Wayne David

Member of Parliament for Caerphilly

Local Development Plan submission

Response to Caerphilly County Borough Local Development Plan by Wayne David, MP for Caerphilly,
Jeff Cuthbert, former AM for Caerphilly, and Hefin David, Labour Assembly Candidate for Caerphilly

  1. The three of us have received hundreds of representations from people concerned about the draft Local Development Plan (LDP). By far the greatest number of comments we have received are concerning the suggested developments to the east and south east of Caerphilly town. Concern has focussed on Gwern-y-Domen, Plasnewydd Farm, Nant y Calch Farm and the bypass.

  2. We believe that the concerns that people have expressed, forcefully and articulately, are well founded and must be taken seriously by the planning authority. We would hope that the LDP is substantially modified in the light of the representations which have been made. Of course, it is up to the local authority to determine what is submitted to the Welsh Government and its inspectors, but Caerphilly County Borough Council, like any other local authority, must take heed of strongly held and genuine views which are being cogently argued. We believe that the opinions expressed by Caerphilly residents therefore need to be taken seriously and acted upon.

  3. One of the fundamental concerns that we have is that the local authority is placing far too much emphasis on the development of the Southern Connection Corridor (SCC), particularly to the east and south east of Caerphilly town. It is widely accepted that the Caerphilly Borough is already suffering from unbalanced social and economic development. The top part of the Rhymney Valley in particular is afflicted by acute depopulation, as the area in and around Caerphilly Basin is experiencing a growing population. Instead of simply accepting the pull of market forces, the local authority should be working with others to put the case for intervention to ensure that industrial and social development is more equally spread throughout the length and breadth of the Borough.
  4. In the wake of the economic and social dislocation of the colliery closure programme, following the Miners’ Strike of 1984-1985, the then Welsh Office undertook a number of measures which sought to address the consequences of the decline of the coal industry. These measures were piecemeal and inadequate, but they did seek to give local authorities the means to help ensure that housing development, for example, was located in areas of the greatest social need, not where developers could make the greatest profits.

  5. The time is surely right for local authorities throughout South Wales to link up to make the case for more strategic interventions. The bottom line is that there are many brownfield sites throughout the upper Rhymney Valley which could be developed if there were financial incentives for private developers. Moreover, the upper Rhymney Valley, with its spectacular and beautiful scenery could become an attractive place to live once again if there were quick and efficient transport links to Cardiff (see below). This is an important argument because it is certain that new private and social housing is needed and will continue to be needed well into the future.

  6. Ensuring that the economic prosperity of Cardiff, which is set to continue to be one of the growth centres of the UK, is spread throughout the region is central to the economic strategy of the Welsh Government. Central to the concept of linking Cardiff to its hinterland is the South Wales Metro. This is one of the most ambitious transport projects of its kind and progress is being made to continue to take the project forward. It has been suggested that an integrated transport metro system could be in place by 2025 and many small valley communities would be connected to the Cardiff hub with an unprecedented travel time. It is anticipated that the connection time between Rhymney, at the top of the Rhymney Valley, and Cardiff city centre will be under 50 minutes. At present, the journey time is 1 hour. Such an improvement in the journey time (and the quality of the experience) will provide a huge increase in the desirability of being domiciled in the upper Rhymney Valley.

  7. Such is the stimulating potential of the Metro that when Cardiff itself is better connected, economic growth could be unleashed in the Caerphilly Borough and other adjacent areas. A report from the Centre for Cities (Right Track and Beyond the Boundaries, 2010) has made the point that as well as contributing to Cardiff’s economic performance the ease of effective travel from work to home would help to disperse housing away from the urban core. Crucially, this would mean that people living in the outer areas of the South Wales valleys, and not merely in and around Caerphilly town, could reside in valley communities and travel to work cheaply and quickly. 1.4 million people live within a 20 mile radius of Cardiff city centre and the economic and social potential of harnessing this latent capacity is huge.

  8. Cardiff has the potential to become a truly great European city and it must be Caerphilly CBC’s objective to make sure that the Rhymney Valley is a central part of that vision. Not long ago Wayne David visited Barcelona. This city is undoubtedly one of the most dynamic cities in Europe, providing an exciting and stimulating focus for the whole of Catalunyaand beyond. One of the most striking features of Barcelona is the way it is linked into an arch of contributory economic hubs, which contribute to and draw strength from the centre. Cardiff and its hinterland needs to develop a similar kind of encompassing perspective for the future.

  9. Increasingly the quality of life is determined in large part by the physical environment. The increasing popularity of rural recreation and sport testifies to the fact that more and more people appreciate the importance of the countryside. It is therefore of concern that the LDP proposes the construction of housing on some of the most important, and indeed beautiful, areas of countryside around Caerphilly town. The Gwent Wildlife Trust feels so strongly about this issue that it has urged members of the public to make representations to the local authority about the need to protect the wildflower meadows and ancient woodland from the proposed development.

  10. Gwern-y-Domen, Plasnewydd Farm and the area around Nant y Calch Farm area are also rich in wildlife including bees, butterflies, a rich variety of birds, and small mammals, including hedgehogs, dormice and bats. Foxes have also been seen in the area. Nant y Calch Farm, located on the lower part of Caerphilly Mountain is especially visually attractive and can be seen from many other parts of the Caerphilly Basin. Indeed, if there were extensive housing and light industrial development and a bypass in this area, it would change for the worse the character of the entire Caerphilly Basin.

