Object

Preferred Strategy

Representation ID: 27782

Received: 17/09/2019

Respondent: Dr David Spofforth

Representation Summary:

Concerns regarding:
Scale of Strategic Development Site, Llanrhos village identity lost.
Exacerbation of surface water flooding.
Green wedge lost (settlements merging).
Loss of Grade 3a BMV agricultural land.
Adverse landscape and visual impacts including setting/views Vardre/Deganwy Castle.
Cost:benefit for new school with closure of Ysgol Deganwy.
Traffic, noise and air quality adverse impacts.
Ratio of new houses to jobs created (predicted flat growth) encouraging commuting and second home ownership, exacerbating aging population, strain on services.
Sustainability/quality of development given recent precedent.
Significant adverse impacts on Maes Dolau Caravan Park.
Not all landowners with interest in the land have agreed.

Full text:

We are concerned about the scale of this Strategic Development Site in comparison to Llanrhos Village. The village will lose its identity and character with such a vast expansion. There have been hundreds of new homes built over the last decade within a few square miles and local services are struggling to cope, particularly with regards to the aging local population. Other than the primary school, no new buildings to meet other community needs have been proposed.
There are currently issues with surface water flooding within the proposed development area. Drainage is poor and significant ponding occurs in winter on the fields next to Bryn Lupus Road - flood waters spill over onto Bryn Lupus Road after heavy rain. The development of this land will increase surface water runoff and flood risk for surrounding areas.
The loss of the green wedge means that the local settlements will start to merge and lose their sense of place - which should be the principal function of designated green wedge land. In addition, the development of this site would result in sterilisation of prime agricultural land (predictive mapping places it within the best and most versatile (BMV) bracket at 3a). This land has become an even more important resource locally given the loss of so many hectares of agricultural land already for housing. According to the proposed LDP para 3.14.3 'BMV land should be conserved as a finite resource for the future' and it should be protected from significant, inappropriate or unsustainable development proposals. 3.14.4 'Considerable weight should be given to protecting such land from development because of its special importance...'
The site is located on beautiful open space beneath the historic Vardre and Deganwy Castle Scheduled Ancient Monument and will encroach onto its lower slopes, adversely impacting the setting of, and views to, the historic site from the north-west. It will also adversely affect the setting and views from/to Ty'n-y-Coed and its historic garden areas. The area is of archaeological significance with numerous findspots in close proximity and building over this historic area would adversely affect its archaeological potential.
The proposal for a new primary school would at first seem a positive idea, however we have been told that this would involve the closure of the existing Ysgol Deganwy with the creation of only around 30 additional pupil spaces - around 4 per year group. We would question the use of money to build a new school for such a small net gain, rather than improving the existing school. Parents at Ysgol Deganwy have been promised a significant sum of money to be spent on improving the school for current pupils as some facilities are sub-standard and there is concern that this Strategic Development Site proceeding would halt these proposals. The vital role of Deganwy Playgroup, Out of School Club and Holiday Club (currently in a separate building to Ysgol Deganwy but connected via an internal gate) do not seem to have been considered. There is also the concern that should additional school places not be needed in 2024 that this parcel of land would end up being additional housing. The proposed location of the new school is away from the area where most pupils currently reside and given the topography and unsuitable pedestrian pavement areas on Pentywyn Road, this will be likely to increase private vehicle movements on connecting roads from Deganwy to Llanrhos.
The addition of so many new houses will put a strain on the already busy Bryn Lupus and Pentywyn Roads, with associated adverse traffic, noise and air quality impacts. There would also be issues caused by school runs and parking at school drop-off, pick-up times as is currently an issue at Awel y Mynydd. We would question how this fits in with policy SP/6 'Promoting healthier places in Conwy - b. Reduce exposure of populations to air and noise pollution...'?
The LDP overall has a much greater ratio of new houses (4300 +20% contingency) to be built than new jobs (1800) created - and this site is no different. In the draft LDP it states 'estimates currently put the percentage of the population in Conwy CB who are aged 16-64 at only 56.6% compared to 61.5% in Wales and 62.9% across Great Britain. This leads to high dependency ratios - that is, the number of children/older people for each person of working age. High proportions of dependents in the population can place a strain on the economy and on the social structure of the community. The population structure in Conwy CB is also aging at a faster rate than much of the rest of Wales..' Therefore the creation of such a large strategic site with such a high ratio of houses to employment land (and general lack of jobs in the area!) would seem to be encouraging the aging of the local population or promoting the purchase of second homes/buy-to-lets rather than to provide opportunities for younger families or encourage working age people to move to the area?
In the proposed LDP, the forecast is for employment growth to be flat (para 6.2.4) and with the exception of the Colwyn Bay Tidal Lagoon (a project which is very unlikely to come to fruition), the other 'positive impacts' on employment levels referred to in the proposed LDP are a significant distance away outside of Conwy (Deeside, Menai, Orthios, Wrexham etc). The lack of local jobs means that people who aren't retired/second home owners will have to travel to jobs elsewhere (additional car movements, noise, air quality impacts etc)- even with an improved bus network, the extortionate pricing structure of Arriva for local journeys will mean that the car is the transport mode chosen for anyone who doesn't have a bus pass (e.g. £6.70 single from Bryn Lupus Road to Ysgol Deganwy for an adult and two children over 5 to get to school in a morning).
The new developments built nearby in recent years and up to the present day have all been disappointingly generic, cul de sac designs, reaching bare minimum standards for sustainability and of dubious build quality. Designed to maximise developers' profits while stripping the sense of place away from the area. It is a big concern that this development would be no different. Developments elsewhere in the UK have been a showcase for biodiversity and/or sustainability (e.g. Kingsbrook, Poundbury, BedZed) however, there does not seem to be any mechanism for enforcing more forward-thinking development in this area. On previous local developments, bar the nominal social housing element, the properties have been extortionately priced and out of reach for local people on average salaries (£350k for a 4 bed house in the Sychnant Pass development!!) which again attracts those retiring to the area or second home owners/buy to lets. According to the proposed LDP (para 6.2.5), 'In Conwy CB employment in the high skills, high wage sectors... is relatively low, totalling just 13% of all employment compared to 25% across Great Britain as a whole'. So who exactly can afford to move into this development, and what will it do to the local area, pressure on already strained services etc??
On initial plans of what the site could look like, it's noted that the skate park and play area is hidden away from houses and any roads - we have lived on a similar development before and the recreational facilities became a centre for anti-social behaviour. We would be concerned that a poor layout for this site such as this could increase anti-social behaviour in the wider area.
The proposed development area completely surrounds Maes Dolau Caravan Park, a large and popular caravan site with guests who come to the area and contribute a lot to the local economy. They come because of the tranquil location and beautiful surrounding countryside. If this development is allowed to go ahead the site will surely close from the significant adverse construction and operational noise, light pollution and landscape impacts (we have relatives who stay there who have already said if the development goes ahead they will have no choice but to move). This would be a blow to the area and involve the loss of jobs for those who run/are employed at the site and significantly, the money generated by occupants for the local economy. There would then be the concern that this plot would end up as additional housing.
It is our understanding that not all landowners with interest in the land included within the proposed strategic site have agreed to development. There must therefore be doubt regarding deliverability of the site and we would question the appropriateness of its inclusion for consideration.
It is also concerning that no assessment of submitted candidate sites has been prepared/published by CCBC and that no possible alternatives have been documented. It is therefore not possible to determine whether the strategic sites proposed are the best options available.


Our response:

Not accepted. The site will be reduced in area to reflect the recommendation in the Green Wedge Review.