 2010, with approximately 40% of the identified sites remaining for development. The remaining 15% shortfall for the area will be adequately covered by the delivery of 333 homes on the former Catnic Site (application submitted) and land at Abertridwr Road which recently received consent for a further 34 homes. The existing and previous local development plans have acknowledged the requirement for a balanced approach to housing delivery across Caerphilly borough as a whole, and the need to protect countryside and Special Landscape areas to the south of the borough, being most at risk from speculative development due to the proximity of settlements to Cardiff and Newport, has been repeatedly accepted as a sound planning position at examination. In addition to the above it can be demonstrated that the natural growth of the Caerphilly Basin population using Stats Wales projections to 2021 would require significantly less homes than the 2,542 authority target over the same period. It is clear that the LDP targets include a margin for error and allowance for market fluctuations with an allocation that accommodates additional growth over and above natural population changes, and the delivery of any homes over and above the need required to sustain natural growth is in direct conflict with the aims of the Future Generations Act (Wales). The argument for development in this area as a means of addressing a county wide housing delivery target is, therefore, an overly simplistic approach to justify the unnecessary loss of a highly valued local landscape. In addition to the above, in accordance with Planning Policy Wales, the Caerphilly Basin has a considerable amount of previously developed land (brownfield) within the settlement boundary and which must be considered by the LPA before any Greenfield land is released. Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 3

4 We note that Asbri Planning, the agents acting for the developers have previously represented objectors to the Bedwas Colliery allocation and challenged the validity of other brownfield sites in contributing to the local Joint Housing Land Availability Studies and all prior to bringing forward this current proposal. During a recent consultation regarding the proposed replacement Local Plan for Caerphilly representations were made against the release of Greenfield sites within the Caerphilly Basin at the present time, simply due to the fact that the LDP candidate sites process identified Brownfield sites for up to 2,700 houses in addition to the 1,600 homes on previously allocated sites in the area. The figures represent a potential housing land supply of nearly 4,300 homes; which equates to approximately double the number of homes required as being necessary to satisfy demands for growth to 2031 as identified by the Public Policy Institute for Wales (PPIW) figures published in September In addition to this, and in accordance with Planning Policy Wales 9.2.6, sites for a further 800 homes might be possible a possible total of 5,100 units without the need for developing Greenfield sites. Planning Policy Wales states that In contributing to the Well-being of Future Generations Act goals, planning policies, decisions and proposals should Promote resource-efficient and climate change resilient settlement patterns that minimise land-take (and especially extensions to the area of impermeable surfaces) and urban sprawl, especially through preference for the re-use of suitable previously developed land and buildings, wherever possible avoiding development on Greenfield sites (Sections 4.7, 4.8 and 4.9). On the basis that sufficient Brownfield land has been identified for housing allocated sites as part of the LPA candidate site assessment process, and that the release of any Greenfield land within the Caerphilly Basin is presently unnecessary and wholly incompatible with the core objectives of Planning Policy Wales this application should be seen for what it is; developer profitability not community benefit. Welsh Government expressed serious concerns as to the soundness of the withdrawn replacement LDP growth strategy and its divergence from the PPIW predicted population growth between 2015 and Using TAN 1 housing land supply formula Caerphilly Basin has a more realistic 10 year housing land supply (based on un-built sites already benefitting from planning permission). PPIW published a report by [the late] Alan E. Holmans, CBE in September 2015 entitled Future Need and Demand for Housing in Wales. Alan Holmans was acknowledged as the UK s preeminent expert in projecting future housing need and demand. His report concludes [on page 37] that Caerphilly Borough will only need 5,700 houses ( ). Therefore, Caerphilly Basin, being 32% of the borough population, gives rise to a need for approx. 1,824 homes over the same period. 1. The existing LDP targeted 2,542 homes in the Basin area until year 2021, of which 1,138 were built up to year The un-built houses from the 2010 LDP target (1,155 homes) from the extrapolated PPIW figure of 1,824 leaves a shortfall of 669 units required until year Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 4

