Testun llawn:
I object to the allocation of HG1 KS1 (North West Barry / Weycock Cross) on the grounds that the site is unsound, unjustified, and undeliverable. The Council’s own supporting evidence, together with the developer’s technical reports, demonstrates that the site fails key tests relating to transport, drainage, biodiversity, Green Wedge protection, landscape character, heritage, and community infrastructure.
[1] Transport & Air Quality: Weycock Cross is already over capacity. The RLDP transport evidence is incomplete, based on limited data, and omits an Air Quality Assessment entirely. Active travel and public transport options are weak, indirect, or impractical. The site would generate significant car dependent growth and site-related congestion & pollution contrary to PPW and the Well being Act.
[2] Green Wedge & Landscape:
The Technical Briefing Note misinterprets PPW by reducing Green Wedge policy to a distance test. The 2015 Inspector found this land integral to openness and separation. The site remains visually exposed, contributes to the rural setting of Barry, and forms part of a continuous landscape corridor. The case for moving the GW boundary is weak and would set a damaging precedent.
[3] Biodiversity: The Preliminary Ecological Appraisal identifies multiple high value receptors, including ASNW, Priority Hedgerows, bats, dormice, badgers, otters, reptiles, and Red-List protected ground nesting birds. Impacts cannot be avoided or mitigated. The site cannot deliver PPW’s required net benefit for biodiversity.
[4] Community Infrastructure: The RLDP provides no deliverable strategy for GP capacity, social care, education, or community facilities. The Council’s own Health Impact Assessments warn of negative health outcomes if development proceeds without infrastructure in place. Vague assurances of off-site financial contributions have no real bearing on strategic infrastructure provision.
[5] Drainage & Flood Risk: The developer’s own drainage strategy shows unresolved risks: missing NRW Product 6 data, significant height discrepancies between flood models and ground levels, unknown outgoing watercourse capacity, unviable SuDS infiltration due to soil type, and the need for 9,580 m³ of attenuation. Foul drainage solutions are speculative and require major off site works. Fundamental viability remains unproven.
[6] Heritage: The Heritage Assessment fails to comply with PPW and Cadw guidance. It does not assess significance, setting, cumulative impacts, or mitigation. Conclusions are unsupported and cannot be relied upon for plan making.
[7] Conclusion: The allocation conflicts with PPW, TAN guidance, the Well being Act, and the Council’s own evidence base. The site is not sustainable, not deliverable, and should be removed from the RLDP.
