An alternative use is proposed for this site - refer to representations 5684 & 5685.

Remove this area from ”housing development” because ofthe difficulty for potential
developers to build roads from Tirycoed Road to the old maternity hospital. This is already a
busy road with old, weight restricted bridges at either end.
Change the listed ground to the west of the old Maternity Hospital from "housing
development" (See red circle on map) because of conservation and access restriction
concerns.
This area qualifies for SINC status given that the rhos pasture and hedges are protected
habitats and the Marsh Fritillary Butterfly is protected under UK law, listed under Schedule
5 of the Wildlife and Countryside Act, and the EU Habitats and Species Directive (Annex II).
I also object to the remaining development site (See purple box on map below) on
conservation grounds and lack of access. These plans have been pushed for a number of
years already and have always been refused. The circumstances have not changed 700
people objected to a housing development on this site under the aegis of both the RLDP and
the current PAC (521.186). (See online petition)
https://www.change.org/p/no-to-the-housing-deveIopment-on-tirycoed and door to door
petition https://thunderbolt.me.uk/Docs/Tirycoed%20Petition%20Redacted.rar
Furthermore actual size of this site would support a great deal more homes than the 25
currently being proposed in PAC 521.186 . However we also object on the understanding
that the current LDP cannot be met on the following grounds:
SP2 Retail and Town Centres
There are no large retail outlets, in Glanamman unless you travel to Ammanford. The Dentist
and GP surgery are oversubscribed, there are no leisure facilities nearby and the local
infrastructure is not able to cope with an influx of housing on this scale. The main road
though Glanamman already struggles to cope with too much traffic causing queues through
the village and consequently fumes from a steady flow of traffic passing through where a lot
of houses are situated very close to the main road.
SP3 Sustainable Distribution — Settlement Framework
There are very few services available in this location and this development would put huge
strain on existing ones. We constantly suffer from disrupted water supplies clue to the
ageing and an inadequate water supply system, which would be overwhelmed by the
additional capacity needed.
SP4 A Sustainable Approach to Providing New Homes
There is not an ”appropriate number” of homes being suggested for this site. Although 25
dwellings are currently being requested, it is very clear that the site has capacity for at least
100. That would be a massive burden on the local infrastructure and facilities. The access
road is not suitable for such volumes of traffic and there are already huge issues with water
supply and drainage which cannot be addressed.
SP9 Infrastructure
Those already living in Tirycoed Rd have already had to pay for the upgrading of their
electricity supply due to its lack of capacity and overall the local infrastructure is very poor.
SP12 Placemaking and Sustainable Places
Placemaking should be holistic and inclusive and rightly be at the heart of any planning
decision. Furthermore any development should; comply with Welsh Government policy on
sustainable places
https://researchsenedd.waleslresearch-articleslmaking-sustainable-places-what-role-can-t
he-planning-system-play/, and take account of the Well-being of Future Generations (Wales)
Act 2015 and be predicated on
-
Making the best use of resources;

-Facilitating accessible and healthy environments;

-Creating and sustaining communities; and

-Maximizing environmental protection and limiting environmental impact.

My concern is that this proposed housing development will fail to meet most of those
expectations. There are dangers that this development will destroy established habitat and
endangered species, it will cause light pollution and it will adversely affect community
cohesion into which it is being placed.
SP13 Rural Development
This proposed site is located in an area of outstanding natural beauty where wildlife
currently thrives. Allowing such a large development on such precious land is absolutely
against current rural development policy
httpszllresearch.senedd.waleslresearch-articleslthe-rural-development-plan-for-walesl
which is predicated on ”the sustainable management of natural resources and climate
action”
SP14 Maintaining and Enhancing the Natural Environment
Housing development will destroy our unique and bio diverse landscape and our protected
habitats and lead to loss of biodiversity. This development will lead to the de-wilding of the
site and the subsequent loss of the Marsh Fritillary Butterfly, Devils Bit Scabious and winter
visitors such as snipe and woodcock.
Devils Bit Scabious- Christian Fischer, CC BY—SA 3.0 <https://creativecommons.org/licenses/by-sa/3.0>, via Wikimedia Commons
Previous planning applications have absolutely failed to address the issue of habitat
destruction (Which the developers have been actively engaged in). Endangered species will
be displaced and lost and riparian corridors will be blocked preventing otters (which are low
in Wales) from travelling.
SP15 Protection and Enhancement of the Built and Historic Environment
The appropriate use of this redundant building is certainly not to allow its demolition and
replacement with a totally unsuitable housing development. Absolutely no consideration
has been given to the wishes of the local community nor the protection of this historic site.
SP16 Climate Change

There has been no carbon audit of potential housing development on this site. It has been
estimated (Drexler et al 2021, NERR094) that the current carbon stocks (rhos pasture,
shrubs and hedges) on the site (ca 2ha) are 220 T C which will be cut by 84.75 T C to 135.25
T C after housing development. The carbon emissions (Berners-Lee 2010) as a result of
development (25 houses plus roads, paths, drives, parking bays) will be approximately 3000
T C02 and there will be a sequestration reduction of 0.125 T C yr (NERR094).