5 3. By adding all the above together the result is a total housing requirement from years of 3,211 units, incorporating the current LDP targets and PPIW predicted future growth. 4. There are presently sites in the area with planning permission for up to 1,665 homes. In summary: A LDP Target 2,542 B Total houses built to ,138 C Remaining target to 2021 A-B 1,155 D Units req (PPIW) PPIW 1,824 = 91 dpa E Units req D-C 669 = 67 dpa F Total req A+E 3,211 G Revised annual build rate F/ 21y period 162 = 153 dpa H Allocations with benefit of planning 1,665 It is clear from this brief analysis that the actual number of houses required to satisfy the PPIW growth predictions to 2031 are already in the system and have the benefit of planning permission. LDP targets / growth aspirations do not represent a balanced and sustainable approach to town planning and that in the absence of a plan going forward the predicted growth figures should be a more realistic benchmark, thereby demonstrating that there is currently a 10 year land supply for this particular geographic area. There is a real danger that short-sighted responses from councils to current economic conditions could undermine urban regeneration schemes in the future. Please also note the following from PPW, which provide valid reasons as to why the application for the above site should be rejected. Section Preference for the re-use of land (up to 5,100 units in the Caerphilly Basin). Section The Welsh Government will seek to ensure that previously developed land is used in preference to greenfield sites Section Local planning authorities should address the scope and potential for rehabilitation, conversion, clearance and redevelopment when considering suitable sites for housing development. Maximising the use of suitable previously developed land for housing development can assist regeneration and at the same time relieve pressure for development on Greenfield sites. In particular, local authorities should consider the contribution to the overall provision of land for housing that can be made by reclaimable or reclaimed urban land and by disused or underused buildings. Sites which are no longer likely to be needed for office or industrial purposes may also be appropriate locations for housing. Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 5

6 In identifying sites to be allocated for housing in development plans, local planning authorities should follow a search sequence, starting with the re-use of previously developed land and buildings within settlements, then settlement extensions and then new development around settlements with good public transport links In determining the order in which sites identified in accordance with paragraph above should be allocated, the presumption will be that previously developed sites or buildings for re-use or conversion should be allocated before greenfield sites. In addition to the above and according to Caerphilly County Borough Council there were 486 empty properties in the Caerphilly Basin on 4th November 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 and considerable housing need. The evidence clearly suggests there is no need for additional housing of the proposed nature in the Caerphilly Basin other than the developers needs to satisfy their shareholders. Settlement Boundaries The 1983 Caerphilly Basin Local Plan (CBLP) adopted by the Rhymney Valley District Council resolved that growth be contained wherever possible within the existing urban fabric and that the retention of individual settlements be maintained. It stated there will be a presumption against development outside the settlement limits unless it is in the interest of agriculture, forestry or outdoor recreation. The CBLP also noted that the Van area, to the east of Caerphilly is considered by many to the one of the most attractive areas of countryside in the Valley mouth. The Strategy for the Southern Connection Corridor of the current adopted LDP ( ) is to consolidate development within existing settlement boundaries to Reduce the impact of development upon the countryside. A key part of the Strategy is to promote resource efficient patterns of development across the whole of the County Borough; not just in the Caerphilly Basin. As stated in the LDP, a strategy which relies solely on the south of the County Borough for economic progress is unsustainable in the long term. The settlement boundary performs a number of important strategic functions, namely: it defines the area within which development would normally be allowed, taking into account all other material considerations it promotes the full and effective use of urban land and thus concentrates development within settlements it prevents the coalescence of settlements, ribbon development and fragmented development it prevents inappropriate development in the countryside Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 6

7 The LDP states that the settlement boundary ensures that vulnerable land uses such as open space, leisure land and community uses have sufficient protection to avoid their loss to more profitable development such as housing. The Strategy in the SCC promotes sustainable development that uses previously developed land within settlement limits and protects the natural heritage from inappropriate forms of development. While the planning application states there is no record of planning consent for residential development being refused (Pre-Application Consultation Report Page 29 (h)) and that planning consent was granted in 1991 for a change of use from agriculture to a golf course (which is somewhat different to a large scale housing development), it fails to note a rejection of the land for inclusion as a candidate site for development of 600+ houses in The existing settlement boundary is defined by the Mornington Meadows Van Road Distributer Road, which in September 2009 (Deposit Local Plan up to 2021: Council consideration of Representations Part 2, Volume 4 of 6) stated, in respect of Gwern y Domen land submitted for housing development (E286 and HG99.22) that The Inspector found no justification for inclusion of the land as housing. The Inspector considered that development within the sectors identified by the Objector would 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 character and appearance of these rural surroundings. (paragraph ). In further rejecting the same site for leisure allocation (E286 and LE99.29), the Council stated, in respect of the site being an SLA, that The upland and lowland character of the area together with the plantations and rights of way network provide an important recreational feature in the area. It also forms the visual context and setting for the historic town of Caerphilly. The site contains a number of important habitats and its topography reflects the underlying geology of being on the southern boundary of the coalfield valleys. The Council further stated that Inclusion of candidate site E286 was ruled out at the preferred strategy stage as a result of its unacceptable encroachment into the countryside and other ecology and landscape restraints. And, the site forms part of a larger network of countryside links, including links with Rudry common to the east, Wern Duu woodlands and Caerphilly Mountain to the south and east and Bedwas and Machen to the north. The site should therefore be protected, in its entirety, for its important open countryside character and its role within the immediate and wider landscape setting. Traffic/Highways The 1983 Caerphilly Basin Local Plan adopted by the Rhymney Valley District Council noted that the Van area, to the east of Caerphilly is considered by many to the one of the most attractive areas of countryside in the Valley mouth. Access to the area could be gained via the Mornington Meadows peripheral road but it is considered that this would cause serious problems of traffic congestion in the town centre. Accordingly, the council s preferred option was to develop to the west of Caerphilly (Cwm Farm/Cwrt Rawlin). Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 7

