Testun llawn:
I would like to raise my objection and concerns for the inclusion of the Site 4069 (also referred to as HG4 (1)) Land to the East of Colwinston for 25 Residential dwellings as part of the Deposit Replacement Local Development Plan (RLDP). The site is unsuitable for the intended use due to access and safety concerns, is in conflict with the Vale's own sustainability policies, and will negative impact the environment and habitat surrounding the village. Specifically:
1. The existing LDP (2011-2026) shows the current settlement boundary for Colwinston running to the west of the proposed Site 4069. The RLDP proposed to shift this boundary to allow Site 4069; however, this change is neither justified nor is it supported by any obvious environmental, planning, or policy goals. Background Paper (BP18a) provides an assessment of the various Candidate Sites put forward and states that Site 4069 "would be an appropriate rounding off in respect of the settlement pattern in Colwinston". This conclusion seems arbitrary and flawed as the proposed change doesn't fill in/round off the existing boundaries in any way, nor does it follow the established pattern of development in the village. In fact, it is wholly out of character and in conflict with the existing arrangement and form of the village, and will expand the development footprint into the countryside without any connection to the surrounding village, with an associated impact on the environment. Expanding the settlement boundary as proposed would actually facilitate future 'rounding off of the boundary to the north and south and should therefore be rejected.
2. Similarly, as part of the Call for Candidate Sites for the RLPD in 2022, several sites located east of the Colwinston settlement boundary were assessed for their suitability for residential development (Site 409, Site 453, Site 474). Of these, Site 453 occupies the same location as Site 4069, albeit a larger area. Site 453 was rejected as suitable for housing as "the site would represent unacceptable intrusion in to the open countryside and is affected by major highways constraints." Although the Vale desperately needs affordable housing, this site remains unsuitable for exactly the same reasons due to its incursion into the open countryside and the existing major highways constraints that were cause for rejecting the site in the Candidate Site Assessment Register (November 2023).
3. Colwinston is defined in the RLDP as a Minor Rural Settlement, and has a limited number of local facilities, including a church, pub, and Church in Wales Primary School. However, the lack of any shops or public transportation in the village means that it is a car-dependent community for most services and is not a sustainable location for new development. Under Welsh Planning Policy new development should be located so that most people's needs are available within a 15-20 minute walk or bike, but this is certainly not the case in Colwinston. In the evidence base of the RDLP, the Settlement Appraisal Review (June 2023) (SAR) awards a score of '6' to Colwinston for having a regular bus service (note that Greenlinks are excluded from their analysis) - this is factually incorrect. The SAR defines that access to bus services "must be within 400m of the settlement being assessed in order to receive a score". The nearest bus stops to the village are located on the A48, approximately 1,000 m from Site 4069 and are only accessible via a narrow road with no footway or cycle provision. In addition, the eastbound bus stop is only accessible across a three lane section of busy road where the posted speed limit is 60mph and there is no crossing, making this a very dangerous stop to access. Correctly scoring Colwinston (with a score of 0) due to this lack of bus or cycle provision would significantly lower the villages sustainability score.
Furthermore, BP18a appears to give the site a green scoring for Sustainable Transport - Active Travel Access" (page 86) when there is no Active Travel (pedestrian or cycle) linking non-vehicular modes of movement in anyway proximate to the site. Therefore, providing a further 25 homes in a village with few services and no public transportation would create new housing that is car-dependent and therefore in conflict with current national planning policy and the RLDP. Specifically, Site 4069 would not promote new housing "in sustainable locations with good access to employment, public transport, community facilities and shops" (section 5.3), nor would it be consistent with the Placemaking and Active Travel policies of the RLDP (section 4.1) that aim to facilitate development of "safe, accessible, well-connected communities equipped with appropriate supporting infrastructure" and "promote the use of sustainable methods of travel".
4. Development of Site 4069 would also be detrimental to the safety of residents and visitors to the village due to the additional traffic placed on the narrow country roads that access the village. Although not at capacity from a volume point of view, the roads into Colwinston are all single-lane country lanes with passing places, and all significantly less than a normal 5m carriageway. With heavy school traffic especially at morning and afternoon pick up times, no footway and blind or poor visibility at many locations, the roads into the village are often dangerous and not safe places to walk (especially for children, as a recent accident would attest to). A new development would add more traffic to this already unsafe road system, especially considering the car-dependent nature of a village without public transportation or Active Travel connections, and therefore should be considered unsustainable and inappropriate.
5. Site 4069 can only be developed by access through a gateway onto Heol Cae Pwll, a road that has not been adopted locally by the Council due to failures of Redrow to complete all their Section 106 obligations. Notwithstanding that issue, Heol Cae Pwll is often effectively rendered a single lane road due to parents and staff of the school parking along the roadway. This forces cars leaving the development onto the wrong side of the road, where visibility is very poor, creating an un-safe traffic arrangement.Add to this the presence of young school children running across the same intersection, and the parking of cars on the verges along the main road, conflicts between cars and pedestrians are common, with a child recently having been hit at the school entrance. Adding a further 25 homes onto this road would seem to only add to these issues and create further unacceptable risk. This access arrangement would also be un-safe should construction go ahead with all materials and labour having to travel through the same bottleneck to access the site.
6. Site 4069 has an existing Public Right of Way (PRoW) that runs along the hedgerow to the west of the site, connecting the north and southern parts of the village. This route currently has a countryside character as it passes through fields along the existing hedgerows. Development of the site will change the character of this route significantly, or re-routing the PRoW would be much more circuitous than the existing pathway, neither of which seem appropriate for a pedestrian connection of this type. Ideally, any future development would retain the PRoW within a Green Infrastructure (GI) corridor that provides amenity space and public realm for residents, and habitat and dark corridors for bats consistent with the RLDP policies. However, such a provision would likely reduce the viability of any future development by reducing housing numbers and so seems unlikely to be provided. Therefore, if the site goes forward the Council should at a minimum require extensive GI corridors along the existing hedgerows through which the PRoW and pedestrian corridors should be retained.
