Office Use Only

Cardiff County Council

Local Development Plan 2006 2026

Date Received

Deposit Plan Comment Form

Representor Number

Please use this form to make your comments on the Deposit Plan. If you are unable to complete the online form you can photocopy this form or download copies from the website at www.cardiff. ov.uk !ll completed forms should be returned by midnight Tuesday 26 November 201 to" LDP #eam$ %oom 22& 'ounty (all$ !tlantic )harf$ 'ardiff$ '*+0 ,-) or email LDP.'ardiff. ov.uk

P!"T 1# Contact details

$our% your Client&s details #itle" /ame" 1ob title" (where relevant) 3r anisation" (where relevant) 'llr 0raham #homas 'ouncillor for 'rei iau and 2t *a ans !gent&s details (if relevant)

!ddress" #elephone no" 7mail"

'ave Creigiau !ction (roup Committee : Wynford Ellis Owen, Graham Thomas, Bryn Jones, Stuart Thomas, Nikki Howard, Sian Hughes, Ian Bu kland, !red "a#ies, Jeff "a#ies, John $ahill "i kenson, Harold Newman, "a#e Judd% c4o 'ounty (all$ !tlantic )harf$ 'ardiff 0&506 5605+2 0raham.thomas.cardiff. ov.uk

Please note that all representations will be made available for public inspection and cannot be treated as confidential. (owever to ensure data protection we will remove personal details from publically accessible documents

2i ned"

Date"

26th /ovember 20+8

Part 2# Commenting on the Plan

#he 'ardiff Local Development Plan 9LDP: will be e;amined by an independent Inspector appointed by the )elsh 0overnment. It is the Inspector<s =ob to consider whether the Plan is sound. #here is no le al definition of >sound> but in this conte;t we use its ordinary meanin of >showin ood =ud ement> and >able to be trusted>. #he ?uestions or >tests> which the Inspector will consider in decidin whether the Plan is sound are in Part 6 of this form. It may help you to read them and the uidance in Part 6 before you tell us what you think of the Plan and its policies. @efore you set out your comments in detail$ it would be helpful to know whether you think the Plan is sound$ or if you think that all or parts of it are unsound and need to be chan ed. I think the LDP is sound I think the LDP is unsound and should be chan ed If you think the plan does not meet one or more tests of soundness 9see Part 6:$ it would be helpful if you could indicate here which test9s: you consider it does not meet. Please note if you do not identify a test it will not mean your comments will not be considered.

2a )hich part*s+ of the Plan are you commenting on,

If you want to add a new policy$ para raph or te;t$ please set out clearly in Part 8 where you think it should o in the Plan. Policy number*s+
9and%or+

Paragraph or section number*s+

*and%or+

The Proposals -ap (please tick )

*and%or+

!dd a ne. Policy

*and%or+

!dd a ne. paragraph or te/t

2b !lternative 'ites
#he 'ouncil must consult on all site allocation representations received which seek to chan e the Deposit Plan by either addin a new site$ alterin or deletin a proposed site. #his will ensure that all information related to site allocation representations has been treated the same as the Deposit Plan. 0t is therefore essential that you clearly indicate if you are submitting a site allocation representation belo.1

!re you proposin to" A#ick all that applyB !dd a new site !lter a proposed site Delete a proposed site

If you want to su est a new site please attach a site plan identifyin the boundaries of the site you wish to be included in the Plan with a red line and provide details of its proposed use. 3n this plan please also identify other land in your ownership usin a blue line. If you are proposin a new site it should be accompanied by a sustainability appraisal. #he appraisal should use the same sustainability framework as set out in the 'ouncil<s 2ustainability report on the Deposit Plan. #his information must be consistent with the scope and level of detail of 'ardiff<s sustainability appraisal. It should also refer to the same baseline information in identifyin the likely si nificant effects of the revised policy or new site. Please follow the link below to view the 'ouncil<s 2ustainability !ppraisal. www.cardiff. ov.uk4localdevelopmentplan

