SD15_2_4 Session 15A Statement Representor 2826

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2826
RHONDDA CYNON TAFF COUNTY BOROUGH COUNCIL
LOCAL DEVELOPMENT PLAN UP TO 2021
Written Representation on behalf of Glyncoch Communities
Partnership and Green and Friendly Action Glyncoch (GAFA)
Objector Ref: 2826.D2
LDP Consultation Document Page Number: 60 – 62, Paragraph Number: 5.83 – 5.84,
Policy Number AW14 / AW15, Site Reference SSA26 /SSA13
Purpose of document
The purpose of this document is to refute the council’s rejection of objections made by
key organisations and householders in Glyncoch against the LDP allocation of land
adjacent to Glyncoch for mineral extraction.
Summary of Key Ground For Objections:
The above proposals to allocate land on the mountainside above Glyncoch for mineral
extraction will enable the expansion of Craig yr Hesg Quarry. Consultation with the
inhabitants of Glyncoch has demonstrated that many feel these proposals will lead to
further noise and disruption to the residents of Glyncoch (see appendix A), exacerbate
air quality and threaten the structural integrity of the primary school as well as nearby
housing. The designated area for mineral extraction is just 138.75 meters from the
nearest house, 160 meters from the local primary school and just 123 meters from the
primary school’s outdoor classroom. A large number of local residents have expressed
health and safety concerns. There are also concerns relating to the inadequate
infrastructure for the transportation of minerals. The current quarrying levels have a
negative impact on the quality of life of local residents, and increase in such levels
would exacerbate this situation.
Summary of Alternative Proposal
To remove designation of land for mineral extraction from site SSA26 /SSA13. For the site
to be designated instead, as a community amenity, enabling residents to access the
countryside through links with the nearby designated nature reserve, as well as to
develop an outdoor activities and natural environment learning zone. These plans
include a community owned wind turbine which will generate revenue for the
regeneration of Glyncoch. Funds will be raised from the Welsh Assembly Government’s
Community Scale Renewable Energy Generation Programme which uses European
Structural Funds to provide advice and grants to support the development of
community-sized renewable energy schemes, through the Energy Saving Trust. These
alternative proposals developed by local people will facilitate economic, social and
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environmental regeneration and the genuinely holistic, sustainable development of the
Glyncoch community as well as RCT.
Summary of Council’s response
1. The council refers to advice given in Minerals Technical Advice Note 1
paragraph 71 (MTAN 1 para 71), which advises that the buffer zone for sand
stone quarries should be no less than 100 meters. The council points out that sites
SSA26 and SAA13 meets those requirements and suggest that permission would
need to be obtained to extract minerals inside the minimum distance.
Furthermore it points out that our objections are misguided in the sense that
MTAN 1 para 71 are in essence about protecting the mineral reserves rather than
the community.
2. The council also suggests that variation in traffic from the site would be subject to
traffic regulation.
3. The council rejects the Glyncoch Community Partnership and GAFA proposals to
use the site as a community amenity on the following grounds:
‘for community use, the land is somewhat isolated from the village, with a rugby
field nearby more appropriately located. There is no suitable access for
maintenance vehicles to the site’.
Glyncoch Community Partnership and GAFA objections to council’s response
1. Indeed MTAN1 paragraph 71 does advise that the buffer zone for sand stone
quarries should be no less than 100 meters and the council’s proposals do
comply. However, the document also acknowledges the tension between the
need to extract minerals to support economic development and the need to
protect the environment as well as the health and wellbeing of communities.
People within Glyncoch feel that the existing quarry already impacts upon the
lung health of residents and compromises the structural integrity of community
buildings and homes. They are concerned that further expansion to the quarry
would exacerbate this further. MTAN1 para 75 states that ‘ The potential impact
on health must always be considered in relation to proposals for aggregates
extraction and a health impact assessment for any proposal …located within
one kilometer of an existing community.’ Furthermore, paragraph 80 states that
‘cosmetic damage or hairline cracks [to buildings] should not occur at vibration
levels lower than 20mm ppr at a frequency of 15Hz and lower than 50mm ppv at
50 Hz and above’. Damage to homes and buildings within the area suggest that
the existing quarrying activity must be outside of these parameters.
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What is particularly of grave concern to residents is the fact that there are high
levels of tuberculosis in Glyncoch as recognized by the Local Health Board and
Public Health Protection over the last year. It has been suggested that quarry
dust may exacerbate the suffering of those with TB.
2. Variation in traffic from the site may be subject to regulation, but many local
people who have been consulted suggest that current levels of traffic are
unacceptable and distruptive.
3. The site would support the Communities First Area of Glyncoch to access the
countryside and walking routes in and around Rhondda Cynon Taff. Glyncoch
was excluded from the recent development of Pontypridd Circular Walk despite
a local and national policy commitment to promoting health and wellbeing in
the most disadvantaged communities. Access for maintenance vehicles for
walking routes and a wind turbine can indeed be achieved via Glyncoch Rugby
Club.
