Of the 8 Main Service Centres, Flint has 1,598 homes in ‘green’ sites – 68% of the total.
4.5 If we consider the reference to employment and transport nodes, then it would be expected that those locations closest to the Deeside Enterprise Zone, the A55, A494 or train stations would have higher allocations.
4.6 Connahs Quay (Main Service Centre) has 105 ‘Green’ homes.
Saltney (Main Service Centre), Queensferry (Main Service Centre) Hawarden, Broughton, Garden City, Mancot, Northop, Northop Hall, Drury, Bretton and Sandycroft (Local Service Centres), all of which are close to employment and transport links, have no Green sites.
4.7 Reference to the settlement hierarchy as it affects Hope, Caewgrle, Aberborddu and Cefn y Bedd (HCAC) doesn’t make much sense when taken in the wider context of the available candidate sites and other policy matters such as active travel. These settlements are geographically distinct and it is not realistic to expect residents to walk between them (they are served by three separate train stations).
4.8 Although they have been grouped together since the Alyn and Deeside Plan, that in itself is not justification alone. The UDP inspector did not find a problem with the single boundary but setting that boundary was not a primary concern of the inspector. The purpose of the LDP is to identify sites suitable and sustainable for development. It is not clear how considering four distinct settlements as a single settlement helps with the Wellbeing and Cohesive Communities goals.
4.9 In reviewing the wider figures, it would be useful to understand better what criteria have been used and how those criteria have been applied in relation to the Spatial Plan, because the numbers do not reflect the wording of the strategy.
Policy STR3 Strategic Sites
This policy makes provision for strategic mixed use sites at:
- Warren Hall, Broughton
- Northern Gateway, Deeside
5.1 The growth target for both employment and housing is ambitious and will require the strategic sites to be brought forward. Clearly Warren Hall is located closer to Higher Kinnerton and Penyffordd and is likely to have an impact on these settlements and that should be taken into account when considering other housing allocations.
5.2 There are concerns that Phase 2 of the single site school in Penyffordd may be brought forward ahead of the end of the LDP plan period to accommodate additional pupils from both Warren Hall and Higher Kinnerton. We have expressed concern about Phase 2 for a number of reasons, the most significant of which is transport and access.
Policy STR4 Principles of Sustainable Development & Design
This policy includes ways to deliver sustainable development
6.1 Where is the detail of this policy? Clearly sustainable development is a fundamental principle of Planning Policy Wales.
Policy STR5 Transport and Accessibility
This policy aims to facilitate an integrated transport system and ensure sustainable and accessible development.
7.1 We need to be wary of assessments of public transport as a measure of sustainability, without assessing the full extent of the services. For example, the Borderline railway is not likely to electrified during this plan period and with a change of franchise operator, the frequency of service – currently adequate at best – is not guaranteed.
7.2 The local bus services are under-utilised and car ownership is the primary means of transport. Penyffordd has, in the past year, lost one bus service, had another half its frequency of service and has no Sunday service. One of the two remaining services is under threat of closure or further reduction in the frequency of services.
7.3 Community Transport schemes are in their early stages and with Flintshire’s general budget context, are under serious threat with the cost potentially beyond the affordability of Community and Town Councils.
7.4 It would good to see this policy refer to active travel, so that the principle becomes ingrained in policy rather than a ‘tick box’.
Policy STR6 Services, Facilities and Infrastructure
This policy aims to ensure that new development is supported by necessary and adequate infrastructure whether through CIL or planning obligations.
8.1 Communities are dependent upon CIL payments and they must go beyond education and childrens play areas. Communities need open space, shared community facilities for all ages and basic amenities including improved waste, water, gas, electric and high-speed internet.
8.2 CIL payments are best allocated by Town and Community Councils who are in turn responsible for consulting the Community. Place Plans as SPG are an ideal way to deal with this.
Policy STR7 Economic Development, Enterprise and Employment
This policy seeks to ensure a healthy, vibrant and diverse local economy.
9.1 In Penyffordd there is a suggestion that land be made available for small business units close to the train station. These appear to have been dismissed due to the availability of other employment sites in the County. In practice there are increasing numbers of self employed and small businesses with few affordable, local facilities available. Warren Hall is not likely to bring forward office or workshop space suitable for small growing businesses or start-ups.
Policy STR8 Employment Land Provision
This policy makes provision for a range of employment land and premises.
10.1 See STR7
Policy STR9 Retail Centres and Development
This policy seeks to support town, district and local shopping centres as multi-functional hubs for local communities.
