April 2011.
Deposit Conwy Local Development Plan
1.0 Background
The Associations prime objective is the preservation of Bodafon Fields
Llandudno in their entirety in their present undeveloped state. The Association represents several hundred supporters and the representations/objections contained herein have already been conveyed to and endorsed by a public meeting attended by some 150 people at the Craig y Don Community Centre.
1.1 The 1988 appeal inspector’s report
An appeal for a major development on the fields was rejected by the inspector with costs after a public enquiry but does not seem to be worthy of mention in the site selection process. The inspector concluded:-
‘Whilst the appeal site is somewhat featureless its value lies in that it represents an area of open countryside which extends from the Nant y Gamar hills almost to the shoreline. It is an extensive area which when viewed from close quarters or afar serves to emphasise the juxtaposition of this coastal resort with its rural hinterland. Clearly it also provides a break between Llandudno and Craigside. In visual terms the site is a feature which contributes significantly to the town’s setting and separates it from the developed areas to the east.
I am satisfied that the site has quite properly been identified in the approved structure plan and adopted local plan as an area where conservation of the existing rural character of the landscape is of primary concern’.
Several subsequent attempts to develop the fields have failed, been withdrawn before final decision or aborted by the developer.
2.0 THE OBJECTION
Housing, Hou.1, 1.8 hectares Nant y Gamar Llandudno (site ref; 413. 116 (SR85)
See also Map 2, and BP21, Table 12 Contingency sites.
2.1 For the reasons given below this housing proposal is strongly opposed
2.2 Summary.
This housing proposal which was not in the 2009 version of the plan has been inserted at a late stage without any reference in any documents to the landscape conservation status or the agricultural land classification of the site and without consultation with the community or the Town Council until 2011. The land take of prime farmland will reduce the viability of the farm which already relies heavily on diversified activities and the housing will add significantly to the already heavy traffic flows generated by Ysgol Gogarth and the mental health centre ‘Roslin’ both situated on Nant y Gamar.
2.3 The Housing Strategy- Llandudno hierarchy.
The consultants’ (Baker Associates) report BP3, Appx. 1 and 2 recommends
6800 dwellings to satisfy the housing need to 2022 plus a further 1100 units to support job creation, reduce average age and satisfy 37% of the assessed AHLN.
The Council have accepted the 6800 + 1100 recommendation in total. 90% of the total is allocated to urban areas. The detailed allocation by Conwy over urban hierarchies is incremental and subjective with scant evidence of each hierarchy’s needs. There is an unreasonable rigidity of hierarchies for monitoring, delivering and phasing the Plan. The hierarchies of Llandudno, Penrhyn Bay, and Deganwy/Llandudno Junction are all within a four mile radius of each other.
To be sound and comply with other plan policies phasing should be on the basis:-
1. Previously developed land
2. Greenfield sites / inferior agricultural land.
3. Greenfield sites comprising grade 3A or better land.
4. There should be flexibility between the above hierarchies to
deliver the above phasing patterns ,achieving overall housing
targets without strictly adhering to an individual hierarchy’s
target thereby conforming with other policy requirements and making the plan fair and sound in that respect.
.
2.4 Nant y Gamar (413/116) site selection.
This site was allocated at a late stage in 2010 after the 2009 consultations were closed.
At stage 2 of the site selection process, under ‘constraints’ this site only quoted ‘Proposed
green wedge’.
The site is designated:-
A Landscape conservation area – Llandudno Conwy Local Plan 4AY
“ “ “ Gwynedd Structure Plan (GSP) D 3.
Restricted development LLCLP- 4BW
Agriculture Land Class 3A PPW 2.8.1., GSP D7, LLCLP 4GR and may also be a
Green Wedge? LLCLP 4Y
There is no documentation whatsoever to indicate that these factors were made known to and considered by elected members or officers as part of the selection process and
do not appear to have been given any weight in the process. This is contrary to stated policies in BP.1, BP.21 (6.2.2. and 6.2.3) and PPW 2.8.1 and means their inclusion is unsound having had inadequate consideration, and less than other similar sites in the plan.
