We welcome Council’s recognition that a full Replacement Review is needed, given the extensive contextual changes since the adoption of the current LDP in January 2016. We want this to take a comprehensive view that will put the needs of the city’s residents and the welfare of future generations ahead of the demands of developers, and prioritise improvements to the quality of daily life ahead of prestige projects.
Size and nature of LDP
At 406 pages, the current adopted LDP is a formidable document for residents to read and use. The Replacement LDP should be no more than 100 pages in length, with a sharpened focus on how the city should develop, removal of repetition, and referral to SPGs for technical detail.
A single overarching policy should set common criteria that would then be reflected in each individual policy. We have commented in our response to the Draft Review Report on what this should be. With an integrated approach, both residents and organisations will better understand what the LDP is seeking to achieve. Individual policies should be kept short and clear. Explanatory commentary on a policy should avoid undermining that policy by providing clauses that could be used to circumvent it.
Understanding of the LDP would be improved through the use of images and graphics, including a Key Diagram, showing required infrastructure at a city-wide level, and for existing and proposed neighbourhoods, assessing (with community councils, public sector, voluntary sector and business) gaps in education, community, recreation, health and transport for each.
A Strategic Development Plan for South East Wales will be produced in parallel with Cardiff’s new LDP. This should follow the same integrated, focused approach that we recommend for the LDP. Care should be taken to avoid contradiction and unnecessary duplication. An SDP presents opportunities that could be beneficial to both Cardiff and other authorities, such as offering a wider range of brownfield sites for housing growth. The LDP should not adopt damaging land use policies if the SDP could open the way to better alternatives.
Context and evidence base
We have commented on the context and the Evidence Base in our submission on the Draft Review Report.
2 COMMUNITY INVOLVEMENT SCHEME
Who will be consulted?
Paragraph 2.1 explains that “The LDP Regulations require the Council to work in partnership with a wide range of stakeholders in preparing the Replacement LDP, including specific and general consultation bodies (see Appendix A) and the general public.” Appendix A appears to be out of date (e.g. it includes MEPs) while general consultation bodies have been identified as those “who appear to have an interest in development matters” (para. 1.5). Cardiff Civic Society is pleased to be on the Appendix A list, but the way in which this list has been drawn up introduces biases and could exclude those who may have important views about the future of the city if they were asked.
The prosperous suburbs in the north of the city are well represented (either through their Community Councils or recognised local groups) but the poorer inner city is not. Many of the questions an LDP seeks to tackle (e.g. easy access to functional open spaces) have varying implications across the city’s wards. The list of consultees should be extended to ensure all parts of the city are represented, through inviting contributions from bodies (e.g. local community centres) which do not usually comment on development matters. In addition, a councillor from each ward should be involved in LDP preparation.
Similarly, recently formed groups could have important things to say about how the city should change to meet their concerns and priorities. As examples, Extinction Rebellion or Youth Climate Strike have much to say about environmental and climate change challenges, Black Lives Matter could offer a view from young black people. The list of consultees should be extended, and organisations should be encouraged to come forward.
Steps to reach out to those who do not usually interest themselves in development issues, except when immediately affected, would help achieve inclusiveness and wider consensus across the city.
The consultation process
Consultation questions should be open (e.g. “what would you like to see in your area?”) rather than expecting people to engage with daunting planning documentation that may not be easily accessible to those without an academic or professional background, or whose first language is not Welsh or English.
The way of working needs to be collaborative, so that the LDP is “owned” by the majority of those involved in its preparation, which will involve the Council working across sectors and age groups to help reconcile differences. The LDP must not be taken over by developers and landowners with the resources to sustain engagement with the process over a prolonged period, which will be more difficult for resident groups unless supported by Council officers.
It is unclear how residents will be engaged in building the Evidence Base. Developers and landowners will be asked to submit candidate sites, but will those be visible for public comment? Consultation is promised on the Integrated Sustainability Appraisal, but it is not explained how. Nothing is said about consulting on other elements of the evidence base.
3 TIMETABLE FOR PREPARING REPLACEMENT LDP
We welcome the recognition that the timetable for preparing the Replacement LDP has had to be put back because of the pandemic. However, this means that urgent issues (such as updating policies to support Council’s One Planet Cardiff strategy) may now need to be tackled through new or updated Supplementary Planning Guidance. The consultation process for such SPGs must be as rigorous as for the Replacement LDP and should not become a means of bypassing that.
Point 5 of the Key Stage table allows 6 weeks for the Preferred Strategy Consultation but paragraph 2.21 states this will last 8 weeks.
4 MONITORING AND REVIEW
Monitoring of the Delivery Agreement should include a mechanism through which residents could raise concerns if they feel they are not being consulted adequately or on time.
The preparation of Annual Monitoring Reports should include resident consultation.
As explained above, the list should be expanded to include the widest range of opinions across the city.
Replacement LDP preparation
The flowchart indicates more opportunities for consultation than those shown in the Key Stage timetable. That is welcome, but stakeholders (including residents and community groups) need to be clearly informed, ahead of time, of how and when they will be able to get involved, and where and when material will be published.
Involvement in Replacement LDP stages
As the evidence base aims at “a clear understanding of the dynamic social, environmental and economic characteristics and issues that exist within Cardiff”, it is important – as argued above – that efforts are made to bring marginalised residents and groups into consultation.
The risk that “Replacement LDP fails test of soundness” is acknowledged. Mitigation should include “a robust evidence base with sustainability appraisal and well audited community and stakeholder engagement”, but it also needs to ensure that stakeholders views are taken account of, and that residents and community groups do not feel that their opinions have been given less weight than those of developers and landowners.
CCS response to LDP Draft Delivery Agreement DRAFT 0.1 Lyn Eynon 23 January 2021 Page 3 of 3