If you want to add, amend or delete a site, did you submit the site as a Candidate site? If so, please give the Candidate Site name and reference (if known). he Candidate Site !egister can be viewed at" www.cardiff. ov.uk4localdevelopmentplan 'ite name 'ite "eference
2I#7 7 /3%#( 3* 1C-/'#I3/ 88 !/D 2I#7 * 23-#( 3* '%7I0I!-

Part # $our comments and suggested changes

Please set out your comments below usin additional sheets as necessary. If you want chan es made to the Plan$ please be specific. *or e;ample$ if you want new te;t added$ please set out the new te;t and e;plain where it should o in the Plan. If you want chan es to the Plan$ we will assume you do not consider the Plan to be sound. (owever$ please note that it is not the role of the Inspector to make an acceptable plan better. If you do not consider the Plan to be sound and that it should be chan ed$ please e;plain clearly why you think the chan es are needed. If you think a chan e is needed for the Plan to meet one or more tests of soundness$ please tell us which one9s:. Dour comments should be set out in full on this form. #his will help the 'ouncil and the Inspector to understand the issues you raise. Dou will only be able to submit further information to the 7;amination if the Inspector invites you to address matters that he or she may raise. Please note that the Inspector will not have access to comments you may have made in response to previous consultations$ you cannot rely on submissions made at previous consultation sta es as the Inspector is not bound to consider them. If you seek more than one chan e and consider the Plan fails to meet more than one test of soundness it is not necessary to complete separate forms. (owever it would be helpful if you used separate forms if you wish to make comments both ob=ectin to and supportin the Plan.

'ubmitting !dditional 0nformation

Please tick this bo; if you have submitted additional material to support your comments. If submittin additional material please supply both an electronic and paper copy.

$our Comments
Please state your representation$ includin how you would like to see the Plan chan ed$ with your reasons. Do not for et to enclose any relevant documentation 9for e;ample a sustainability appraisal for an alternative site: with this form.
Save Creigiau is a campaign group established in 2012 following the publication of the preferred strategy for Cardiff LDP and the immediate concerns of local residents. he group has held ! separate and widely advertised public meetings in Creigiau to establish the feelings of Creigiau village residents and the surrounding areas towards the Local Development Plan. "ll three meetings were very well attended with appro# 1$0 people attending each% the last of which was held on &ovember 10th 201!. he group has '!( )aceboo* and witter followers% with whom we engage with on a daily basis% and who demonstrate almost unanimous support for our position. +Save Creigiau, Steering -roup is open to all% and represented by a team of appro#imately 20 residents of the village% without political influence. he comments made in this document reflect responses made to us from village residents. hese comments have been discussed at the public meetings% through various leafleting and email campaigns% in the local community newsletter +Community Lin*,% and on social media% including )aceboo* and witter. Save Creigiau recognises the need for an LDP and accept that Cardiff has to grow and sustain its ma.or economic role as the capital city. " substantial amount of wor* has gone into drafting the Deposit Local Development Plan into master/planning and into parallel studies% in particular those on sustainable transport. 0owever it is clear that the timeframe for developing the Plan has not allowed the proper integration of all these elements. he LDP needs greater clarity and selective changes / not more words / to ma*e sure that it provides a framewor* to deliver a sustainable city for future generations that is truly worthy of the title 1uropean Capital. 2e want the LDP to improve the 3uality of life of both e#isting and new communities and highlight below some of the *ey issues we have identified. 2e feel that sites D 4 1 should be considered as one% as they in effect lead to development on both sides of the "511(% leading not so much as an e#tension to Creigiau village% but its envelopment and the development of a new town on the border of another massive development% Site C north of St )agans. 6n addition% the proposed e#pansion of communities in 7C and the 8ale of -lamorgan are in very close pro#imity% compounding the situation. he logistic% transport environmental and sustainable impact of such an e#tensive new development in a current rural setting have not been presented% and a cohesive strategic plan has not been produced in its support. We are concerned that the Deposit LDP is neither sound nor sustainable because: 9i: 9ii: the level of house building is unli*ely to be delivered in the 1! years remaining of the current plan period% and could well result in an unsustainable pattern of development ; the transport strategy cannot provide sustainably for the scale of development proposed in &orth 2est Cardiff and the plan,s details on new infrastructure re3uired are vague and provide no certainty of delivery; the $0<$0 modal splits is totally aspirational in rural communities. here is no detail on what will happen to cars users on already over congested road networ*s% such as the "511(% with an e#plosion in use% even if all the new developments are less reliant on these roads; the 2elsh Language has not been ta*en into account when formulating the Deposit LDP% particularly in Creigiau% where it is the fabric of the local community with !0= 2elsh spea*ers. " massive house building programme as proposed would triple the si>e of the village and lead at the very least to dilution of 2elsh as valued by the community and re3uired in "& 20 guidance
6