8 The development of Gwern y Domen would overwhelm the road infrastructure because of the large scale increase in local traffic. The 2011 census showed that in the St James ward 33% of households had no vehicle, 37.8% had one vehicle, 21.5% had two vehicles and 7.6% had three or more vehicles. Applying that same criteria to the proposed development of 618 households, then 234 households would have one vehicle; 132 households would have two vehicles and 46 households would have at least three vehicles. Even assuming that 203 households on the proposed development would have no vehicle (which considering the style of housing proposed is unlikely) then there would be at least an additional 636 vehicles joining the Mornington Meadows distributer road; a 24% increase in traffic flow within St James ward. Statistical data (Statistics on Commuting in Wales, 2010) suggests that 80% of residents in the proposed development who are employed will use their vehicle to travel to work thus feeding into the already congested Mornington Meadows Van Road distributer road. Van distributer road, morning queue heading North to Bedwas Road. CCBC has acknowledged the traffic problems in the area. In considering a planning application on 11th June 2014 in respect of a single barn conversion at Gwern y Domen Farm (Application No. 13/0875/COU), the planning committee noted that this single property development will add additional traffic to the strategic highway network of the Caerphilly Basin, which currently operates at capacity during peak periods, thereby aggravating existing congestion problems. If a single dwelling caused such alarm 3 years ago and there is no immediate plan or capacity to relieve the distributer road in the near future, then an additional 636 vehicles [at least] will have a catastrophic effect on the highway network. Natural Heritage Section 40(1)) of the Natural Environment and Rural Communities Act 2006 (NERC) places a duty on every public authority, in exercising its functions, to have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity". Biodiversity conservation and enhancement is an integral part of planning for sustainable development. The planning system has an important part to play in nature conservation (PPW paragraph 5.2.7). Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 8

9 The use and development of land can pose threats to the conservation of natural features and wildlife. Past changes have contributed to the loss of integrity of habitat networks through landtake, fragmentation, severance, disturbance, hydrological changes and other adverse impacts. Section 11 of the Countryside Act 1968 requires all public bodies (including LPAs), in the exercise of their functions relating to land, to have regard to the desirability of conserving the natural beauty and amenity of the countryside. Section 49(4) of that Act provides that references in the Act to the conservation of natural beauty are to be construed as including reference to the conservation of its flora, fauna and geological and physiographical features. Section 28G of the Wildlife and Countryside Act 1981 places a duty on public authorities (including LPAs), in exercising their functions so far as this is likely to affect the flora, fauna or geological or physiographical features by reason of which a SSSI is of special interest, to take reasonable steps, consistent with the proper exercise of their functions, to further the conservation and enhancement of those features. on Gwern y Domen will be an intrusion into open countryside, representing a linear offshoot of development from the settlement into a Special Landscape Area (SLA) (NH1.5) and impacting on a long established Green Wedge and Site of Importance for Nature Conservation (SINC) with mineral safeguarding and areas considered Best and Most Versatile (BMV) land for agriculture (Approximately 6.77 hectares of the site are subgrade 3a BMV located in the south eastern corner of the site). This site should not be considered for development as it is defined as outside of the settlement. Although the site is not within a green wedge, a Green Wedge currently exists between the site and the existing settlement and, therefore, would be contrary to national planning policy on development in the countryside. Currently the land is a mix of pastoral farmland and lowland wildflower meadows on the lower and gentle slopes with woodland dominating the higher areas. Scattered rural buildings and farms are the primary settlement pattern. The area comprises a sandstone ridge with scarp slope across a dissected plain of Old Devonian Red Sandstone and carboniferous limestone ridge. The landscape is a complex, multi-period landscape containing evidence of prehistoric, Roman, medieval and post-medieval occupation that has remained relatively unchanged, with little evidence of intrusion by 19 th /20 th century industrial or residential development with protected archaeological sites within or adjacent to the proposed development area. The first principle of Caerphilly Delivers : Sustainable development where we promote social justice and equality of opportunity and enhance the natural and cultural environment and respect its limits. Setting unrealistic population growth, especially in the Caerphilly Basin, will not enhance but degenerate the natural environment beyond its limits. The existing and previous local development plans have acknowledged the requirement for a balanced approach to housing delivery across Caerphilly borough as a whole and the need to protect countryside and Special Landscape Areas to the south of the borough, being most at risk from speculative development due to the proximity of settlements to Cardiff and Newport, has been repeatedly accepted as a sound planning position at examination. Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 9

