Testun llawn:
Representations regarding (objections to) the proposed designation of a Green Wedge between Llantwit Major and Llanmaes
Please find enclosed, on behalf of and under instruction from our client, ‘Representative Body of the Church in Wales (RBCW)’; ‘Ms Rhian Reid’ and ‘Mr Anthony John Cowling’, representations for consideration as part of Vale of Glamorgan’s RLDP Deposit Plan.
Context to these Representations
This submission comments on the Deposit Plan, specifically the proposed designation of a Green Wedge between Llantwit Major and Llanmaes, this designation includes our client’s site ‘Glebelands at Llanmaes’, which for clarity extends to the following:
Aerial image of our client’s site (outlined in red)
The site is divided into three parcel’s, each under separate client ownership. For context, the site ownership plan is provided below.
Aerial image of our client’s site (outlined in red and yellow)
Parcel Owner
Parcel 1 Representative Body of the Church in Wales (RBCW)
Parcel 2 Ms Rhian Reid
Parcel 3 Mr Anthony John Cowling
The Green Wedge
As part of the Deposit Plan, updated Proposals and Constraints Maps have been published by the Council. The Deposit Plan Proposals Map sets out the Vale of Glamorgan’s green wedge designations. For context, a number of Green Wedge designations (7 in total) are made by the existing adopted LDP (the Development Plan). The Deposit Plan Proposals Map sets out that the Vale of Glamorgan Council proposes a designated Green Wedge between Llantwit Major and Llanmaes, accordingly, one of 2 new / additional green wedges (responding to submissions made through the RLDP Candidate Site Process). For ease of reference, an extract of the relevant Proposals Map is provided overleaf:
Deposit Plan Proposals Map
Alongside the Proposals Map, the Deposit Plan RLDP Written Statement sets out and includes Policy DNP2 (Green Wedges) which states the following:
“Green wedges have been identified to prevent the coalescence of settlements and to retain the openness of land at the following locations:
1. Between Dinas Powys, Penarth and Llandough;
2. North West of Sully;
3. North of Wenvoe;
4. Between Barry and Rhoose;
5. South Penarth to Sully; and
6. Between Llantwit Major and Llanmaes.
Within these areas development which prejudices the open nature of the land will not be permitted.”
The subtext to the policy also sets out the following:
“6.417. Therefore, within the areas defined by the green wedges there will be a presumption against inappropriate development19 which would contribute to urban coalescence, prejudice the open nature of the land, or have an adverse impact upon the setting of an urban area. In applying this protection, however, it is recognised that individual or small groups of dwellings exist within the designations and that activities such as agriculture, forestry and recreation, occur. Consequently, development associated with existing uses will be limited to minor structures which are strictly ancillary to existing uses. Details of each of the designations are contained within the Green Wedge Background Paper”.
These Representations (Objections)
We appreciate the intention of the Llanmaes and Llantwit Major green wedge is to “prevent the coalescence of settlements and to retain the openness of land” – in this case and instance Llantwit Major and Llanmaes.
Whilst we do not raise objection to the designation of a Green Wedge per se (i.e. an outright objection to the principle and / or extent of some of the designation proposed) we do object to the particular extent of, and precise definition of, its extent. Accordingly, our clients’ representations seek to omit their land ‘Glebelands at Llanmaes’ from the proposed Green Wedge, for the reasons set out below, and evidenced as follows.
Again, and for clarity, our client’s ownership site plan is provided below:
Aerial image of our client’s site
Our clients land relative to the proposed green wedge designation is shown more precisely and closely by the following extract from the proposals map.
‘Zoomed in’ Deposit Plan Proposals Map (approx. site location outlined in red)
As Policy DNP2 (Green Wedges) of the Deposit Plan RLDP Written Statement sets out, the intention of a Green Wedge designation, as per PPW guidance, is to “prevent the coalescence of settlements”, which in this case is to prevent the coalescence between Llantwit Major and Llanmaes. Whilst we fully appreciate the Vale of Glamorgan’s intentions to prevent the urban coalescence of these two settlements, we question the necessity of including the Glebelands site within the proposed Green Wedge boundary.
Step 18 of the Green Wedge Assessment seeks to ‘Determine whether outer boundary should be adjusted in order to use clear boundary features, or to simplify its form’. Paragraph 3.5. of the Green Wedges Background Paper (BP27) reiterates the PPW guidance for defining green wedges “boundaries should be chosen carefully using physical features and boundaries to include only that land which it is necessary to keep open in the longer term”. In respect to the Llantwit Major and Llanmaes green wedge, the assessment itself acknowledges that the designation should “Use Llanmaes Brook which forms the southern edge of the existing Conservation Area boundary as the northern boundary of most of the green wedge to the southeast”.
Given this, it is questioned as to why the designation extends northwards beyond the Llanmaes Brook. There are already clear, distinguishable physical features – including the B4265 and the Llanmaes Brook (illustrated on the image below). These physical features are adequate and sufficient barriers to development north of the by-pass – which is designated as ‘countryside’ and does not adjoin a/the settlement boundary (to either Llantwit Major and / or Llanmaes) and is significantly protected in policy terms as a result.
Defensible Boundaries between Llantwit Major and Llanmaes
Key
Extensive strong woodland belt along and following watercourse
Extensive road corridor
In this context, the designation of the Glebelands site as part of the Green Wedge extends the boundary into an area where there is no demonstrable need for additional restriction, and where the stated purpose of preventing coalescence is already being met by existing physical features and policy context. We therefore propose the following Green Wedge between Llantwit Major and Llanmaes, which depicts a considered, more evidence-based extent to any Green Wedge designation:
Proposed Alteration to the Green Wedge
The above Green Wedge clearly maintains the intentions of the Green Wedge between Llantwit Major and Llanmaes to “prevent the coalescence of settlements” whilst “using physical features and boundaries to include only that land which it is necessary to keep open in the longer term”.
Accordingly, this refined extent would follow clear physical features whilst still fully achieving the intentions of the wedge, and avoiding the unjustified inclusion of the Glebelands site. For these reasons, we maintain that the Glebelands site should be excluded from the proposed Green Wedge designation.
Summary
The omission of our clients site ‘Glebelands at Llanmaes’ from the proposed Green Wedge is both evidence-based and consistent with the guidance set out by PPW. As such, the revised boundary running adjacent to Llanmaes Brook and the associated vegetation, represents a more robust, defensible, and policy compliant Green Wedge designation.
The following plan depicts a considered more evident and policy compliant extent to any Green Wedge designation:
Proposed Alteration to the Green Wedge
Summary and Conclusion of these Deposit Representations / Objections
In summary, these representations to the Deposit Plan object to the green wedge designation between Llantwit Major and Llanmaes, specifically the inclusion of the ‘Glebelands at Llanmaes’ site.
It is considered the assessment for this green wedge is not soundly based. As set out above, the decision to include the Glebelands site is not justified given that the intentions of the green wedge can be maintained with the omission of our clients site. A more appropriate, evidence-led boundary is therefore put forward, following clear defensible physical features by adjusting the northern edge of the Green Wedge to correspond with Llanmaes Brook.
Given the detailed nature of this representation our clients would be happy to discuss any aspect of this letter when your Authority comes to evaluate the content.
We look forward to hearing from you in due course. In the meantime, however, we hope and trust that all is in order with this submission. Please do not hesitate to contact us in the event that further information is required or considered beneficial.
