Testun llawn:
1. Conflict with the RLDP Spatial Strategy
1.1 The RLDP’s spatial strategy seeks to direct housing growth to sustainable locations, prioritising:
1.1.1 Well-connected settlements;
1.1.2 Locations with good access to services, facilities and employment; and
1.1.3 Development that reinforces, rather than undermines, settlement form.
1.2 The Site:
1.2.1 Is poorly related to the existing settlement patterns;
1.2.2 Represents an outward expansion that risks fragmented or dispersed growth; and
1.2.3 Does not clearly demonstrate how development would integrate with the existing built form in a manner consistent with the Plan’s strategy.
1.3 The location of the site therefore undermines the RLDP’s stated approach to sustainable growth and settlement hierarchy.
2. Unsustainable location and transport accessibility
2.1 Planning Policy Wales requires development to minimise the need to travel and to prioritise active travel and sustainable transport.
2.2 In respect of the Site:
2.2.1 There is insufficient evidence that the site is located within convenient walking distance of everyday services and facilities;
2.2.2 Public transport is essentially non-existent; and
2.2.3 Development would be likely to result in increased reliance on private car travel, contrary to the national policy and the VOG’s climate objectives.
2.3 The RLDP evidence base does not robustly demonstrate that these sites can support genuine modal shift or deliver sustainable travel patterns.
3. Landscape, countryside and settlement character
3.1 The VOG is characterised by a sensitive and distinctive landscape, with clear settlement edges and areas of open countryside, contributing to local character.
3.2 The allocation of the Site would:
3.2.1 Result in the loss of undeveloped land that performs an important landscape and/ or settlement function;
3.2.2 Risk erosion of settlement identity through incremental outward expansion; and
3.2.3 Cause harm to the visual and rural setting of affected communities.
3.3 Where sites lie within or adjacent to Special Landscape Areas of valued countryside, national and local policy requires strong justification. That justification has not been demonstrated.
4. Failure to deliver high-quality placemaking
4.1 Placemaking is identified in the RLDP as a central objective. However, the Site raises significant concerns in this regard:
4.1.1 The location and constraints risk development that is peripheral, car-dominated and poorly integrated;
4.1.2 Opportunities to create walkable neighbourhoods with a strong sense of place appear limited; and
4.1.3 There is a real risk that development would result in standardised estate layouts, rather than distinctive, locally responsive places.
4.2 The evidence does not show that development on these sites could achieve the quality of placemaking required by the national policy and RLDP.
5. Infrastructure capacity and deliverability
5.1 For the Site to be soundly allocated, the VOG must demonstrate that they it is deliverable within the plan period and supported by appropriate infrastructure.
5.2 In relation to the Site:
5.2.1 There is insufficient clarity regarding highway capacity, safe access and mitigation;
5.2.2 Local services and facilities are already under pressure, with no firm delivery strategy identified;
5.2.3 The infrastructure implication of allocating multiple sites in proximity have not been adequately addressed (as there are other candidate sites close by, namely 398, 401, 402, 468, 2671 & 4068).
5.3 As such, the effectiveness and deliverability of the allocation is not demonstrated.
6. Failure to justify the need for the Site
6.1 The RLDP must show that the Site allocation is necessary, having regard to reasonable alternatives.
6.2 The evidence does not demonstrate that:
6.2.1 More suitable or less sensitive sites have been exhausted;
6.2.2 Previous development land opportunities have been prioritised to the extent required by national policy; or
6.2.3 The Site is required to meet identified housing need.
6.3 Without such justification, the allocation of the Site fails the tests of soundness.
7. Cumulative impact
7.1 When considered collectively with other candidate sites in close proximity to the Site (namely candidate sites 398, 401, 402, 468, 2671 & 4068), allocation of the Site would result in:
7.1.1 Excessive growth pressure on certain settlements;
7.1.2 Incremental erosion of countryside and landscape character; and
7.1.3 Development that is inconsistent with a plan-led, sustainable strategy.
7.2 The cumulative impacts have not been adequately assessed or addressed.
8. Conclusion
8.1 For the reasons set out above, the Site is:
8.1.1 Unsustainably located;
8.1.2 Likely to cause unacceptable harm to landscape and settlement character;
8.1.3 Inadequately supported by infrastructure and deliverability evidence; and
8.1.4 Not justified by housing need or the consideration of alternatives.
8.2 The Site should therefore be removed from the RLDP, or the Plan found unsound insofar as it relies upon its allocation.