9iii:

9iv:

; 9v: the funding needed for the scale of infrastructure investment in &orth 2est Cardiff is unachievable. he developers are e#pected to provide funds to pay for facilities costing hundreds of millions before any commitment to construction. 6n the current economic climate it is difficult to see how this can be seen to be realistic; Loss of valuable green space and increased air pollutions is detrimental to the health and mobility of rural areas.

9vi:

2e call for the following considerations to be made to the Deposit LDP% to mitigate these factors% and provide for a more sustainable approach to the &orth 2est of Cardiff. 1. 1nvironmental < he air pollution from this development will contribute to Cardiff,s e#isting air pollution problem 9construction phase and permanent: as it,s upwind of the prevailing westerly. "ny P?10% P? 2$ and fuel emission 9cars@boilers: will generally be blown into the Cardiff City basin. Cardiff is already struggling to meet air 3uality targets; it may be the difference that causes regular failure. -reen Aelt < 2e are e#tremely disappointed that the new -reen Aelt designation% which has been added after the preferred strategy stage% stops .ust short of Creigiau. -iven the rural nature of all the land &orth of ?5 Corridor% it is logical that the ?5 should be natural physical border and a +hard line, for a green belt. "ll land north of the ?5 be should be designated a -711& A1L area. he -reen Aelt in the current Deposit LDP% although welcome as a means of giving some of the city,s green spaces more protection% doesn,t go far enough. 2hilst the 2012 &ational Planning Policy )ramewor* clearly states that one of the *ey ob.ectives of a -reen Aelt is to Bchec* the unrestricted sprawl of large built/up areasC% the -reen Aelt proposed in the Deposit LDP applies to mountainous land that is not at ris* of large/scale or strategic development anyway% such as the Caerphilly ?ountain 7idge% -arth 0ill% and Pentyrch 7idge. Creigiau% on the other hand% being an area of low/lying countryside% 9with no less than three +Sites of Special 6nterest for &atural Conservation,% an ancient woodland% agricultural grade land% and many routes for wal*ers: is clearly at ris* of Dunrestricted sprawlD from nearby urban areas. 6f Cardiff Council were serious about Bsafeguarding the countryside from encroachmentC% which is another -reen Aelt ob.ective included in the &ational Planning Policy framewor*% it would have surely e#tended the proposed -reen Aelt to include Creigiau. he inclusion of a -reen Aelt would prevent the coalescence of Cardiff with 7C and give both local authorities the opportunity for further dialogue in terms of allocation of housing for their e#pected growth patterns. "part from the strong physical border arguments above% this would also protect the small% 2elsh spea*ing village of Creigiau from being swamped by over development and urban sprawl and thus achieve the following vital protection factors </ E E E E 2. Creigiau should retain its village heritage for current and future generations. Preservation of bats% newts% ancient woodland and other e#isting environment and other local wildlife and protected species. Preservation of green fields for people to en.oy now and in the future% which are also visible from traffic passing along ?5 preserving the green image of the city. Preservation of S6&Cs% and local woodland. Surrounding ancients woodland surround building to its ecological decline.

