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Dear Cardiff Council Planning Committee,
ADDRESS & POSTCODE:
…. herby wish to object to planning applications 20/01108/MJR, 20/01110/MJR and 20/00357/MJR based on the following.
I hope that you pay significant regard to my objections. I do not believe that these issues can simply be mitigated away. They will have lasting long term detrimental effects on my community and my health, and therefore the applications should be rejected.
Safety of the Community
• The provisions outlined to ensure safe and efficient use and operation of Park Road during construction are insufficient. The 100 plus HGV’s accessing the site daily (200 plus journeys a day, to and from) for four years will unacceptably increase traffic, traffic jams, accidents, and pollution on an already busy J32 exit. Further these are only estimated numbers – there will likely be more as there is no contracted developer to provide a factual estimate at this time.
• The junction itself is in constant high-level use, serving as a means of connecting North, South, East and West Wales to Cardiff. However nowhere have the applicants considered the effect of the ‘100’ quoted HGV’s on the roundabout, or noted the potential difference in sizes and types of construction vehicles.
• Additionally, the traffic assessment data is over four years old, with the most recent data based upon one week period of assessment outside of Whitchurch Hospital – a considerable distance from the main area of access to these sites – Junction 32. It is clear that the data provided is therefore inadequate and cannot account for the safety of the community for up to four years of construction traffic.
• It is claimed (p.17) that “The extension of the period to 48 months is to increase flexibility of construction access, and the improve the efficiency of the construction process, which should result in a reduction in time for construction”. There is no evidence in the planning documents to support the claim that this temporary road will reduce construction time. Therefore the application should be refused.
• Local school children’s safety will be at risk (e.g. railings will be removed) as will cyclists’ and all pedestrians – including teachers and carers, who have rights to a safe workplace. The HGVs will cause considerable anxiety and distress for children with severe ASD from Ty Coryton School, who walk up and down Pendwyallt Road throughout the day as a part of their routine. This routine is crucial to maintaining their education and care, but will be severely disrupted by these large vehicles encroaching on the community.
• Further, the increase of dust from construction vehicles and air pollution shall pollute local residents, as well as children and teachers during their time at school, as the school playing field is only one row of houses away from the main road.
• If the northern access route will suffice for peak times, I ask why the southern route is needed outside those times.
• PS references LDP T5 Managing Transport Impacts. That includes obligations to “make satisfactory provision for access, parking and circulation, particularly by pedestrians, cyclists, public transport users and disabled people with mobility impairments and particular access needs”, and to “avoid unacceptable harm to safe and efficient use and operation of the road, public transport and other movement networks and routes.” This particular proposal does not achieve this, and objections have already mentioned important issues such as child safety.
• In addition, the air pollution data provided is incorrect, and should be recommissioned by an independent body. As Covid-19 affects respiratory systems, any increase in air pollution in the local area will present a serious threat to our lives.
• We are in the midst of a pandemic and may have another lockdown this winter. We need accessible, restful green space to walk in and the construction of the temporary access road and the bridges to the site will prevent this, as will the construction of the Hospital. The building works and loss of green space will have serious detrimental effects on the community, who are facing uncertainty, losses, risks to health and disrupted lives from COVID19.
• There are over 300 households in our community without a garden. Further, our community ranks at 55 out of 214 Lower Super Output Areas in Cardiff, and 345 out of 1909 in Wales. How can the Council justify further depriving this community during a pandemic, austerity and climate crisis?
• In addition, medical experts suggest that we will be living with Covid19 for the next few years and so we may have lockdowns in the future. The people of Whitchurch, especially many without access to a garden need safe, green space available to them.
• The world has changed and we invite Cardiff Council to recognise this by rejecting these applications.
Biodiversity and the Environment
• PS references several of the Environmental Policies in the LDP but dismisses any concerns around these, arguing (p.18) “The temporary use of the access road will not have unacceptable impact on the value of the listed heritage assets, although it will have a very minor / insignificant and temporary impact on the wider setting by the movement of vehicles through the area. The value of the heritage assets themselves will be preserved by the proposal.”
• The provisions outlined to protect wildlife, such as bird boxes and planting trees are inadequate. Disturbances from vehicles, construction and dust will severely affect the distribution of wildlife. The felling of over 600 trees to enable the project is unacceptable and will take far too long to replace in terms of their carbon mitigation (trees take 50-100 years to reach maturity).
