Gwrthwynebu

ID sylw: 6021

Derbyniwyd: 26/06/2026

Respondent ID: 645

Ymatebydd: Ms Zoe Aubery

Asiant : Boyer Planning

Cadarn? Heb nodi

Policy TRA2 seeks to support development that promotes active travel by requiring developments to provide, or contribute towards, walking and cycling infrastructure.
BR support the principle of promoting active travel and improving opportunities for walking and cycling in accordance with national planning policy, the Active Travel (Wales) Act 2013 and wider sustainability objectives. However, suggest that amendments should be made to the proposed wording of Policy TRA2 to ensure it remains proportionate to proposed scheme and able to consistently applied when determining a range of development proposals.

The policy requires development proposals to incorporate active travel infrastructure within development sites and/or make financial contributions towards off-site provision. Whilst off-site improvements may be appropriate in certain circumstances, the policy should clarify that any financial contributions will only be sought where they are directly related to the development and reasonably related in scale to the proposed scheme. Without such clarification there is a risk that the policy could result in requests for contributions towards wider network improvements that do not meet the relevant legislative tests.

From a practical standpoint if development sites are expected to contribute financially towards Active Travel scheme as mitigation measures, then the scale and mechanism of those contributions should be clearly established as part of the plan-making process. Without this clarity, there is a risk that Policy TRA2 could introduce unforeseen costs and extensive time delays, potentially affecting the plan’s ability to meet its housing requirements.

Additionally, the policy states that development proposals which have a "significant adverse impact" on a Public Right of Way or existing Active Travel route will be expected to provide alternative routes. Whilst the objective of protecting and maintaining route connectivity is supported, the policy does not define what would constitute a "significant adverse impact". As drafted, the wording is open to interpretation and could result in inconsistent decision-making and uncertainty for applicants.

BR suggest that the absence of a clear definition makes it difficult for applicants to understand when mitigation measures or alternative routes will be required and may lead to disproportionate requirements being imposed on development proposals.

Finally, significant weight should be given to development proposals that retain, protect and positively integrate existing Public Rights of Way (PRoW) within their design. Schemes that incorporate and enhance established walking and cycling routes can help maintain connectivity, encourage sustainable travel, support public access to the countryside, and preserve the character and recreational value of the local area. Accordingly, proposals that successfully accommodate existing PRoW, whilst safeguarding their accessibility, safety and amenity, should be supported according and this position reflected within the overall planning balance.

The Council considers the policy provides sufficient clarity in relation to the requirements towards Active Travel provision. It should be noted that in applying the policy and seeking financial contribution or otherwise through planning obligations, the provisions of the CIL regulation and the tests contained therein, will be fully applied.