ransportation )actors < Last year a report from TPA (Tranport Planning Associates) showed a 50/50 split to be impossible

to deliver given the extra demand generated by new development and the lac! of alternative p"blic transport services#$ %"ch a dramatic shift in modal split is "nli!ely even if there is good provision for wal!ing and cycling extra local b"ses and &"s 'apid Transit beca"se of the high fre("ency of rain the levels of wor!place par!ing and the n"mber of lin!ed trips "nderta!en for school wor! and shopping# )aving a rail or a tram train in place prior to the development of new comm"nities will ens"re that layo"ts and orientation of footpaths provide safe and convenient to stations and stops# Attempting to retrofit s"ch access is neither easy nor cheap# &"ilding in the infrastr"ct"re from the o"tset will help to create ("ality living environments comparable with the best of *"ropean cities# +t wo"ld also help if employment ho"sing and other facilities are located in close proximity to give the potential for shorter ,o"rneys to wor!# *mployment sites s"ch as the &"siness Par! north of the -. /n 00 sho"ld be served by high ("ality p"blic transport giving the opport"nity for people to travel to wor! by s"stainable modes and to balance inbo"nd and o"tbo"nd comm"ting flows to improve long term service s"stainability# +t wo"ld not be possible to deliver s"stainability if any ma,or retailing is allowed in o"t1of1centre employment locations so the policy to disco"rage this is welcomed# 2ithout any new highway proposals% how does the Deposit LDP deal with the ac*nowledged increase in road trafficE Proposals for more efficient use of the e#isting road/space focus around provision on bus lanes. he plan continually fails to address the needs of car based traffic% which is by far the biggest factor in transport planning. ?any of the local roads are narrow and unsuitable for today,s level of use. Cycling and wal*ing are not practical choices for the ma.ority of people living in Creigiau% where commuting .ourneys are generally too long in distance and routes are too dangerous routes. his means it will always be car dependent area. 6t is absolutely vital that the LDP anticipates and is consistent with the City 7egion approach to planning being developed by 2elsh -overnment. he long/term plans of each of the authorities are li*e a .igsaw that will together form a coherent picture of the future for the region. "t present it is not clear how these plans are to be pieced together. he LDP is heavily dependent and lin*s closely with the ?etro scheme being developed by the 2elsh "ssembly. 0owever% the timing of both pro.ects in incompatible with the LDP in 201$% and the ?etro suggested to be done for 202$ at the earliest. his lin*s in with our phasing argument which is detailed below. "ccess to public transport within Creigiau and the surrounding areas is very limited. he proposed motorway .unction access is strongly opposed as it will turn Creigiau into a rat run for commuters from 7C . Since the opening of the Church 8illage by/pass there has been a dramatic increase in the number of cars using Creigiau as a short cut to access the "511(% raising health and safety issues for residents. Function !! is already a ma.or pinch point in the City for commuters and visitors to the city for ma.or events and other activities. Putting more traffic through this interchange needs serious planning and investment to ma*e improvements to allow better traffic flow.

!. 2elsh Language Protection G "&20 Save Creigiau has a particular interest in the soundness of the LDP in relation to the historic environment. Creigiau is a village whereby the 2elsh Language is defined by planning regulations to be +part of the fabric of community,. 6n the latest census report appro#imately !0= of residents in the village classified themselves as 2elsh Spea*ers. echnical "dvice &ote 20 9 "&20: rules have recently been revised to strengthen and define the meanings. 1ven under the previous "&20% local authorities are re3uired to consider whether they had communities where the use of 2elsh was part of the social fabric. 6n Creigiau the 2elsh Language clearly is part of the social fabric and thus we must ta*e into

