LDP report: My concerns
10:13am Monday 21st January 2013 in Letters
I AM writing to express my concerns about the report into the LDP which is due to be considered by the Council (January 23).
The report was approved by the economy and environment scrutiny committee (December 4) and the planning committee (December 20).
The report set out three options for dealing with the LDP and the recommendation which has been approved so far is option 3 - ie to cease work on the Deposit LDP as approved in January 2012 and commence work on a replacement Deposit Local Development Plan.
Approximately 4700 residents have formally objected to the plan, expressing their concerns about many of the housing allocations which stem from the strategy of the LDP.
The committee report states that the LDP Preferred Strategy is sound and the fault has been the way in which the Deposit Plan implemented the strategy. It also states that it is essential that the council secures the necessary infrastructure to facilitate the development proposed in the Local Development plan and "representations indicated that there needed to be far more reference to the need to deliver transport improvements across all modes to adequately mitigate new development as well as dealing with the issue of congestion in the eastern Vale of Glamorgan."
A report was also presented to the cabinet (November 19) on the progress of the community infrastructure levy (CIL) with work being undertaken in tandem with the preparation of the LDP and that it was envisaged that the LDP and the CIL inquiry could run concurrently during 2014.
As the strategy of the LDP is to remain the same, the allocations in the revised deposit LDP will have to be in the same towns and villages as the allocations in the first deposit plan but the main difference being after the introduction of the CIL every new housing consent will have to contribute to the as yet undefined cost of providing new infrastructure.
There are two problems with this. Firstly, as the strategy is not changing, the 4700 objections to the LDP deposit development sites will not be overcome.
Secondly the introduction of the CIL will not raise sufficient funds to carry out the necessary infrastructure improvements required to deliver the LDP strategy. The LDP Strategy concentrates growth in Barry and the south east of the Vale where the major infrastructure problems exist and where major improvements will be required to allow the scale of the new proposed development to proceed.
Major improvements required to Port Road and the junction of Culverhouse Cross alone would cost in excess of £60m. The Dinas Powys Bypass would cost approximately £50m and improvements to the road from Llantwit Major to the A48 including the Llysworney Bypass would be an additional £20m - in total, £130m which does not include the cost of improvements to the Merrie Harrier junction, the Five Mile Lane and improvements to other junctions in Barry and the surrounding area which were assessed as being at capacity when the Barry Waterfront proposals were being considered.
It should be noted that all of these schemes were excluded from the first deposit plan on the basis that funds would not be available to finance their implementation. In order to make the LDP Preferred strategy deliverable the revised deposit LDP would have to include these schemes and the £40m raised from the CIL would leave a shortfall of over £100mjust to carry out the necessary highway improvements.
As well as this, CIL will also have to include costs for other elements of infrastructure such as schools, community facilities and recreation and leisure facilities.
In considering the options that have been put forward, the committee report members should be looking to adopt an LDP that meets the needs of the whole of the Vale and not one that suits a particular party interest.
The committee report states that the strategy of the LDP is sound but this has yet to be tested and will not be until the LDP examination.
What is evident is that the implementation of the Strategy directed allocations in the first deposit plan to locations which were considered to be unacceptable in the adopted Vale Unitary Development Plan - a situation that will continue with the revised deposit LDP which is based on allocating sites according to the settlement hierarchy regardless of whether those settlements are constrained.
It will continue to require the allocation of large housing sites on greenfield sites of good agricultural land quality to the edge of major towns and villages throughout the Vale. For example, Llantwit Major and Cowbridge are likely to continue to contain new allocations yet in the UDP it was recognised that they had reached their limit of development. To satisfy the LDP strategy areas that were protected from the development in the UDP such as the Heritage Coast and the Undeveloped Coast are now proposed for development. Large housing sites are proposed in minor rural settlements in which the UDP restricted development in order to protect their character and integrity. The implementation of the LDP strategy will inevitably mean that the sound planning principles established in the UDP will be discarded.
Re-issuing a new deposit plan in several months time together with proposed CIL will not overcome these problems nor the concerns of the objectors to the deposit LDP.
There is an obvious solution to the dilemma which the council is faced with and that is reconsidering the allocation of Llandow airfield which was recommended by the UDP inspector.
Officers are reluctant to include it because it questions their previous recommendation to exclude it from the Preferred Strategy and also the bad feeling that was generated from the judicial review undertaken by the developers.
The judicial review was undertaken mainly because when the Preferred Strategy was reported to Cabinet, the report failed to inform members that the council's own consultants carried out their independent analysis of the site they concluded it was sustainable and should be included in the LDP. These views were not supported by officers and as the consultants were not prepared to alter their view their contract was terminated by the council.
Understandably the developers who had made a considerable investment in the scheme and had been informed by officers that if the council's consultants considered Llandow to be a sustainable option it would be recommended to be included in the Preferred Strategy, challenged the council's decision to exclude Llandow from the Preferred Strategy on the basis that the Cabinet could not make an informed decision as the officers had not provided all the relevant information to Cabinet.
It should be made clear that the judicial review was into the procedures that had been followed in preparing the LDP strategy and had nothing to do with the merits of the scheme which the judge stated was a matter for the LDP examination.
Members will be aware that the proposals for Llandow have gained a large amount of support from members of the local community who consider this option to be a much better one than the expansion of towns and villages. It has even been supported by Friends of the Earth.
There is no better opportunity in the Vale than allocating Llanndow which if implemented properly would provide a sustainable solution.
The new housing would be provided adjacent to the existing employment area which will be expanded and allow people to reduce journeys to work.
The site lies adjacent to the Vale of Glamorgan passenger railway line and one of the conditions of implementing the site should be the re-opening of the passenger station adjacent to it.
The development should also fund the provision of the Llysworney bypass and the road improvements from Llantwit Major to the A48 including the Pentre Meyrick roundabout. These infrastructure improvements have been costed and can be paid for by the developer either by S106 contributions or through CIL. Members will also be aware that there is a lot of support for the Llysworney Bypass which should be re-instated in the revised deposit LDP.
Members should therefore select an option which allows Llandow Newydd to be included in a revised deposit LDP. This may require re-consulting on a revised Preferred Strategy but at least such a revision would allow a significant amount of the required new housing to be accommodated in Llandow and make it unnecessary to include so many unpopular and controversial allocations in Barry, Penarth, Sully, Cowbridge, Llantwit Major, Wick and other rural villages.
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