10 Planning Policy Wales excerpts: in the countryside should be located within and adjoining those settlements where it can be best accommodated in terms of infrastructure, access and habitat and landscape conservation. Infilling or minor extensions to existing settlements may be acceptable, in particular where it meets a local need for affordable housing, but new building in the open countryside away from existing settlements or areas allocated for development in development plans must continue to be strictly controlled. All new development should respect the character of the surrounding area and should be of appropriate scale and design. Among the objectives of the current adopted LDP ( ) are: Ensure that the County Borough is well served by accessible public open space and accessible natural green space Identify, protect and, where appropriate, enhance valuable landscapes and landscape features and protect them from unacceptable development Identify, protect and enhance Sites of Nature Conservation and earth science interest and ensure the biodiversity of the County Borough is enhanced Siting a large housing development of 618 properties in open countryside next to a SINC and rare habitats is contrary to those objectives. Well-being of Future Generations (Wales) Act In contributing to the Well-being of Future Generations Act goals, planning policies, decisions and proposals should: Promote resource-efficient and climate change resilient settlement patterns that minimise land-take (and especially extensions to the area of impermeable surfaces) and urban sprawl, especially through preference for the re-use of suitable previously developed land and buildings, wherever possible avoiding development on greenfield sites wherever possible (Sections 4.7, 4.8 and 4.9). Contribute to the protection and improvement to the environment so as to improve the quality of life, and protect local and global ecosystems. In particular, planning should seek to ensure that development does not produce irreversible harmful effects on the natural environment and support measures that allow the natural heritage to adapt to the effects of climate change. The conservation and enhancement of statutorily designated areas and of the countryside and undeveloped coast; the conservation of biodiversity, habitats, and landscapes; the conservation of the best and most versatile agricultural land; and enhancement of the urban environment all need to be promoted (4.10, , Chapters 5 and 13). Contribute to the protection and, where possible, the improvement of people s health and wellbeing as a core component of achieving the well-being goals and responding to climate change. Consideration of the possible impacts of developments positive and/or negative on people s health at an early stage will help to clarify the relevance of health and the extent to which it needs to be taken into account (Sections 4.7, 8.1, 11.1 and Chapter 12). Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 10

11 Locate developments so as to minimise the demand for travel, especially by private car (Section 4.7 and Chapter 8). Support the need to tackle the causes of climate change by moving towards a low carbon economy. This includes facilitating development that reduces emissions of greenhouse gases in a sustainable manner, provides for renewable and low carbon energy sources at all scales and facilitates low and zero carbon developments (Sections 4.7, 4.11 and Chapter 12). A site assessment (in Caerphilly planning team s own words) rejecting Rudry sites where this development would coalesce, The site [for only 60 houses] represents a very significant expansion to the village, increasing the size of the village by over 50%. Such a large-scale development will place significant pressure on the existing highway infrastructure, which is substandard due to its narrow carriageway widths, limited forward visibility and a complete lack of pedestrian provision. In considering a planning application on 11th June 2014 in respect of a single barn conversion at Gwern y Domen Farm (Application No. 13/0875/COU), the planning committee noted that this single property development will add additional traffic to the strategic highway network of the Caerphilly Basin, which currently operates at capacity during peak periods, thereby aggravating existing congestion problems. If a single dwelling can cause such alarm 2 years ago and there is no deliverable short term plan or capacity to relieve the distributer road in the near future, what effect will an additional 600 plus residents vehicles have on roads already operating at capacity during peak periods? From Healthier Caerphilly : The Plan will provide a policy framework for the protection and enhancement of recreation and leisure facilities to ensure they are accessible to all. Building 600 plus houses on Greenfield land in Caerphilly Basin will deprive the community in most need of healthy active lives of these facilities. Therefore this application to build 600 plus houses on Gwern y Domen is contrary to the Statutory guidance on the Well-being of Future Generations (Wales) Act 2015 which points out Public bodies must consider all seven of the well-being goals.. It is important to understand that this is not about balancing impacts; it is about working towards win-win solutions and identifying the multiple benefits. Similarly, it advises that if an impact assessment is required then this should be integrated to ensure steps you are going to take do not conflict with one another and therefore limit the achievement of your objectives. The charity Land Trust has published a report which highlights the important functions and the hidden value of natural green areas. It argued woodlands absorb pollution and lock up carbon, and wetlands store water which reduces the risk of flooding. Through a natural capital accounting approach, the Land Trust was able to translate these benefits into financial terms. Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 11