account the needs and interests of the language in formulating the policies set out in the Local Development Plan. 2e therefore consider that the two sites south of Creigiau 9Sites 1 and ): do not ta*e this into account as e#panding the village envelope so dramatically can only results in mass migration into the village from non/2elsh spea*ers. he village envelope has e#panded over the years at a sustainable rate which maintains the identity of the village as 2elsh Spea*ing. 2e do not have an issue with limited levels of development in an organic manner but this forced placement of a town three times the si>e of the e#isting village 9sites D 4 1: will threaten the 2elsh language so proudly represented by all residents. 5. 6nfrastructure &ew schools < &ew schools should be ready to meet the demands of the new communities. )or the &2 Cardiff e#tension% we note that e#isting schools in Creigiau are full and could not cope with an e#tended catchment% however temporary. Sewerage in Creigiau is already overstretched with Councillors and Community Councillors getting regular reports of overflowing foul drains% flooding in e#isting boggy fields and sewerage spilling out onto residential areas. Surface water problems are not addressed in the LDP and are a common occurrence locally. Auilding more houses reduces further the natural drainage and will e#acerbate the e#isting flooding. 2hat is the evidence that sufficient C6L funds can be raised to cover the costs of new facilities and infrastructure before any houses are put into placeE $. 0ealth < &ew health facilities% especially primary care% should be ready for new communities what is the evidence that sufficient C6L funds can be raised to cover the costs of new facilities and infrastructureE he 2elsh "mbulance Service% for ! of the last 12 months% have not met the H0= target of reaching patients who were seriously in.ured% or had life threatening conditions such as a heart attac* or stro*e 9Category " call out: in I minutes. 2ith much more traffic in &2 Cardiff this would seem to confirm that peopleJs lives could be at ris* in the worst case scenarios. a*ing into account that Creigiau patients may have to go to the 0eath 0ospital and not 7oyal -lamorgan 9as could happen / result of the "41 review is awaited: this situation could only worsen. he Council have a duty of care to Council a# payers. he benefits of green spaces to health and the economy are now well documented. he benefits of access to green fields and open spaces were highlighted in the ?arch 2012 &0S 2ales 7eport B-reen space% reduction of health ine3uities% and cost effectiveness of interventions.C he &ational 1cosystem "ssessment details the social% economic and health benefits of the countryside; Bcontact with nature gives pleasure% provides recreation and is *nown to have a positive impact on long/term health and happiness.C he proposed developments on greenfield sites will ta*e the countryside and its benefits further away from many residents. here will be a clear negative impact on the 3uality of life for local residents with increased air and noise pollution. H. Deliverability )actors < Phasing. Priority should be given to Arownfield and 2indfall sites% and utilising further the thousands of empty properties across the city% and then to sites with e#isting ade3uate infrastructure. Sites with little or no e#isting infrastructure should not be brought into development until their infrastructure is in place% re/enforcing the Councils own position as it identified as a red concern. " strongly phased approach is essential to give the council ade3uate control over to ensure the progress
!

of development is consistent with the city,s changing needs. Knce sites are put forward for development% it is very difficult to revo*e them further down the line. he first phase should be for those sites in which the infrastructure is already better placed to cope with the additional demands. )ollowing this% later phases should include those sites where considerable infrastructure is re3uired. 6n the final phases of the plan% those areas that represent concentrated areas of largely residential land use% especially on greenfield sites% if it proves absolutely necessary to do so. he forthcoming &ational Planning Aill will re3uire greater coordination on a regional basis. he council should be anticipating this by coordinating this plan to a much larger e#tent with our five neighbouring authorities. he lin*s with 7C are of particular importance and should be fully discussed before the plan is completed. 2e *now that neighbouring authorities such as 7C and Caerphilly are under/delivering on their plans because of this lac* of cohesion between Councils. Cardiff will suffer adversely because of this and the phasing approach demonstrated above could allow for future changes in &ational Planning Policy. 2e call for the total removal Site 1 South of Creigiau as a strategic site. Creigiau as a village would need massive infrastructure investment to allow even this level of e#pansion due to the capacity of e#isting service such as sewerage and school. he H$0 houses allocated to this site could be easily absorbed by the plan in other location in particular 2indfall Sites and better use of Arownfield Sites. he ACC and 0 8 site studios are both e#amples of the potential other areas that will occur during the period of the plan. Creigiau as a 2elsh Spea*ing area needs better protection from large scale e#pansion and as such the belt of land should be allocated -reen Aelt Status as described in this response. his would comply with "&20 regulations to not adversely impact on the language as a fabric of the community. his site in particular is very damaging to the character of the area and is unnecessary urbanisation of the rural areas. 6t should be left out of the plan or at the very least used in a phased approach as a site when all other have already been fully utili>ed. he 2ales Spatial PlanJs outlines the need to designate Llantrisant 9and ?wyndy@ albot -reen: as a Strategic Kpportunity "rea G this is being totally ignored by developing Creigiau so close to these areas.