The destruction of Rhos pasture, trees and grassy marsh/and on this site would be an
absolute disaster for the local environment. Paving over huge areas for roads and paths will
create hard standing that will cause rain water to surge onto surrounding roads and
properties, causing flooding. Previous planning applications have had few mitigating
measures for renewable energy, carbon negative building materials or energy conservation
schemes.

SP19 Waste Management

Safeguarding resources would not be achievable if planning permission were granted for this
site. The loss of trees and pasture would contribute to Climate Change while the amount of
carbon that would be released during the construction phase alone would be damaging to
the environment.

Could I request that CCC reclassify the development site as community or public spaceland
refer CCC to your obligations under the aegis of the placemaking guide 2020.
(https://dcfw.org/wp-contentlthemedecfw-child/assets/PIacemakingGuideDigitalENG.pdf)
The importance of community space was highlighted In a recent supreme court ruling -
Hilary Term (2023) UKSC 8 on appeal from (2020) EWCA civ 1751- (R (on the application of
Day) (Appellant) v Shropshire Council (Respondent) (landmarkchambers.co.uk)) where the
court ruled in favour of the local community.

Furthermore the importance of having access to community space was a frequent theme
highlighted in a consultation report on connected communities
https://www.govwales/sites/defaultifiles/consuItations/2019-03/summary-of—responses 2.
@

This site could provide so much benefit if it were used for well-being, conservation and
recreation (given the increasing number of people suffering with mental illnesses maybe a
well-being centre, a conservation area with pond, and board-walks for recreation and
conservation interpretation). This site is adjacent to the most important breeding ground for
the Marsh Fritillary Butterfly in the Amman Valley. Please note CCC’s obligations with
regards to placemaking charter (http://dcfw.org/placemaking/placemaking-charted) to
provide spaces to promote prosperity, health, happiness, and well-being in the widest
sense.
This would meet the current requirements on the following grounds:

SP1 Strategic Growth

The installation of Health and conservation facilities would be far more beneficial to the
community than housing. This site is within easy reach of local Schools, so could be used as
an outdoor education centre for children and adults alike.

SP2 Retail and Town Centres

Having a Community lead facility on this site benefits everyone.

SP3 Sustainable Distribution — Settlement Framework

Our suggested project (The Tirycoed Well-being Centre) not only uses the existing building
foundation as its base, but will also be managed sustainably, the exact opposite ofthe
current proposals.

SP6 Strategic sites

This project will invest in the local Community and provide much neededfacilities for all,
rather than benefiting already very rich people. This inward development will also create
local sustainable jobs, benefit local business and bring a much needed boost to the local
economy.

SP7 Employment and the Economy

This project will invest in the local Community and provide much need facilities for all,
rather than benefiting the Developers. This inward development will also create local
sustainable jobs, benefit local business and bring a much needed boost to the local
economy. It will also serve as a Community hub, allowing people to meet and interact,
something a housing estate will actively discourage.

SP8 Welsh Language and Culture

Our plan will bring the local community together and enhance its integration, keeping the
Welsh language alive, rather than causing its demise due to the influx of non-Welsh
speaking people.

SP9 Infrastructure

This site could be both built and managed to meet the needs of our local Community as
required by the conditions of this section of the RLDP.

SP12 Placemaking and Sustainable Places

Our proposal would fully comply with the placemaking charter
(http://dcfworglplacemakinglplacemaking-charter/) and we would endeavour to provide
spaces to promote prosperity, health, happiness, and well-being in the widest sense.
Furthermore we would endeavour to ensure the site was both sustainably managed
(possibly with help from INCC) and built to enhance and improve the local biodiversity, with
all the benefits this would bring.
SP13 Rural Development

This site absolutely fulfils the requirements ofthis section ofthe RLDP. It actively improves
and enhances the available facilities accessible to the local Community, while adding and
improving local facilities for all.

SP14 Maintaining and Enhancing the Natural Environment

Habitat conservation is at the heart of this proposal will include. Improving the landscape
naturally, by using cattle to graze the Rhos pasture, establishing ponds and encouraging
natural regeneration, meeting this requirement ofthe RLDP.

SP15 Protection and Enhancement of the Built and Historic Environment

The current proposal to simply destroy the existing building on this site will be revisited. Any
required works will be carried out sympathetically and in an environmentally sensitive way.
SP16 Climate Change

By using sustainable methods this proposal is protecting valuable natural assets. There
would be no need to destroy vast areas of natural land, as would be the case if a housing
development was allowed.

SP18 Mineral Resources

This proposal would actively promote improvements to the environment encouraging
carbon sequestration and improving the local landscape to the benefit ofthe environment.
SP19 Waste Management

Solar and wind power for this community site could be self sufficient for its energy and thus
reducing reliance in carbon generation.

References

Berners-Lee, M. ’What’s the Carbon Footprint of .....Bui|ding a House’. The Guardian, 2010,
Environment - Green Living Blog.

Drexler, S, A Gensior, and A Don. lCarbon Sequestration in Hedgerow Biomass and Soil in the
Temperate Climate Zone’. Regional Environmental Change 21, no. article number 74 (2021): 157-.
NERR094. ’Carbon Storage and Sequestation by Habitat: A Review of the Evidence (Second Edition)’.
Natural England, 2021.