  11. One of the concerns of many people is the inadequacy of the transport infrastructure in the area of proposed development. There is already a strain on the road network during peak travelling hours and other likely developments, such as in Waterloo, will only increase the pressure. To address this problem the LDP suggests a new bypass which will pass under the railway line, cut into the hillside and exit on to Mountain Road.  Apart from the despoliation of extremely beautiful countryside, the junction of this road onto Mountain Road is potentially a very real danger, given the steep gradient at this point and the already heavy traffic during rush hours. A junction at the point envisaged would surely add to the already heavy traffic flow and cause severe congestion during peak travel times and thereby create a significant traffic hazard on an extremely steep stretch of road. At the moment this part of Mountain Road is made significantly more hazardous when there are adverse weather conditions and the proposed junction would make the situation much worse.

  12. As well as significant local concerns about the volume of traffic generated by the proposed developments, there is also concern in the north of Cardiff. At present an estimated 10,900 people commute from the Caerphilly area to Cardiff on a daily basis and many travel along the A469 into Thornhill. Cardiff residents have recently voiced concerns about “traffic chaos” should the traffic flow from the north substantially increase. The Cardiff Civic Society, commenting on the plans for the Cardiff LDP, expressed the concern that there was a risk “that Cardiff will acquire a reputation for traffic congestion that will deter investment and degrade the quality of life in the city”. If those concerns were expressed in the context of the Cardiff LDP, they surely hold firm with regard to the impact that the Caerphilly LDP will have on northern Cardiff.

  13. Cardiff North AM Julie Morgan, Cardiff Council and the Civic Society have all campaigned for a green belt north of the M4. The inspector agreed to a green wedge which gives protection for the 10 year length of the LDP. They all believe that it is necessary to help maintain the essential character of the city as well as preserving the countryside. It is of concern that Caerphilly CBC has not proposed the designation of a green belt or green wedge. We believe that such protection ought to be actively considered to the east and south of Caerphilly town.

  14. Importantly, in the agreed Cardiff LDP it is clearly indicated that it is the policy of Cardiff City Council to “work with adjacent local authorities to reduce traffic flow entering the city”. The Cardiff LDP specifically refers to traffic flow from Caerphilly. It can be seen therefore that the proposed developments around Caerphilly run counter to the stated policy intent of Wales’ capital city.

  15. Given that there is an active debate about local authorities being amalgamated and existing local authorities cooperating much more with each other, we strongly believe that Caerphilly County Borough Council and Cardiff City Council ought to initiate joint planning approaches. However, in recognition of different timescales Caerphilly CBC ought to fully take into account Cardiff’s LDP which has already been agreed.

  16. It is also worth making the point that the stark distinctions and contradictions between Cardiff’s agreed LDP and Caerphilly’s proposed LDP demonstrate the need for a ‘regional’ approach to strategic planning. No local authority exists or should develop policy in ‘splendid isolation’ and the onus is on the Welsh Government to ensure that a more strategic approach is adopted in future.

  17. We recognise that in producing this LDP, the objective of the council is actually to limit widespread greenfield development in the south of the borough. The council feels that to not have an LDP that is able to meet housing demand puts at risk any greenfield site, anywhere in the south of the borough that may be desirable to planners. By including limited greenfield sites, it is hoped to limit speculative planning applications in the short term. It is believed that should the local authority turn down such applications on the basis of the existing LDP, they would be very vulnerable to being overturned on appeal due to the high housing demand. Such a scenario could lead to unlimited greenfield development. Nonetheless, it is significant that the overwhelming view of councillors of all parties is that these sites should not be developed and certainly not on the basis of this current LDP system.

  18. With this in mind, we note that the Planning Wales Act 2015 aims to create a planning  system in Wales ‘fit for the 21st Century’ by addressing five key objectives:
    A modernised framework for the delivery of planning services.
    Strengthening the plan-led approach.
    Improved resilience.
    Frontloading and improving the development management system.
    Enabling effective enforcements and appeals.

  19. The Act introduces new powers to designate strategic planning areas and establish strategic planning panels. The strategic planning panel will be made up of members of relevant local planning authorities and other nominated members, and will be responsible for preparing a Strategic Development Plan (SDP), a new sub-regional strategic level development plan.

  20. SDPs will only apply to areas of greater than local significance. General consensus amongst planning officers in South East Wales is that the strategic planning area should include the administrative boundaries of all ten South East Wales local authorities, from Bridgend in the west to Monmouthshire in the east.  However this is yet to be agreed by any of the constituent authorities. Until this is agreed, there will continue to be unbearable pressure on Caerphilly to release limited greenfield sites in order to reduce the risk of planning appeals being won by developers seeking to build in a much wider greenfield area in the South of the borough.

  21. A South East Wales Strategic Development Plan could include strategic allocations, housing provision, transport, employment, gypsy and traveller provision, minerals and waste. This will result in a consistent, effective and efficient approach, reflecting strategic priorities, with key decisions taken once rather than numerous times.

  22. We therefore request that the review of the Caerphilly LDP be suspended until such time as a Strategic Plan for South East Wales can be established. Given the complexity of the objections outlined in paras 1-17, above, it is wise to wait until an SDP can investigate whether these developments are necessary to meet housing demand in the context of a much wider strategic area. It is also vital that residents’ voices are heard in the development of an SDP.


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