In BP.21 table 4.11 contingency sites – urban, there is a similar omission for site 413/116 (SR85), where there is no reference to ALC, in contrast to, ( e.g.) sites 67/347/353, 37/38, 91/284, 79/80 (SR73), and 344(sr110). where ALC has featured.
BP21, para. 4.23 Table 6, lists inter alia ‘any relevant planning history and status in local adopted plan’ as stage 2 assessment criteria. These criteria have not been demonstrably
observed in this case, making the selection unfair and unsound.
The Council have also failed to properly evaluate Agricultural Land Class in a number of
sites taken out of plan in the Llandudno and adjacent hierarchies. Sites 117/210, 118, and122/144 fall into this category where specific site assessments have not been conducted (Revised guidelines MAFF 1988) and only large scale map classifications
which do not subdivide grade 3 into 3A (Protected) and 3B (Inferior) and are unsuitable for site selection are available. This adds to the unfairness as Bodafon has been specifically assessed as 3A.
2.5 Farm Viability (TAN 6 W 2010)
The farm area is 40 hectares. The coastal zone (10. ha.) is mainly used for tourism- Caravans, transport festival etc. and is only available for grazing. The Golf Range (5.5.ha) can only be used for grass cuttings for animal feed; the Rare Breed Farm (4.5.ha.) is grazing only and the proposed housing and school field remove a further 2 hectares from agriculture. Thus 22 out of 40 hectares have very limited use leaving only 18 hectares for intensive farming. Yet There has been no TAN 6 viability assessment before selecting this site for housing.
2.6 Traffic and services
Nant y Gamar is already heavily congested especially at peak times because of traffic generated by Ysgol Gogarth and the mental health centre ‘Roslin’. Both these also give rise to considerable on street parking during working hours. Site selection is silent on this issue
but 65 dwellings will add significantly to this problem and cause rat runs through residential streets to reach county and trunk roads.
Services in the area are overwhelmingly busy or absent. There is no NHS dentist, It is difficult to get a G.P. appointment, and primary schools are full to capacity.
2.7 Consultation
The objection site was allocated in mid 2010 after all consultations had closed. Thus other areas of the County have had opportunity to make substantive representations and have those representations considered, whereas the Craig y Don and Craigside communities have had no consultation until March 2011. This housing site has been allocated by officers
despite well known and well documented strong community opposition, e.g objections to the 2001 UDP; to the Trams/housing application (0/22641) 1996/7 and to the revised application (0/21128 ) 1998/99.
The Association was supportive of the 2009 plan which made the whole area a green wedge but indicated it would wish to comment on any changes.
At a public meeting at the Community Centre on 5th April, attended by over 150 people, there was an unanimous vote showing that people had very strong feelings about not being consulted and therefore not being part of these plans being imposed upon them.
Section 3, Record of Consultation in the Consultation Paper lists delivery agreement requirements. Following the very late addition of this very sensitive site to the Housing lists
There has been no community involvement and sections 1, 11, 111, V, and V11 of the delivery agreement have not been met.
2.8 Conclusion
The failure to demonstrate due consideration and weight to agricultural land classification
in formulating the housing strategy has created an overriding housing need in the Llandudno hierarchy and consequent greenfield land grab of protected farmland which need not have arisen to deliver the Housing strategy. Similarly the failure to show proper consideration for landscape conservation and ALC, together with a total absence of
consultation both with the Llandudno Town Council and the communities of Craigside and Craig y Don, makes the inclusion of the Nant y Gamar site both unfair and unsound.
The Association and its supporters realise that a great deal of effort has gone into
preparing this plan and recognise the serious need for a Local Plan for Conwy. Most of the above objections and the statutory form and tests of soundness are site specific.
The Association could therefore withdraw its objection if the Nant y Gamar site (413/116 (SR85)) was deleted from the plan and the whole of Bodafon Farm including this site was designated a green wedge for the duration of the Plan.
The Association requests that its representative(s) be permitted to address the public enquiry if necessary in particular to respond to any comments made by Conwy Council in relation to this objection.
A petition arranged by the Association has been formally conducted with statutory forms and tests of soundness attached for inspection by all signatories and should be considered alongside this representation to appreciate the strength of feeling against this housing allocation.