11.1 There is an urgent need to support retail and other community based enterprise in our local town centres. Retail is changing forever with the shift to online purchasing and town centres have been decimated, particularly smaller centres such as Buckley.
Policy STR10 Tourism, Culture and Leisure
This policy sets out a number of principles to be applied in considering different tourism, leisure and cultural development proposals.
12.1 Referring again to the potential commercial sites at Penyffordd train station, which would suit businesses serving passing 4x4, cycling and motorcycle traffic heading for the AONB and National Parks.
Policy STR11 Provision of Sustainable Housing Sites
This policy sets out the approach to and principles to be applied in making provision for viable and deliverable housing development to meet general, affordable and specific housing needs.
13.1 We cannot see the detail of the policy but the principle of enabling existing residents, whether growing families, young people looking for a first home or the elderly downsizing, to find alternative accommodation within their budget is essential. This is a separate issue to homes defined as ‘affordable’ and is why a balanced housing mix is so important.
Policy STR12 Provision for Gypsies and Travellers
This policy sets out the approach taken in providing for the needs of gypsies and travellers.
Policy STR13 Natural and Built Environment, Green Networks & Infrastructure
This policy encompasses a number of strands in seeking to protect both the built and natural environment.
15.1 We need to ensure that heritage buildings are protected as far as is reasonable affordable and practical. Reviewing the history of Penyffordd / Penymynydd and realising the number of heritage / history buildings that have been lost to development is sad – Penymynydd Methodist Chapel, The Towers, Meadowslea, the White Lion, The Royal Oak for example. There are few buildings left which help to define the settlement and provide a sense of heritage. It would be very easy to sweep aside these types of buildings, not suitable for listing, and lose the spirit of a village.
15.2 The natural environment is equally as important, whether it is semi-ancient woodland, as enjoyed between Penymynydd and Dobshill or the agricultural field structures and hedgerows established hundreds of years ago.
15.3 The Penyffordd Place Plan seeks to connect people to the natural environment and heritage around us through the introduction of heritage and nature walks.
Policy STR14 Climate Change and Environmental Protection
This policy sets out the ways in which the Plan can help address Climate Change and also deals with other aspects of environmental protection such as flood risk, pollution and energy generation.
16.1 Solar farms and managed woodland are increasingly popular and suitable for land which is unavailable for housing development from which the landowners would like to recover some income – policies should be included for this eventuality.
16.2 More emphasis than ever is needed on the protection of established trees and hedgerows on sites which are granted planning permission. We must stop it being acceptable to remove large proportions of vegetation in order to increase the number of units that can be built on a site. This should be enshrined in policy.
Policy STR15 Waste Management
This policy seeks to ensure a sustainable approach to managing waste within the County.
17.1 Wales and Flintshire have an excellent record in encouraging household recycling, but this can be further enhanced through designs which allow for space for recycling bins and receptacles.
Policy STR16 Strategic Planning for Minerals
This policy sets out the ways in which the Plan will sustainably manage minerals resources and activity.
Are there any other strategic policies that should be included?
The Preferred Strategy sets out a comprehensive framework of policies but you may consider that additional strategic policies need to be included?
Are there any other comments on the Preferred Strategy?
Do you have any comments on other aspects of the Preferred Strategy including supporting documentation?
Comments specific to Penyffordd / Penymynydd:
20.1 The growth under the UDP in Penyffordd is well documented. The settlement grew from 1,340 houses in April 2000 to 1,622 in April 2015, most of them post 2011.
20.2 In the LDP period, Penyffordd has grown by a further 174 houses, including 53 built outside the boundary previously and 40 for which permission has been granted but which are yet to be built. There are a further 32 which are subject to appeal and which FCC are unwilling to contest.
20.3 According to Flintshire County Council, Penyffordd has experienced the highest percentage growth of any settlement in Flintshire.
20.4 In light of the figures shown above for the distribution of houses across the County and the position of Penyffordd in the 3rd tier, the adjacent strategic site at Warren Hall with 300 houses, it is reasonable to say that Penyffordd need not accept any further allocations.
20.5 But the village is realistic about need and in our Place Plan we have acknowledged that some further growth may be necessary – if it of the right type to meet local demand – it equates to a further 37 houses over the plan period (excluding Hawarden Road), but none ahead of the LDP adoption – to allow time for infrastructure to catch up.
20.6 There is genuine concern that the allocated site PEN037, the remainder of Wood Lane Farm, has been designed as a ‘green’ site. Please can you expand on the reasoning and reassure us that it has nothing to do with a developer ready with a plan to bring forward? Our Place Plan 2.2 (reference 3.07) defines this site are being too large and will result in unsustainable levels of growth, particularly if it is developed as a continuation of the Groves development with the same housing density as it is widely speculated to be.
