Testun llawn:
HG1 KS1 North West Barry (Weycock Cross)
Objection-KS1: Green Infrastructure, Recreation Spaces and Biodiversity
I object to the proposed removal of the Green Wedge designation and the allocation of land at
North West Barry (HG1 KS1), as set out in the Technical Briefing Note – Green Wedge and
Landscape Implications of Expanded Site and its annexed reports. The rationale presented is
methodologically flawed, inconsistent with national policy, and directly contradicts the findings of the 2015 Planning Inspector and the adopted LDP.
1. Misinterpretation of Green Wedge Policy and Contradiction of Inspector Findings
The Technical Briefing Note asserts that the land is “not necessary” for the Green Wedge to
function because a gap of 2.3–2.5 km would remain. This is fundamentally unsound.
The 2015 Planning Inspector explicitly concluded that this site:
forms an integral part of the pastoral landscape of the Green Wedge
plays a key role in maintaining openness
would be harmed by development
Planning Policy Wales (PPW) is clear that openness, not distance, is the defining attribute of a
Green Wedge. Coalescence is assessed through character, perception, openness, and
containment—not kilometres. The Briefing Note misinterprets national policy by reducing it to
a numerical metric.
2. Circular and Self-Serving Reasoning
The Briefing Note argues that because the existing settlement edge is “poor quality” (fences,
gardens), extending the settlement boundary 200 metres west would “improve” it.
This reasoning is circular:
it uses previous erosion of the Green Wedge to justify further erosion
PPW states that Green Wedges exist precisely to prevent incremental outward creep
and urbanisation
a degraded edge strengthens, rather than weakens, the case for retaining openness
It is illogical and contrary to PPW to argue that because the Green Wedge has already been
weakened, it should be weakened further.
3. Incorrect Claims of Visual Containment
The Briefing Note claims the site is visually contained due to landform and woodland.
However, its own visual appraisal confirms the opposite.
The site is clearly visible from:
Cwm Ciddy Lane
the A4226 (major approach into Barry)
Coed-y-Felin and other elevated residential areas
all existing properties on the eastern boundary
The Inspector previously confirmed that the land:
has an open, undeveloped character
contributes to the perception of separation
The land is not visually enclosed in any meaningful sense; it is only partially filtered.
4. Understatement of Landscape Importance
The Briefing Note repeatedly describes the site as “unremarkable” or of “low sensitivity”. This
contradicts:
LANDMAP classifications, including a High-value geological landscape and several
Moderate-value layers
the Inspector’s conclusion that the site forms part of a meaningful undeveloped
landscape corridor
The assessment treats the site as an isolated parcel, ignoring its role as part of a continuous
open landscape between Barry and Rhoose. Green Wedge designation protects function, not
merely scenic quality.
5. Misrepresentation of the 2011 Green Wedge Background Paper
The authors argue that because the 2011 draft paper excluded the site, it is unnecessary. This
is misleading:
the 2011 paper was draft evidence, not an adopted designation
the site was reinstated in 2013 during plan refinement
the 2015 Inspector accepted the adopted Green Wedge boundary as valid and sound
Selective quoting from early drafts ignores the plan-making process, consulta on, evidence
refinement, and Ministerial approval.
6. Incorrect Applica on of PPW Tests for Green Wedge Dele on
The Briefing Note claims development would be a “controlled expansion”. This contradicts
PPW, which states that Green Wedges should only be removed where normal development
management policies are insufficient to protect openness.
The paper argues the opposite: that normal policies can control expansion. This is
self-defeating. If normal policies suffice, then Green Wedge protection remains necessary.
The paper also assumes that housing need justifies deletion. PPW is explicit: housing need
alone is not grounds for removing a Green Wedge.
7. Flawed “2.5 km Gap” Argument
The claim that “2.5 km would remain” is a flawed metric. Green Wedges do not operate on
minimum distances. PPW states that wedges exist to:
avoid incremental erosion
prevent perceived coalescence
maintain long-term openness
Urbanisation on one side of a wedge can significantly alter perception even if distance
remains.
8. Weak and Non-Defensible Boundary Proposal
The Briefing Note argues that development would “round off” Barry. This is incorrect.