12 The study entitled The Hidden Value of Our Green Spaces said these functions helped reduce costs for communities and public sector services, such as to the NHS. Contribute to economic prosperity by helping alleviate costs to businesses and the public purse Support and enhance the services provided for free by the natural environment Give people a place to improve their own health and wellbeing Offer people educational opportunities and encourage community cohesion and reduces social isolation. Habitat The marshy grassland habitats, hedgerow trees and woodlands provide valuable stepping stones, foraging and wildlife corridors for a number of UK protected species including reptiles, breeding birds, invertebrates, dormice, great crested newts, bats and a plethora of unique and rare waxcap fungi (including ballerina, scarlet, golden, slimy red, snowy to name but a few found all confirmed and having been recorded and grid referenced on the site). Gwern y Domen s traditional Welsh hay meadow is species rich in biodiversity, the most environmentally beneficial of Wales agricultural land. It is well documented that wildflower meadows are in steep decline and now extremely rare tragically having lost over 99% in the last 30 years; therefore we cannot afford any further loss or erosion of such rare and valuable ancient land to development when it is clearly unnecessary. Summary Extracts from Ecological Reports regarding Gwern y Domen. NB. The following reports were submitted to CCBC Planning Department on 13 th October 2015 attached for ease of reference. Report 1. (Brenin Associates (Ecological Consultants) Ltd March 2015 Report No. C010/001/V1) The desk study revealed anecdotal evidence of two species protected by European legislation: Dormice and Great Crested Newts. A consultant s report from 2013 provided evidence of bat roosts which would be entirely surrounded by the proposed development. The survey revealed that the site contained a substantial network of hedgerow, scrub and woodland edge habitats, which are likely to be of considerable value to nature conservation. The presence of Dormice was confirmed during the survey, by the findings of characteristicallychewed hazel nuts. The proposals are likely to result in a direct loss of very extensive areas of mature trees over pasture, hedgerows, scrub and ruderal herbs, which are considered to be of potentially high value to nature conservation and biodiversity. This may result in significant losses of habitat for a number of protected and / or priority species, and diverse assemblages of species. Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 12

13 There is also the potential for indirect impacts to occur. Many species that use the site (including Brown long-eared bats, and Barn Owls) are likely to be sensitive to light pollution. There is the potential for development to pollute the wet areas and pond used by great crested newts. Any retained reptile and breeding bird populations could be devastated by an increase in pet cats (should there be an increase in housing). The desk study revealed records of the following birds that are protected under Section 1 of the Wildlife and countryside Act from within a 2km radius: barn owl (Tyto alba) kingfisher (Alcedo atthis) red kite (Milvus milvus) peregrine (Falco peregrinus) The desk study also revealed records of the following bird species of conservation concern within the search area (see Appendix 1 for a definition of this term): dunnock (Prunella modularis) bullfinch (Pyrrhula pyrrhula) starling (Sturnus vulgaris) song thrush (Turdus philomelos) lapwing (Vanellus vanellus) grey partridge (Perdix perdix) merlin (Falco columbarius) curlew (Numenius arquata) snipe (Gallinago gallinago) cuckoo (Cuculus canorus) nightjar (Caprimulgus europeaus) Report 2. (Brenin Associates (Ecological Consultants) Ltd September 2015 Report No. C010/002/V2) Brown long-eared bat roost at Gwern y Domen: This study found that there is a likely brown longeared bat maternity roost at Gwern y Domen which supported at least 31 individuals at one time. The survey data indicates that more bats are likely to have been roosting within the building, given that more bats were found emerging from a distinctively different area. To the west of the site are dense hedgerows and sheltered field edges, connecting the parkland habitat adjacent to Coed-y-Mardy woodland, and it is likely that these areas are of significant value to the bats at Gwern y Domen. 64% of the brown long-eared bats roosting at Gwern y Domen flew westwards upon leaving the roost. Bats were also seen flying north towards more dense hedgerows within the site and the Caerphilly and Machen disused railway (an area of scrub and woodland). A number of the bats were also seen flying northeast along the access road to Gwern y Domen Farm. The road edged with dense hedgerows is also likely to be of considerable value to the population present at the roost. Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 13