Summary he deposit LDP will affect the 3uality of life in a negative way for everyone that resides in this area. 2e are concerned about the detrimental impact it will have on family life% with parents and commuters having to leave much earlier and returning much later. Precious time spent with family will be lost and never recovered% due to the poor timing of planning and infrastructure. 2e as* that concerns raised by local residents are ta*en into account and ad.ust the plan accordingly.

P!"T 2# )hat happens after Deposit,

!t this sta e$ you can only make comments in writin 9these are called >written representations>:. (owever$ everyone that wants to chan e the Plan can appear before and speak to the Inspector at a Fhearin session< durin the Public 7;amination. @ut you should bear in mind that your written comments on this form will be iven the same wei ht by the Inspector as those made verbally at a hearin session.

#a $o you want your comments to be considered by %written representations& or do you want to speak at a hearing session of the 'ublic ()amination? ('lease tick one of the following) I do not .ant to speak at a hearin session and am happy for my written comments to be considered by the Inspector. I do .ant to speak at a hearin session. #b If you wish to speak, please confirm which part of your representation you wish to speak to the Inspector about and why you consider it to be necessary to speak at the *earing.
As an elected representative of Creigiau and St Fagans, I believe that I have a duty to articulate in person the strength of feeling against the proposed Cardiff L !"

P!"T 3#

(uidance Notes

+. #he Plannin and 'ompulsory Purchase !ct 200, states that the purpose of the 7;amination of a Local Development Plan 9the Plan: is to consider whether it is GsoundH. #his means that anyone who wants to comment on or ob=ect to the Plan should seek to say how it is unsound and what is needed to make it sound. 2ound may be considered in this conte;t within its ordinary meanin of G showing good #udge$ent% and &able to be trustedH. #o assess the Plan +0 tests are used. #hese tests are set out in Part 6 of this form. 2. )here you propose a chan e to the Deposit Plan it would be helpful but not necessary$ to make clear which test9s: of soundness you believe the Plan fails. #he tests are in 8 roups Fprocedural< 92 tests:I Fconsistency< 9, tests:I and Fcoherence and effectiveness< 9, tests:. If you wish to comment on the way in which the !uthority has prepared the Plan$ it is likely that your comments or ob=ections would fall under one of the procedural tests. If you wish to comment on or ob=ect to the content of the Plan$ it may help to look at the Fconsistency< and the Fcoherence and effectiveness< tests. 8. *ailin to identify a test will not mean that your comments will not be considered$ providin it relates to the Plan 9or part of the Plan: and it is clear what chan e9s: you are seekin . Dou should include all your comments on the Plan and set out your full case on the form$ usin accompanyin documents where necessary. If you seek more than one chan e and consider that the Plan fails to meet more than one test of soundness it is not necessary to complete separate forms. It would help if you use separate forms if you wish to make comments ob=ectin to part of the Plan and in support of other parts of the Plan$ but a ain only one form is necessary to e;press support for different parts of the Plan. ,. )here a roup shares a common view on how it wishes the Plan to be chan ed$ it would be helpful for that roup to send a sin le form with their comments$ rather than for a lar e number of individuals to send in separate forms repeatin the same point. In such cases the roup should indicate how many people it is representin and how the representation has been authorised.

P!"T 6#

Tests of soundness
Procedural Tests P It has been prepared in accordance with the Delivery ! reement includin the 'ommunity Involvement 2cheme. #he plan and its policies have been sub=ected to 2ustainability !ppraisal includin 2trate ic 7nvironmental !ssessment. Consistency Tests ' It is a land use plan which has re ard to other relevant plans$ policies$ and strate ies relatin to the area or to ad=oinin areas. It has re ard to national policy.

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It has re ard to the )ales 2patial Plan. It has re ard to the relevant community strate y4ies 9and /ational Park Jana ement Plan:. Coherence and 4ffectiveness Tests

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#he plan sets out a coherent strate y from which its policies and allocations lo ically flow and4or$ where cross boundary issues are relevant$ it is compatible with the development plans prepared by nei hbourin authorities. #he strate y$ policies$ and allocations are realistic and appropriate havin considered the relevant alternatives and4or are founded on a robust and credible evidence base. #here are clear mechanisms for implementation and monitorin . It is reasonably fle;ible to enable it to deal with chan in circumstances.

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