Testun llawn:
I formally object to HG4(3)/Site ID 404 /Site ID 2814, the allocation of 50 dwellings at Land at Heol Fain, Wick, within the Replacement Local Development Plan 2021–2036. While the need for affordable housing is acknowledged, development must be proportionate to settlement scale, supported by infrastructure, and consistent with national sustainability policy. In this case, the Plan does not demonstrate that these tests are met.
Wick is a small rural village with a population of approximately 927 at the 2021 Census. In recent years it has already experienced substantial residential growth with 124-dwelling estate completed in 2019 and a further 17 affordable homes have recently been built on the edge of the village, significantly increasing the size of the settlement within a short period and a material increase in housing stock in a settlement of fewer than 1,000 residents. However, there has been no corresponding expansion in local infrastructure or services. The village continues to rely on a single primary school, a small shop/post office and one remaining public house. There is no secondary school or GP surgery within the village, and limited employment opportunities. As a result, residents must rely heavily on nearby towns such as Bridgend, Llantwit Major and Cowbridge for many everyday services and employment opportunities. Continued housing growth risks reinforcing patterns of car-dependent travel. National planning policy emphasises the importance of sustainable placemaking and locating development where communities can access daily needs in a sustainable manner. The Plan does not clearly demonstrate how the proposed scale of growth in Wick supports these objectives.
Against this context, the proposed allocation of a further 50 dwellings represents continued expansion without clear evidence that the settlement can sustainably absorb additional growth. The Deposit Plan does not provide a settlement growth analysis demonstrating why this scale of additional housing is proportionate to Wick’s size, service base, and infrastructure capacity. Without such analysis, it is not possible to conclude that the allocation reflects balanced or sustainable development, or that it is justified when considered against the alternatives available to the Plan. National planning policy requires development plans to direct growth to the most sustainable locations and ensure that development in smaller settlements remains proportionate.
The Candidate Site Summary identifies the site as Red for Climate Change and Red for Access to Health Services, with several infrastructure categories rated Amber. A Red climate rating indicates that the site performs poorly against sustainability and decarbonisation objectives. However, the Deposit Plan does not explain the basis for this rating, or quantify the likely transport or carbon impacts, and thus does not identify mitigation sufficient to demonstrate alignment with national policy. Under Planning Policy Wales Edition 11 and the Environment (Wales) Act 2016, development plans must support decarbonisation, reduce reliance on private car travel, and locate growth in the most sustainable locations. In the absence of clear evidence explaining how a Red-rated site contributes to these objectives, the allocation lacks sufficient justification.
Similarly, the Red rating for Access to Health Services reflects the site’s limited proximity to essential healthcare facilities. The Plan does not provide evidence of confirmed GP capacity, agreement from the relevant Health Board, or secured mitigation measures. Given the recent and proposed cumulative growth in Wick, the absence of such evidence raises concerns about the ability of local services to accommodate further population growth.
Infrastructure capacity more generally is also identified as requiring mitigation through several Amber ratings in the assessment. Amber indicates that constraints exist and are not fully resolved. For an allocation to be sound, the Plan must demonstrate reasonable certainty that necessary infrastructure can be delivered within the Plan period. While the Infrastructure Delivery Plan identifies the types of studies typically required at planning application stage, it does not provide clear evidence that constraints affecting this specific site have been fully assessed or resolved.
The site also lies outside the strategic growth area. The RLDP Candidate Site Stage 2 Assessment Register (November 2023) notes that only small-scale affordable housing could potentially be considered “subject to need and viability”, and that market housing would not be acceptable. Inclusion of the site as a formal allocation therefore appears speculative and conditional, with no clear evidence demonstrating affordable housing need or delivery viability. Premature allocation risks undermining the Plan’s strategic approach.
There may also be drainage considerations requiring further assessment. The field proposed for development lies slightly lower than surrounding housing and is bounded by a lane and sewage pumping station at the lowest point. Parts of the field appear to contain reeds or similar vegetation, which may indicate naturally wet ground conditions. While this observation is not based on formal hydrological analysis, it suggests the land may already contribute to local surface water drainage. The 2011–2026 Deposit Plan previously required investigation of sustainable drainage and soakaway suitability for the adjacent development that has since been constructed on two sides of the field. Development of the remaining land could therefore affect drainage arrangements serving existing properties. In the absence of detailed evidence demonstrating that drainage issues can be satisfactorily addressed, deliverability remains uncertain.
The allocation would also represent further greenfield expansion of the settlement. Incremental outward development alters the character and form of a rural village. The field has long been informally used by local residents for dog walking and quiet recreation. Although privately owned, this informal use contributes to local amenity and its loss would be noticeable for nearby residents. Whilst the site appears within the settlement boundary, the boundary itself has been specifically moved to accommodate the site under the associated Settlement Boundary Review. This approach risks creating a circular justification whereby the site is brought within the settlement boundary specifically to accommodate the proposed allocation, which may then appear more acceptable because it lies within the settlement boundary. It also risks predetermining the suitability of the site through the boundary review process rather than assessing the allocation on its planning merits.
This objection therefore relates not only to the characteristics of the site itself but to the cumulative impact of continued housing growth in Wick without corresponding improvements to infrastructure or services. The Plan does not demonstrate that allocating 50 additional dwellings in a village that has already experienced significant recent growth is proportionate, sustainable, or consistent with national climate and placemaking objectives.
For these reasons, HG4(3)/Site ID 404 /Site ID 2814 is not justified by the available evidence. The Plan does not demonstrate that the scale of development is proportionate to the role and capacity of the settlement, that infrastructure constraints can be satisfactorily addressed, or that allocation of an out-of-strategy site is appropriate.
