Many of you will have had a letter or email from the council regarding the latest news on the Cardiff Local Development Plan.The following letter has been sent to the council as the Danescourt Community Association's response
Councillor Ralph Cook
Deputy Leader
Cabinet Member for Strategic Planning, Highways, Traffic & Transportation
County Hall
Cardiff
CF10 4UW
9 July 2013
Dear Councillor Cook
Cardiff Local Development Plan 2006-2026 Deposit Plan: Working Draft
I refer to your letter dated 1st July 2013 drawing attention to the above and I feel obliged to advise you that I do not consider it to be a sound plan.
Your Background Technical Paper 12 on Transportation correctly states in its introduction that it " evidences the need for advanced provision of sustainable transport infrastructure to mitigate the impacts of forecast growth and ensure developments are accessible by sustainable transport " and that "the scale of development which Cardiff has to accommodate in the next two decades presents major transport challenges". Please remember the use of the two words: advanced provision because they are of significant importance.
The Transportation Paper goes on to analyse existing circumstances and to contrast these with a likely future scenario identified at 1.4.3 in which:
-
the demand for travel by car would increase by 41%
-
10% of new demand would be unable to travel on the highway network due to lack of capacity
-
average journey speeds would decrease and
-
journey times would increase;
and at 1.5.1 it concludes that the modelling undertaken indicates that:
-
all the major development sites will need to be supported by significant new transport infrastructure and improvements to existing transport facilities.
Two major findings at 3.2.1 are that:
-
Cardiff's key corridors are currently operating at or close to capacity and
-
strategic corridors would be significantly congested in the peak periods with an average 41% increase in vehicle travel times for journeys within Cardiff.
The major development sites proposed are correctly listed as sites 46, 72, 82, 102, 106 and112 at 4.1.1 and again the paper observes at 4.1.3 that these major sites "will need to be supported by significant new transport infrastructure and improvements to existing transport facilities."
All of the foregoing is undoubtedly perfectly correct and probably obvious to anyone, so why is this Deposit Plan unsound? The answer to this is because the solutions offered to these problems are no more than vague outlines with no detail as to how or when they might be provided, by whom or at what expense or indeed who would fund any of them.
Without this level of detail, the Deposit Plan is no more than a pipedream; it is certainly not a well thought out or well researched sound plan. Until this missing detail becomes available I fail to see how you will be able to persuade the rest of your Council, the public or the appointed Planning Inspector that your Deposit Plan is an acceptable document.
My particular concerns lie with the development of sites 46, 82 and 102 because of where I reside. During the morning peak period it already takes in excess of 30 minutes to travel along Llantrisant Road A4119 between Waterhall Road and Llandaff High Street because of the congestion caused by the nature of the historic centre of Llandaff. The projected increase in journey time of 41% indicated would lengthen this journey to around 45 minutes in order to travel a distance of perhaps a mile and a half, a result that would be completely unacceptable.
The Transportation background paper indicates that site 46 will be provided with direct access onto the M4 and that there will be a park and ride scheme accessed from both Llantrisant Road and the M4. Cardiff Council is not the highway authority for the M4, but no indication is given whether the Welsh Assembly in its role as highway authority for the M4 might agree to this proposal.
The difficulty which all of the vague ideas for transportation improvements included within the Transportation background paper have in common is that none of them indicate how the anticipated additional traffic will get from the edge of the current developed area into the city centre without causing chaos and congestion. If new routes are to be built and property to be demolished to allow this, then details of these agreed routes must be incorporated within the Deposit Plan for public consultation.
As you will have gathered I consider that the present Plan falls far short of being a well prepared document with which to inform anyone reliably or to enable an acceptable consultation process to be undertaken. I would urge you to reject it until significant further work has been undertaken to resolve in detail how the correctly anticipated transportation problems which will arise from its implementation can be overcome.
I do not believe this current Deposit Plan to represent the quality of governance and consideration that the population of a capital city should reasonably be entitled to expect from its Council.
I have written separately to my two local Councillors and I will also write to the Welsh Assembly to request rejection of this Deposit Plan.
Yours sincerely
Stewart Burgess
BSc MBA CEng CEnv FICE FCIHT MCMI
for Danescourt Community Association