SD15.2.4 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 SD15.2.4 2826 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. SD15.2.4 2826 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 SD15.2.4 2826 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.’ SD15.2.4 2826 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: [email protected] / 07854334683 / 01443 486496 / Glyncoch Partnership, 56, Garth Avenue, Glyncoch, Pontypridd, Rhondda Cynon Taff.