20.7 There is also confusion about PEN038, the current Redrow application site, which was dismissed as an unnecessary incursion into open countryside and an unnatural extension of the settlement in both the UDP inspectors report and the Planning Officers report this year on the Redrow application. The fact that it is considered to be a potential site for inclusion the LDP in the consultation published just days before the start of the Redrow Public Inquiry was, at best, an embarrassment and at worst may have compromised the case. What is the reasoning given the huge public outcry about the Redrow application?
20.8 It would useful to understand the criteria used to determine that a site of this size in a sustainable village and how it is considered compliant with the spatial strategy?
20.9 The other ‘green’ site in Penyffordd is at ‘Beverley’, PEN006. The wishes of the community are that this side of Vounog Hill / Wrexham Road remain green field and the Place Plan 2.2. (reference 3.21) reflects this. We understand from neighbouring properties that since Meadowslea was built there have been problems with drainage on this land, leading to running water at times and therefore it should be designed ‘Amber’.
20.10 On a point of consistency, the planning department’s report on the Hawarden Road application in Penyffordd referred to the Penyffordd Place Plan objective 3.06 which describes the will of the village not wanting developments larger than 25 homes. In the report the officer expressed the opinion that developments of 25 homes were not viable or good use of land. Site PEN006 would yield fewer than 20 houses. Why then does it comply with the spatial strategy and if it is does, then either the Hawarden Road report was wrong or the strategy is wrong?
20.11 There needs to be some more clarity around the criteria used to assess sites. We noted that beyond Penyffordd there are sites as large as 7.7 hectares (Drury), 9.67 Hectares (Drury), 5.18 (Leeswood), 21 hectares (Mancot) and 37 hectares (Mancot) in sustainable villages, yet in another one of 4.49 hectares (Caerwys) is excluded ‘because of the position of the settlement in the hierarchy’. Is there a size constraint or not and how ‘sustainable’ is ‘sustainable’?
Candidate Site Specific Feedback:
Due to the contribution already made to housing in the LDP period, no further sites should be considered in Penyffordd / Penymynydd in this plan period. The comments below are made in the interests of being constructive – but do not change this fundamental point.
PEN001 Wrexham Road Bryn yr Haul 0.1815 Hectare
Possible boundary change (AMBER)
Due to the contribution already made to housing in the LDP period, no further sites should be considered in Penyffordd / Penymynydd in this plan period.
Place Plan References:
3.21 Vounog Hill Land east of Vounog to be designated as green barrier or green wedge.
PEN002 Bank Farm 2.747
Does not comply (RED)
We agree, this site does not comply but we would like to see it developed as a barn conversion or small commercial business - the site is currently in a state of disrepair
Place Plan References:
3.13 Ensure that the settlement boundary does not extend towards Broughton from Penymynydd particularly in light of the plans for the strategic development of Warren Hall.
6.04 Change of use: Agricultural & Disused Buildings Proposals for the regeneration of derelict sites or alternative use of agricultural buildings within the ward will be supported providing they comply with the requirements of other policies in this plan and where the proposals would not have a detrimental impact on the, rural setting, residential amenity of neighbours and traffic environment.
PEN003 Station Way 1.704
Complies but with constraints (AMBER)
Known drainage issues with this land - not a natural extension of the settlement
Place Plan References:
3.07 Candidate sites above 1.6 hectares should be discounted as too large for the
settlement. The Plan for 2030 section highlights the candidate sites the community
believe should be assessed under the LDP - this does not represent part of this Plan,
merely advisory and based on local knowledge. Nor does it represent an endorsement
of any of the remaining sites.
PEN004 Offas Dyke 0.9997
Complies but with constraints
Concerns over access to the site which would need to be better understood. Concerns over bypass noise.
Place Plan References:
3.02 The A550 Pen-y- fford bypass (constructed in 1986) does not represent the settlement boundary.
PEN005 South of Rhos Road 0.942882
Complies but with constraints (AMBER)
Application already submitted for retirement apartments. The expectation is that the authority will recommend refusal.
PEN006 Beverley, Wrexham Road 0.4777
Complies (GREEN)
Known drainage issues with this land.
Place Plan References:
3.21 Vounog Hill Land east of Vounog to be designated as green barrier or green wedge.
PEN007 Hope Hey, Rhos Road 0.2985
Complies but with constraints (AMBER)
Detached from the settlement.