• Further, the location of trees – the railway cutting whereby the Bridges shall be constructed – demonstrate exactly what rewilding could achieve at a time when they are reaching maturity. To remove them at such a time when old industrial areas are being rewilded in order to meet climate targets would be a mockery of the declaration of a climate emergency.
• Trees are our frontline of defence to the climate emergency. Having declared such an emergency, how can the Council justify cutting down such trees when there is the expressly recognised possibility of constructing the new Hospital on the Grange or with Heath Hospital, where excellent care could be provided?
• Further, the two stone bridges in the railway cutting are currently under assessment by Cadw in relation to them becoming listed. Following the assessment there will be a minimum of a 28 day consultation prior to a final decision being made on listing. If the bridges do become listed then it may be necessary for developers to adjust their plans in order to further protect the bridges from damage through dust; vibrations, the weakening of the structures by removing trees and disturbing roots, and the ruining of their aesthetic qualities by obstruction with the new roads, bridges, and proposed metro line. There may also be a need to reconsider using the railway cutting for storage of vehicles and equipment during construction.
• Due to these reasons, no decision should be made prior to Cadw’s decision on listing and the applications should be rejected because of this.
• As Whitchurch Library has been closed over the course of the consultation periods for all the above named applications, it is impossible that the community have been adequately consulted regarding these projects.
• Although Velindre hosted some in person community consultations, these were cut short by the lockdown. It was therefore impossible for those of our community without access to the internet or a computer to be made aware of these significant changes to the project. This is a serious failure and the applications should be rejected on these grounds.
• There has been inadequate communication with the community to address their needs and concerns. Removing green space will have a harmful effect on the physical and mental health of the local community, as many (300+) do not have access to a garden. Yet many of these individuals were never consulted regarding these applications.
• Further, no residents of Velindre Road, Park Road, Pendwyallt Road, the Hollybush Estate or Whitworth Square and surrounding areas were consulted regarding application 20/00357/MJR. This is demonstrated by the significant increase in objections following the 22nd of May, when the Save the Northern Meadows group posted on their social media asking for more objections to the application. Clearly, Velindre have the power to raise awareness of these matters on social media, as highlighted by their recent campaign #supportnewvelindre. There is no excuse for the complete failure to engage the community on this matter, especially those on Velindre Road who shall live with the increased pollution, traffic, and general chaos that decommissioning old hospitals and building a brand new housing estate and 200 bed hospital would bring.
• Additionally, the utter lack of transparency relating to the project, that only brought the plans for housing on Whitchurch Hospital to light during lockdown demonstrates the community has not been adequately consulted. With plans by CCC for the South Wales Metro to use the railway cutting, but no community consultation on the matter, very grave issues emerge regarding community and democratic participation in local decision making.
• Therefore these applications should be rejected outright.
Out of Date Planning
• Planning permission was granted to20/00357/MJR over 20 years ago. There are now different laws in force, including the Wellbeing of Future Generations Act and the Environment Act. Therefore, no planning permission should be granted for these new applications without them being intensely scrutinised by today’s legislation and policy.
• The building on the meadow conflicts with many aspects of The Planning Policy Wales 2018 which states that a healthier Wales can be achieved by ‘enabling opportunities for connecting with the natural and historic environment’ (118). It is also at odds with The Well-being of Future Generations Act 2015 and the vision of Cardiff Biodiversity and Resilience of Ecosystems Duty Forward Plan. (September 2019).
Alternative Uses for the Site:
• I would like to see the incorporation of the Northern Meadows into the Nature Reserve and secured for future generations.
• This site could then provide excellent community health benefits, increasing positive outcomes for the community and enabling the maintenance of a home for nature in Cardiff.
• This would be along the lines of the Future Generations and the Environment Act. The site could also provide patients of Velindre Hospital with access to nature during treatment, as it is less than 5 minutes from the proposed ‘Grange’ site to the meadows. We have heard suggestion of ‘pods’ to allow patients to witness nature, without being disturbed by glass buildings, and the constant comings and goings of busses, trains, and cars to the site.
I would like to invite the planning committee to make a site visit before deciding on these applications. It will become clear that all of these above applications are inadequate, ill-thought through and do not reflect the concerns of the community in the slightest. In fact, they will place our community under significant risk of harm from air, dust, noise pollution and high impact collisions. They also threaten our long term connection to our natural and cultural heritage, and shall significantly disenfranchise future generations from their access to this incredible and important site.