Compliance with LDP Strategy
The proposals under discussion do not comply with the LDP Strategy which commits to
complying with regional and national policy. See below.
Test of Soundness
Ref P2 Subject to Sustainability Appraisal
The proposals set out by members of the community of Glyncoch facilitate economic,
social and environmental development, whereas if the land is designated for mineral
extraction the emphasis is on economic development to the detriment to the other two
pillars of sustainable development.
Ref C1 Regard for other relevant plans
The proposals disregard the council’s own Environmental Improvement Strategy for RCT
which commits to:
‘Managing our green spaces for the communities and nature’s benefit….[and] meeting
the local challenges of reducing …energy use, resolving traffic problems [and]
addressing pollution. Recognising that improving our environment has a positive effect
on the regeneration of our communities, our health, crime and our social and
economic wellbeing.’ (pg 5)
In actual fact, the council’s street care department has recognized the Glyncoch
communities aspirations to become a model of sustainable development and have
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invested £195,000 in supporting Glyncoch to become a zero waste community. In the
first six months of this scheme, recycling in Glyncoch has increased from 42% to 78%.
The LDP does not consider the Glyncoch Partnership’s proposals which are focused
upon enhancing the designated area of land for access to the Graigwen Nature
reserve, as well as a host of projects to enhance the health and wellbeing of residents,
support out -door learning as well as community resilience to climate change. These
proposals are consistant with the council’s Envionmental Improvement Strategy,
Ref C2 Consistency with National Policy
This element of the proposed LDP, contradicts the Welsh Assembly Governments
constitutional commitment to sustainable development and particularly to support the
development of sustainable communities:
Our future depends on the vitality of our communities as attractive places to live and
work. We need to reduce inequalities between communities whilst retaining their
character and distinctiveness’(WAG: Wales Spatial Plan (2008) pp29 (word version).
The development of the quarry undermines
‘The quality of our natural environment has an intrinsic value as a life support system,
but also promotes wellbeing for living and working and contributes to our economic
objectives. Safeguarding and protecting our natural and historic assets, and
enhancing resilience to address the challenges of climate change, will enable us to
attract people to our communities and provide the wellbeing and quality of life to
encourage them to stay and preserve the foundations for the future’ (WAG: Wales
Spatial Plan (2008) pp38 (word version).
The proposal is balanced in favour of economic development to the detriment of
environmental and social considerations and is contrary to the ethos of the Welsh
Assembly Government’s policies relating to mineral extraction set out in MTAN 1 para 7,
which sates:
‘The overarching objective in planning for aggregates provision therefore is to ensure
supply is managed in a sustainable way so that the best balance between
environmental, economic and social considerations is struck, while making sure that the
environmental and amenity impacts of any necessary extraction are kept to a level
that avoids causing demonstrable harm to interests of acknowledged importance. This
acceptable minimum may not be possible in all instances and where that is the case,
extraction should not take place, local planning authorities or the aggregates industry
should consider alternate working practices or locations for future working to secure a
standard considered appropriate to mineral working in’ the 21st Century.’
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Our proposals are much more consistent with the Wales Spatial Plan’s commitment to
supporting the economic development of communities without compromising
environmental and social considerations.
‘Our future depends on the vitality of our communities as attractive places to live and
work. We need to reduce inequalities between communities whilst retaining their
character and distinctiveness’(WAG: Wales Spatial Plan (2008) pp29 (word version).
‘The quality of our natural environment has an intrinsic value as a life support system,
but also promotes wellbeing for living and working and contributes to our economic
objectives. Safeguarding and protecting our natural and historic assets, and
enhancing resilience to address the challenges of climate change, will enable us to
attract people to our communities and provide the wellbeing and quality of life to
encourage them to stay and preserve the foundations for the future’ (WAG: Wales
Spatial Plan (2008) pp38 (word version).
Conclusion
The alternative proposals suggested by the Glyncoch Partnership, GAFA and a range of
individuals, organizations and agencies to designate the land for community use. This
includes community access to walking routes and the development of a community
owned wind turbine, support local and national policies to promote sustainable
development and community resilience to climate change. The current proposals
suggested by the council to reserve the land for mineral extraction are an archaic reemergence of the traditional economic development policy paradigm that
compromises the environment and the health and wellbeing of communities. Rhondda
Cynon Taff and its residents have suffered enormously from this policy paradigm
throughout the industrial revolution. After years of environmental degradation to the
detriment of the health and wellbeing of residents, Glyncoch along with other
communities in RCT should be protected by the progressive policy framework emerging
from a national commitment to Sustainable Development.
Author: Jenny O’Hara Jakeway, Glyncoch Communities First Co-ordinator
Contact: jenny@glyncochcp.co.uk / 07854334683 / 01443 486496 / Glyncoch
Partnership, 56, Garth Avenue, Glyncoch, Pontypridd, Rhondda Cynon Taff.