Otters, badgers and bats all under threat from developers
HERE IS THE TEXT OF CARDIFF CIVIC SOCIETY’S RESPONSE TO THE PRE-APPLICATION CONSULTATION ON LECKWITH QUAY : JUNE 2020
Cardiff Civic Society has the following comments on this consultation:
1. The Planning Report (PR 2.1.4) states that in planning policy terms the site – the majority of which is in the Vale of Glamorgan (VoG) – is “outside the defined settlement limits” of both Cardiff and the Vale of Glamorgan and thus is “in the countryside”. The site is not allocated for development in the Vale LDP and so should not be developed unless material planning considerations outweigh its designation as open countryside.
2. The proposal is to locate “highly sensitive development” (housing) in a C1 flood zone (PR 2.1.5). This designation means that the site is protected by flood defences, however if these are over-topped the consequences could be devastating. Given that we are in a Climate Emergency with sea level rise happening even more quickly than previously estimated and hugely destructive torrential rain becoming more frequent it would be most unwise to allow 250 new homes to be built in this precarious location.
3. The site is also in a Health and Safety Executive consultation zone (PR 2.1.6) because of potential contamination issues. For this reason alone this site is most unsuitable for housing.
4. A number of permissions for continued use of the site for industrial and related activities have been granted since 1986 (PR 2.2.1), although its use as a Waste Transfer and Recycling Centre was refused in 2002.
5. We note (PR 3.1.2) that the development offers the prospect of a new bridge on the B4267 Leckwith Road at no cost to the public purse which would be a significant benefit, however this offer should not “buy” planning permission for a proposal that would otherwise be refused.
6. The Planning Report claims (PR 3.1.3) that the new signal-controlled junction will “facilitate enhanced pedestrian and cycling opportunities”. This statement is clearly wrong. The proposed new junction would be located within a hundred metres of one of the most busy and complex interchanges on Cardiff’s highway network which present a formidable barrier to all but the most fearless pedestrian or cyclist. The site is located close to the Ely Trail, but this is primarily a recreational route so, whilst it would offer opportunities for exercise, it would not lead to facilities located on the Western edge of the City.
7. The Society is sceptical that this proposal would “….protect, maintain and enhance the existing habitats, biodiversity, landscape features, woodlands and built heritage assets across the site whilst also enhancing the Cwrt-yr-Ala Basin SLA.” Our fears are amplified by the claim (PR 5.1.3 with our bold italics) that “….it is located within the Cwrt-yr-Ala Basin SLA and overlaps with a small area of the Factory Wood SINC and lies adjacent to both Leckwith Woods and the River Ely which are both designated as a SINC respectively. These, however, are local designations only and the proposed redevelopment of the site will have no direct impact on them.” The construction of a new road bridge and building and occupation of 250 new dwellings with access roadways, lighting and activity levels is bound to have a lasting impact on the adjacent areas and their ecology.
8. We dispute the statement (PR 5.1.5) that the development would comply with the VoG LDP MG19 (6) and MG21.
9. We also dispute the claim (PR 5.1.21 and 5.1.22) that this is a sustainable location which will lead to an imperceptible increase in vehicular traffic and thus complies with Transport policy ie “….Policy SP7 of the Vale of Glamorgan LDP and LDP Policies KP6, KP8, T5 and T6 of the Cardiff LDP.”
10. Given that several of the buildings support roosting bats, there are otters in the River Ely at this point and a badger sett nearby we are sceptical that simply “ creat(ing) green fingers of woodland planting to connect the woodland and riverside habitats and forming wildlife corridors between the two…. will .. act as dark corridors across the site providing trees as a buffer from the built environment and shield from any necessary lighting on site.” Because of the scale of construction and the short and long-term impacts of 250 dwellings, when the current activity is in the daytime only, we reject the view that “ ….the proposed development would not have an adverse impact in terms of ecology and biodiversity and would therefore accord with Vale of Glamorgan Policies SP10 and MD9.”
11. We would welcome better protection of the Grade 2* listed and Scheduled Ancient Monument (SAM) bridge (PR 5.1.28)
12. Given that the imperative of the Climate Emergency and emerging evidence of the increased risk of fluvial and coastal flooding we can’t agree with the assertion that: “…the scheme is not, therefore, in conflict with the flood risk, hydrological and drainage policies of the Vale of Glamorgan LDP Policy MD7.”
13. Given its location we consider that this proposal could not integrate with the locality and thus would be in conflict with the National Sustainable Placemaking Outcomes set out in PPW 10 (PR 5.1.33). Indeed, we consider that this would be the wrong development in the wrong place and so does not “….compl(y) with national and local planning policy”.
14. Finally we are concerned that conducting this formal pre-application consultation during the Covid 19 Pandemic – when citizens are understandably more concerned about their own and their family’s health and safety than planning issues – could result in a lower number of comments than might otherwise be the case. If so, this should not be taken to indicate that this proposal is an acceptable one.
In summary, Cardiff Civic Society is not persuaded that the benefits of this scheme outweigh its significant dis-benefits, which are understated in the documentation. Our specific concerns are set out in detail above. Therefore, on the basis of the documentation presented at this stage, we have concluded that although the proposal for a new bridge is acceptable, the proposal for housing on this site should not be pursued.
However, it may be possible to consider alternative land uses on those parts of the site which have been developed already, provided these are compatible with the noise, pollution and flood risk hazards of the site, and would respect the ecological designations on adjoining land as well as protecting a heritage asset – the ancient bridge – on the site.
Nerys Lloyd-Pierce : Chairman, Cardiff Civic Society : 19 June 2020