14 Brown long-eared bats are well documented for foraging close to roost sites (Swift, 1998). They have been found to spend 92% of their foraging time within 1.5km of the roost and significantly more of their time within 0.5km of the roost than further away (Entwistle et al., 1996). The report discusses in detail, the likely value of the areas of habitats within critical zones for the species. Since this roost is located at the centre of the proposals and will be completely surrounded by high-density housing and light pollution, there are likely to be significant adverse impacts of the proposals on the maternity roost. Given this species' known sensitivity to lighting, the proposals put into question the long-term survival of this population. According to the Wales Biodiversity Partnership (2008), significant roosting sites including vital flight and commuting routes and important feeding areas attached to roosts will be selected for designation as SINC sites. There are two maternity roosts at Gwern y Domen of two Priority or Section 42 species of bats, which are therefore considered as being 'significant'. Brown Long-eared bats are highly dependent upon habitats found within 0.5km of the roosting site (Entwistle et al., 1996). Whilst data from the transect surveys cannot be referred to at the current time, it is safe to assume that there are vitally important commuting and feeding sites within 0.5km of the roost site, which is where development is proposed. The direction which bats were recorded leaving the roost site provides us with an insight into how they are using the site. Records of the following bat species were found within 1 km of the site, according to the data results returned from South East Wales Biodiversity Records Centre (Celtic Ecology, 2014): Daubentons (Myotis daubentonii) Whiskered (Myotis mystacinus I brandtii) Myotis spp. Natterers (Myotis nattereri) Noctule (Nyctalus noctula) Narthusius's pipistrelle (Pipistrellus nathusii) Common pipistrelle (Pipistrellus pipistrellus) Soprano pipistrelle (Pipistrellus pygmaeus) Brown long-eared (Plecotus auritus) Greater horseshoe bat (Rhinolophus ferrumequinum) Lesser horseshoe bat (Rhinolophus hipposideros) It is recommended that the roosting sites at Gwern y Domen be proposed as a SINC. The habitats within 0.5km of the roost site which connect the woodland sites should also be designated, since they are likely to comprise vital commuting I flight lines and foraging habitat. Since Brown Longeared bats are sensitive to light pollution, it is also recommended that the grassland habitats be included. The designation would connect the roosts to the SING sites at Goed-y-Mardy and Caerphilly and Machen disused railway via important habitat linkages. This would serve to maintain the integrity of each SING by means of preventing habitat fragmentation on a landscape level; a phenomenon which is known to impact upon mammal populations such as bats and dormice (which are also known to be present locally). Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 14

15 Report 3. (Brenin Associates (Ecological Consultants) Ltd October 2015 Report No. C010/003/V1) The site is considered to be of significant value to nature conservation such that it should be put forward as a SINC site, or at the very least, be protected from development. The following summarises the proposed reasons for its designation: Primary reasons for designation: 1. Maternity roost of brown long-eared bats 2. Maternity roost of common pipistrelle bats 3. Vital flight and commuting routes for the bat populations and important links to feeding areas at Coed y Mardy and Caerphilly I Machen Disused Railway SINC sites 4. A probable breeding population of dormice Secondary reasons for designation: 1. Terrestrial habitat within 500m of known great crested newt breeding sites 2. Likely populations of reptiles and amphibians 3. Hedgerow networks which form important links to woodlands, ponds or other locally important habitats and are known to support protected species. (in this case, habitat connections for bats, dormice, amphibians and reptiles between SINC sites). Potential features of importance: 1. Important flight lines for Annex IV bat species 2. Smaller roosting opportunities for bats within mature trees 3. Hedgerows that would be considered as 'Important' under the Hedgerows Regulations (1997). It is clear from these reports that development of the proposed site at Gwern y Domen would have a devastating ecological impact and would be contrary to CCBC Policies SP10, SP11, CW6 and PPW s TAN5. In 2009 the Gwern y Domen candidate site was rejected by the Inspector who considered that development of it would represent the spread of the urban area beyond the well drafted physical edge of the established built up settlement and into open countryside to the serious detriment of the character and appearance of these rural surroundings. The Inspector stated it was poorly related to Caerphilly and the distributor road forms a defensible and robust boundary to development at this location development of this site would be unsympathetic to the present urban form and rural character and would not be a natural extension to the settlement. Furthermore, the candidate site had a number of constraints including tree preservation orders, ancient woodlands and the special landscape area. The candidate site forms part of a larger network of countryside links, including links with Rudry Common to the east, Wern Ddu woodlands and Caerphilly Mountain to the south and east with Bedwas and Machen to the north. Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 15

