Testun llawn:
Objection re: HG1 KS1: Sustainable Transport and Highways
I object to the inclusion of land at Weycock Cross (North West Barry) being included in
the RLDP because of the impact on congestion, air and noise pollution and the lack of
viable active travel and public transport options. Review of the RLDP supporting
documents evidence base exposes clear contraventions with PPW12 (Chapter 6), TAN
18 and Well-being of Future Generations Act.
Across all three RLDP Strategic Transport Assessment documents (BP14 Strategic
Transport Assessment - Stage 1 / BP14A Strategic Transport Assessment - Stage 2 /
Persimmon Homes/Asbri Draft Transport Assessment) the data, modelling and
conclusions contained within demonstrate that:
Congestion:
o Weycock Cross already operates close to capacity (RFC >0.8) at peak times of
day and will frequently operate over capacity in future as a result of the proposed
RLDP development, even if only the North West Barry site is considered. In its
own modelling, BP14A explicitly shows critical failure in the 2036 RLDP scenario.
o Likewise, the Persimmon Draft Transport Assessment accepts that with the
committed development, traAic levels at Weycock Cross will be “extreme and
unacceptable” and “over capacity”, yet still concludes the North West Barry
site’s impact is “marginal and inconsequential” when taken in the context of the
wider RLDP traAic increase. This is a circular argument (‘more traAic elsewhere
means the negative eAect of one site is proportionately less significant’) is
patently flawed, and contradicts PPW/Future Wales policy focus on reducing
traAic growth and car dependency, not perpetually enlarging junctions.
o TAN 18 and PPW require consideration of cumulative impacts and whether the
network is already at or near capacity - the assessments use small percentage
increases in traAic load (1.3–3.4% from North West Barry alone) to downplay
impact, while ignoring that even small increases can tip an already failing
junction into severe congestion.
o Overall, there is a significant risk that the proposed traAic congestion mitigation
measures will fail to deliver the necessary benefits, nor will they be delivered
before occupation, leaving all residents (new and existing) with years of
unacceptable congestion.
Data quality and modelling validity:
o TraAic modelling data is incomplete, inadequately validated, and
methodologically inconsistent: for instance, the entire Persimmon Draft
Transport Assessment is based on a single day’s traAic data in September 2023.
Likewise, the BP14/BP14A Transport Assessments provide no details on how or
when data was gathered, questioning the validity and provenance of that data.
o The required North West Barry site signalised access junction has not been
assessed cumulatively, leaving a material evidence gap, meaning impact on
traAic congestion is likely to be significantly worse than the modelling suggests
(while the TA talks about “platooning” and better control, the linked junction
modelling indicates that signals inevitably prioritise site traAic while increasing
delays on Port Road, rapidly pushing the wider network close to or beyond
capacity).
Air Quality Assessments:
o No AQA (air quality assessments) are referenced in any of the three TA
documents, despite clear congestion and policy triggers. This directly
contravenes PPW12 (Chapter 6), TAN 18 and Well-being of Future Generations
Act and this alone means the proposed Weycock Cross development is not
suitable for inclusion in the RLDP.
Active Travel/sustainable transport:
o Active travel provision in the plan is weak, indicative, and non-compliant with
statutory requirements, and does not take into account the inherent location and
topology of the site (a long 30-40-minute uphill walking route from nearest train
station).
o The Deposit plan states that land at North West Barry has “bus stops in close
proximity providing buses to Llantwit Major, CardiA and the centre of Barry” yet it
fails to mention that none of the bus services provide a meaningful way of getting
anywhere useful for those commuting to a place of work. For example, bus
service B2 runs hourly starting at 09.42 and ending its service at 15.52.
o Likewise, no existing bus services connect Weycock Cross with Barry train
station at any times of day. Whilst developers can promise up front to fund
additional bus services in future, this is not guaranteed, and public finances will
not be able to make up the gap. How is this suitable for anyone, let alone people
commuting to and from work?
o The Draft Transport Assessment does not really test whether this greenfield,
edge-of-Barry site can genuinely support a sustainable pattern of trips
(frequency, quality and directness of bus, walk and cycle links to key
destinations, particularly the commuter hub of Barry train station). It jumps
quickly from trip rates to junction modelling; PPW and TAN 18 expect a
sequential approach: location and accessibility first, then network impacts—
especially for greenfield housing that risks locking in car-based travel patterns
and dependency.
How can it be claimed that I have been consulted on this critical issue when there
are so many gaps and clear anomalies in the strategic transport assessment
information that I am required to consider?
