Save Parc Coed y Nant near #Pentwyn leisure centre

Fields by Pentwyn leisure centre. Credit: cardiffjournalism.co.uk

 Read Cardiff Civic Society’s letter to Cardiff Council objecting to plans to build on part of Parc Coed y Nant, near Pentwyn Leisure Centre.

Dear Sir/Madam,

 Cardiff Civic Society would like to object to the above proposal on the following grounds.

• Under the Section 6 duty of the Environment (Wales) Act 2016, the council must seek to maintain and enhance biodiversity and promote ecosystem resilience, but these proposals do not support this requirement.

• Parc Coed y Nant, as well as being a popular open green space to the community, is also home to several protected and priority species. The area has also been part of a pollination project to encourage biodiversity and important wildlife.

• Despite the area being a Site of Importance for Nature and Conservation (SINC) with three priority habitats (identified at pre planning stage) an environmental impact assessment was not considered necessary during the screening process.  An EIA must be carried out.

• The proposed development will result in the removal of trees, and although the proposals state that the trees will be replanted, this will have an adverse impact on wildlife. And, as has been demonstrated so many times before, it is impossible to ‘replace’ mature trees. Trees take generations to mature and cannot simply be replaced.  The consequences of tree removal in terms of climate resilience and human health and wellbeing, as well as for biodiversity, are incalculable. 

• The results of a previous habitat survey and protected species assessment have already confirmed the presence of badger, hazel dormice, otter, bats, birds, reptiles, amphibians, fish,  and invertebrates.

*Current amendments to Planning Policy Wales also make the proposal untenable,.

• Legal pre application consultation requirements around consultation procedures prior to the submission of a planning applications include to “write to any owner or occupier of land adjacent to the land to which the proposed application relates”. In section 3.2.1 of the PAC report summary, it states “As there were no neighbouring properties immediately adjacent to the redline application site, and the surrounding land is owned by the applicant (Cardiff Council), there was no requirement to notify adjoining landowners and /or occupiers on this particular proposal.” Given the proximity of the adjoining houses on Bryn Celyn Road, the council has clearly failed in its obligations.

• A description of the proposed work includes “The creation of the new rugby pitch will change the current use of the land from ‘informal’ green space to a high-quality leisure provision accessible to the local community.” This is a significant change of use from an informal space which has multiple uses (and is free to use) to a single use facility for a private rugby club and will not result in a high-quality leisure provision for the community. Its use to the community will be severely restricted and is not clarified in the plans. Furthermore, the plans for the Leisure Centre itself involve eliminating activities that were previously extremely popular.

• Under section C2 (Protection of existing Community Facilities) of the LDP, it is stipulated that,

“Proposals involving the loss or change of use of buildings currently or last used for community facilities will only be permitted if:

i. An alternative facility of at least equal quality and scale to meet community needs is available or will be provided within the vicinity or;

ii. It can be demonstrated that the existing provision is surplus to the needs of the community.

can be met.

While this policy will apply to both commercial and non-commercial uses which provide a social or welfare benefit to the community, community land and buildings are of particular importance. This includes land and buildings that are managed and used primarily by the voluntary and community sector for community-led activities.”

The proposed plans will involve taking vital facilities and open space away from the community. Cardiff Council is again failing to meet its obligations.

*Section, C4 of the LDP (Protection of Open Space), aims to protect open space that has significant functional, conservation, environmental or amenity value. It applies to all areas of open space within the county. Both the planning application and ecological appraisal highlight this development would impact on protected priority species and important habitats and biodiversity.

• Section EN13 (air, noise, light pollution) states that, “The provision of lighting can help prevent crime and the fear of crime, enhance safety and security, and facilitate some sport and recreational activities. However, it can also be intrusive, cause glare and have a harmful impact on human health, wildlife, the amenity of neighbouring land uses and traffic safety.”

In Llandaff extending the operating hours of a 3G pitch at Bishop of Llandaff Church in Wales School (Ref. No: 22/00456/MNR), was refused with one of the reasons being that “the proposed development of floodlighting would have a detrimental impact on adjoining neighbours due to increased light pollution and noise disturbance". Floodlighting in this proposal will have a detrimental effect on human health and wellbeing, as well as having a negative impact on wildlife such as bats and songbirds.

Natural Resources Wales has already identified concerns and made recommendations around this, but these recommendations do not appear to have been included in the full planning application. Residents directly facing the proposed pitch will also be disturbed by noise from use of the pitch late into the evening, to the detriment of residential amenity and contrary to policies KP5(x) and C (ii) of the Cardiff Local Development Plan.

• All local authorities as part of national objectives, should seek to protect trees, woodlands and hedgerows with natural heritage or amenity value, but these proposals will involve removing trees. Cardiff Council has disregarded Section EN7 (Priority habitats and species) of the LDP in their proposals to build on an area which is recognised as having several protected species. The need for development (which has come at the request of Cardiff Rugby, a professional club with access to several other state of the art pitches) does not outweigh the nature conservation importance of the site. For permission to be granted, the developer should demonstrate that there is no satisfactory alternative location which avoids nature conservation impacts.

For these reasons, this application should be refused.

Yours faithfully,

Nerys Lloyd-Pierce

Chair, Cardiff Civic Society