16 The site should be protected, in its entirety, for its important open countryside character and its role within the immediate and wider landscape setting. The Council not only ruled out the inclusion of this candidate site at the preferred strategy stage as a result of its unacceptable encroachment into the countryside and other ecology and landscape constraints; it also recommended to the Inspector at the EiP not to change the LDP in respect of any housing or other allocations nor to change the LDP in respect of amending the Special Landscape Area. It would, therefore, be incomprehensible should the Council consider that development of this site might now be acceptable, especially considering that the Council s own SE/ESA of the site during the revision of its own LDP showed such a negative impact of development. Out of the 70 plus candidate sites put forward in the replacement LDP Gwern y Domen had by far the most detrimental environmental & ecological impact in terms of CCBC's own strategic environmental assessment and sustainability appraisal as a consequence of development that could not be mitigated; twice as many as any other site put forward. No factors have changed since adoption of the LDP other than the speculative purchase of the land by a national developer. According to the Council s own candidate site assessment Gwern y Domen ranks the least favourable of all sites put forward in the Deposit Replacement LDP; that that assessment still holds true. The proposed development will cut off the current habitat corridors which run from Rudry common to this area. It also intersects the linear features of the SINC on the railway line and would cut off this area from any natural access to River Rhymney SINC via hedges and trees currently present on H1.64 and E1.11 separate this site from the woodland on the north of the site and the River Rhymney at Bedwas Bridge. The site already forms an important wildlife corridor and is part of a natural green space network, with woodland at the north western end through to the River Rhymney SINC NH 3.1 to the north, to the marshy grassland SINC with ancient woodland area part of NH at the centre, then linking to the dismantled railway scrub and woodland on the southern and eastern edge (also part of SINC NH3.70). This then forms more links with SINCs NH 3.168, NH3.185 and many others beyond. Community Impact Gwern y Domen falls within the St James ward. According to Stats Wales measures, this was the most deprived small area in Wales (it was ranked 2 in WIMD 2011 and now it ranks 1 in 2014). St. James 3 is the most deprived Lower Layer Super Output Area (LSOA) in the Education domain. It lies within the 10 most deprived LSOAs for the Income, Employment, Health and Education domains, which have a combined weight of 75% in the overall Index. It also lies within the 10% most deprived for the Community Safety domain. The LSOA has changed little in overall rank since WIMD 2011, but its relative deprivation has increased substantially in the Housing and Access to Services domains. A similar pattern can be seen in the Education, with the domain rank moving from 24 in 2011 to 1 in Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 16

17 The proposed development instead of assisting in removing the causes of deprivation will result in the devastating impact of obscuring those figures. The lack of infrastructure allocated for Caerphilly Basin will only serve to compound the issues of access and pressure on services. GP practices within Caerphilly currently have a 14 day waiting list for making health appointments, and there is no mitigation proposed for the inevitable worsening of this already unacceptable level of provision that would follow. With the Ystrad Hospital only accommodating light or minor urgent cases our urgent Health care needs in the area would be placed at breaking point. According to NRW a total of 68% of the adult population of Wales are not meeting the minimum level of physical activity through outdoor recreation. 6% fall within a red zone of concern and are likely to be elderly, disabled, unemployed, without qualifications and live in urban areas especially in SE Wales. Developing an area such as Gwern y Domen sterilizing such a space would go against WFG Act, a resilient Wales and would result in an impoverished living environment for those [St James Ward] residents in most need. It is clear that an increase of (Cardiff, Newport or Bristol commuting) residents in the Ward will dilute its level of deprivation, risking loss of projected investment to alleviate the situation. This will be a catastrophic blow to an already let down community and to the wider community. Population Growth The planning application [Environmental Impact Statement, Volume 3, Chapter 1] states that the population of the County Borough has remained stable over the last decade or so. However, there has been significant change in the distribution of the population within the County Borough, with the loss of population in the north and an increase in population in the south. In particular, the population in the Caerphilly Basin has increased by 4% from 50,765 to 52,996 (Censuses 1991 and 2001). This statement is clearly made in the context of a need for more housing for a growing population. The fact is that the population in the Caerphilly Basin has, since 2001, increased by a further 2,902 to 55,667; a 5.10% increase (2011 Census). Overall the Caerphilly basis has seen enormous growth from 34,600 in 1971 to 55,667 in 2011; a 61% increase in population over 40 years. The 1983 Caerphilly Basin Local Plan (CBLP) adopted by the Rhymney Valley District Council noted that the Caerphilly Basin had experienced a comparatively high rate of population growth from 34,600 in 1971 to over 43,000 in 1981 which led to increasing pressures on all services and facilities. The Caerphilly basin is now at breaking point without the necessary infrastructure or services to accommodate any further growth and struggling to meet the needs of the existing population. Key Objective of current LDP: Accommodate sustainable levels of population growth. / Ensure an adequate and appropriate range of housing sites are available across the County Borough in the most suitable locations to meet the housing requirements of all sections of the population. Interestingly the statisticians are saying the population will be in natural decline from the mid 2020's. Building 618 houses in a very congested area where there are already 555 empty properties is not meeting local needs but exacerbating local problems. Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 17