True rounding-off requires strong, defensible boundaries such as:
major roads
rivers
ridgelines
Here, the only proposed boundary is Cwm Ciddy Lane, a narrow rural lane screened by
hedgerows. This is not a strategic boundary. Moving the boundary westwards invites further
pressure beyond it, undermining the Green Wedge in the long term.
9. Precedent Risk
If this sec on of the Green Wedge is removed:
the boundary becomes arbitrary rather than principled
cumulative erosion becomes harder to resist
other landowners will cite this as precedent
This undermines the historic and strategic role of the Barry–Rhoose Green Wedge.
10. Ecological Objections
The KS1 Preliminary Ecological Appraisal (May 2025) identifies multiple high-value and legally
sensitive ecological receptors. Development would result in significant, unavoidable, and
policy-contrary ecological harm.
10.1 Harm to Irreplaceable Ancient Semi-Natural Woodland (ASNW)
The site adjoins the North East of Knock Man Down Wood, a SINC and designated ASNW. The
PEA confirms:
a rich tree canopy (Sycamore, Ash, Yew, Sessile Oak and Beech)
a diverse understorey
numerous ancient woodland indicator species
The woodland is highly vulnerable to:
hydrological changes
surface water pollution
lighting impacts
trampling and recreational pressure
Development would inevitably cause deterioration through edge effects and disturbance, not
only for the long term, but also during the construction phase.
10.2 Loss and Fragmentation of Priority Hedgerows
The site contains species-rich native hedgerows, all Priority Habitats under Sec on 7 of the
Environment (Wales) Act 2016. These provide:
nesting habitat for a variety of birds
bat commuting corridors
dormouse movement routes
rep le and amphibian foraging
Development will result in hedgerow breaches and contamination, fragmenting ecological
connectivity.
10.3 Adverse Impacts on Bats
Mul ple bat species use the site, including:
Brown Long-eared Bat
Common and Soprano Pipistrelle
Whiskered, Daubenton’s, Serotine
Noctule
A day roost lies less than 50 metres away. Development would:
introduce harmful lighting
risk loss of mature Ash with high roost potential
sever flight lines
10.4 Risk to Hazel Dormouse (European Protected Species)
A Dormouse nest was recorded in 2013. The PEA confirms the hedgerows:
provide suitable food sources
connect directly to high-quality woodland
have sufficient structure
Any impact on hedgerows or lighting spill risks harming this strictly protected species.
10.5 Badger Disturbance
Evidence includes:
a fresh latrine
well-used pathways
guard hairs under fences
The site lies within a Badger clan’s territory. Development would disrupt foraging routes and
increase risk of harm.
10.6 Impacts on Otters
Otters were recorded in the central wet ditch and nearby Nant Talwg watercourse. Carcasses
have been found on or near the site, most recently in February 2026. Men on is made in the
report of the central ditch which serves as an o er commuting link between the water courses
bounding the northern and southern areas of the site, regardless of seasonal drying.
Development introduces unavoidable risks from:
pollution
drainage changes
lighting disturbance
10.7 Loss of Ground-Nesting Bird Habitat
Species recorded include:
Skylark (Sec on 7 Priority Species)
Song Thrush
House Sparrow
Development would remove nesting habitat and cause irreversible loss of farmland bird
territory.
10.8 Impacts on Rep les, Amphibians and Invertebrates
Field margins, the wet ditch, hedgerows and woodland edge support:
Slow Worm
Common Frog
amphibian foraging habitat
priority invertebrates
These habitats would be permanently lost or degraded.
10.9 Conflict with the National B-Lines Pollinator Network
The southern part of the site lies within the national B-Lines network. Development would
remove stepping-stone habitat and break the corridor.
11. Failure to Deliver PPW’s Required “Net Benefit for Biodiversity”
PPW Edi on 12 requires all development to deliver a net benefit for biodiversity and follow
the stepwise approach (avoid → minimise → mi gate → compensate).
The PEA demonstrates that:
the most sensitive habitats lie at the boundaries
these boundaries face the greatest development pressure
harm cannot be avoided or fully mi gated
The developer’s claim that leaving a remnant of the existing greenfield plot as an “open space
buffer” would in some way deliver “significant biodiversity enhancements” is unsubstantiated
and wholly contradicted by the ecological evidence.
Conclusion
The allocation of this land is ecologically unsound, contrary to national and local policy, and
should be removed from the RLDP.