18 Flood Risk The proposed development at Gwern y Domen is on grassland between a forest and a major population area. The population area of Mornington Meadows and Bedwas is already rated as medium to high risk of flooding in parts (high in Bedwas) and some houses in Badgerswood still find difficulty in obtaining reasonable flood risk insurance. Should the proposed development go ahead, the capacity of the fields to the east of Caerphilly, and south of Bedwas will be significantly reduced. Greenfields can absorb around three times as much water as a housing estate - in addition the water passes through a housing estate far quicker than through a field (around 10x as fast). Developing Gwern y Domen will drastically increase the already high risk of flooding in Badgerswood, Bedwas and likely increase the risk in Mornington meadows. Tourism/Leisure The Gwern y Domen landscape is vitally important as part of the natural heritage and identity of Caerphilly town and its loss to development will negatively impact upon the economy not least for the equestrian businesses and tourism values it desperately needs. The bridleway ST runs through the prosed development at Gwern y Domen. This and other routes connected to it are promoted as a tourist and business benefit as What better way to discover the beautiful countryside of Caerphilly County Borough than on horseback. The British Horse Society s County Access & Bridleways Officer (CABO) for Caerphilly says, We work hard to defend, extend and promote safe, easily accessible off-road riding for everyone. This development however will have a significant impact on riders now classified as vulnerable road users, not only for reducing a safe area to ride but also increasing road traffic in an area where there is significant equine business and recreational horse riding. It is also noteworthy that 74% of riders are female. Therefore this plan to develop over or degrade the bridal paths within the Gwern y Domen area will indirectly discriminate against women. In May 2017, a young 14 year old female rider advised GDCG, By having access to the bridle path through Gwern Y Domen, I have a fully off road and safe route to hack over to my local showjumping centre. Without it I would probably not be able to go showjumping or the route to get there would be all roadwork and very dangerous. Today I won the showjumping championships, without being able to ride through Gwern Y Domen I would not have these opportunities. Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 18

19 Footpaths The Planning Application (Environmental Impact Statement, Volume 3, Chapter 1) notes public footpaths across the site, namely VAN FP6, VAN FP 8 and VAN FP 9 (as marked on the map below) However, as the developers are well aware (as they were notified in writing), applications were submitted to CCBC on 16 th December 2016 for Orders under Section 53(2) of the Wildlife and Countryside Act 1981 to add five footpaths which have been used by many members of the public for at least 20 years. These five footpaths are located on the development site. Heritage Gwern y Domen Farm Lane runs through the site from Rudry Road to Fran Fawr (Van Mansion) and which has probably existed since the sixteenth century (Glamorgan-Gwent Archaeological Trust study of Gwern y Domen Farm 1990) as shown on the 1842 map (highlighted red). To quote from the Explanatory Memorandum of the Historic Environment (Wales) Act 2016, If the historic environment is a precious resource, it is also a fragile one. A careless or unwitting act can destroy or irreparably damage a site that has survived for centuries, even millennia. Even small changes, seemingly insignificant in themselves, can gradually accumulate to erode and eventually obscure the historic nature of a venerable building or even an entire area. Such losses impoverish our surroundings, threatening the richness and variety of the historic environment that contributes to the individual distinctiveness of Wales communities and proves so attractive to visitors. The proposed development of Gwern y Domen will, without doubt, result in significant changes which will completely destroy the historic nature of the area. Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 19

20 The Glamorgan-Gwent Archaeological Trust (GGAT) study of Gwern y Domen Farm from 1990 indicates a track running east to west across Gwern y Domen which may form part of the Roman road from Caerphilly to Caerleon via Machen. It supports claims that the land has been farmed since medieval times and that there is archaeological interest in the early medieval site at the Maerdy which the proposed development borders. Indeed the plan submitted by the developer appears to cover the site of Maerdy Cottages (ringed on the map below). GGAT s report states that the evidence suggests the area has been farmed since at least the medieval period and the nucleus for this activity was centered at Maerdy which was the principal holding within the Van estate. It goes on to say that the area around Coed-y-Maerdy wood is of particular interest and although the presumed medieval and post-medieval settlements may have been destroyed by later industrial activity, this is by no means certain and in any event the industrial activity here is of sufficient antiquity and interest to merit protection in its own right. No field evaluation has yet been undertaken to determine more precisely their character, significance and antiquity prior to securing appropriate measures for the future protection of the Roman Road, the prehistoric burnt mound, the settlements and industrial workings in the vicinity of Coed y Maerdy Wood and an unidentified crop mark at ST In respect of CADW s representation the Pre-planning Consultation Report states (page 14) that EDP, a Chartered Institute for Archaeologists Registered Organisation has concluded that there will be a moderate/minor non-significant adverse impact on the setting of scheduled monument Caerphilly Castle (GM002) and that CADW agree with this. Gwern Y Domen Conservation Group PO Box 88, Caerphilly, CF83 2ZW GDFconservationgroup@gmail.com Page 20