Place Plan References:
3.02 The A550 Pen-y- fford bypass (constructed in 1986) does not represent the settlement boundary.
PEN008 Bryn yr Haul, Wrexham Road 0.79038
Does not comply (RED)
Detached from the settlement.
Place Plan References:
3.13 Ensure that the settlement boundary does not extend towards Broughton from Penymynydd particularly in light of the plans for the strategic development of Warren Hall.
PEN009 Hawarden Road 1.36216 duplicate (see PEN040)
Does not comply (RED)
Detached from the settlement.
Place Plan References:
3.13 Ensure that the settlement boundary does not extend towards Broughton from Penymynydd particularly in light of the plans for the strategic development of Warren Hall.
3.07 Candidate sites above 1.6 hectares should be discounted as too large for the settlement. The Plan for 2030 section highlights the candidate sites the community believe should be assessed under the LDP - this does not represent part of this Plan, merely advisory and based on local knowledge. Nor does it represent an endorsement of any of the remaining sites.
PEN013 Station Way 1.07615
Complies but with constraints (AMBER)
Concerns over access to the site and known site drainage problems.
Place Plan References:
3.13 Ensure that the settlement boundary does not extend towards Broughton from Penymynydd particularly in light of the plans for the strategic development of Warren Hall.
PEN014 Rhos Road 1.57806 (approved)
Now has planning permission (GREY)
Planning permission has been granted for 40 dwellings.
Place Plan References:
3.02 The A550 Pen-y- fford bypass (constructed in 1986) does not represent the settlement boundary.
PEN015 Railway Station (Employment) 0.292692
No need for land such as this (PURPLE)
Although larger scale employment land has been allocated, there is justification for small starter units for local businesses.
Place Plan References:
6.01 Siting of Businesses Proposals to develop small light industrial, small offce and retail sites close to the A550 / railway station will be supported provided they comply with the requirements of other objectives in this plan.
6.02 The objective is to promote the best sites for business in the ward in respect of road services, sustainable transport for employees and the impact on the surroundings.
PEN016 Railway Station (Employment) 2.33272
No need for land such as this (PURPLE)
Although larger scale employment land has been allocated, there is justification for small starter units for local business
Place Plan References:
6.01 Siting of Businesses Proposals to develop small light industrial, small offce and retail sites close to the A550 / railway station will be supported provided they comply with the requirements of other objectives in this plan.
6.02 The objective is to promote the best sites for business in the ward in respect of road services, sustainable transport for employees and the impact on the surroundings.
PEN031 Penyfford school fields (mixed use) 0.434518
Windfall potential (AMBER)
This site will be available for development from 2020 but not as housing 'windfall'. The community would like some guarantee openspace to ensure the future of community events. The community would like to explore the possibility of using part of the site to house a relocated Spar shop via landswap or incentive. Alternatively the community would like to explore the possibility of re-introducing some healthcare provision in the village on part of this site.
Place Plan References:
6.08 While many villagers are keen for additional choice and capacity in food retail within the village of Pen-y- ffordd, we must be mindful of the need to protect village size and community life and for businesses to be sustainable and appropriate for the village/ward resident numbers. New retail premises must fit into the feel of the village and not cause a reduction in the quality of life of existing and future residents.
6.09 Provision of Health Services
Proposals for the re-introduction of a healthcare facility in the village would be welcomed where the design is of a scale and design fitting of a village environment, provide adequate parking provision and a robust tra c plan. They must not have a detrimental impact on the residential amenity of neighbours including issues of noise, traffic congestion, smells and vibration.
PEN032 Penyffordd school (community facility) 0.713924
Windfall potential (AMBER)
See PEN031
See PEN031
PEN033 Melwood Close 0.108145
Windfall potential (AMBER)
Planning permission has been granted for 5 dwellings but we understand there is a problem with agreeing S106 contributions. The Council are keen to bring forward this development.
Place Plan References:
3.26 The former clinic on Melrose Close need to be reused for development or open space - it should not remain in the current state.
PEN034 Abbots Lane (housing) 0.288797
Windfall potential (AMBER)
Site has been agreed as the location of the single site school, subject to planning permission.
PEN035 Spar 0.139276
Windfall potential (AMBER)
See PEN031 - the location of the Spar on this site is not sustainable and proactive efforts are needed to relocate the grocery store within the village, potentially off-Chester road on the old school grounds. This site could be used for affordable housing potentially in a land-swap arrangement.
PEN036 Hawarden Road 1.36216 duplicate (see PEN040)
Complies but with constraints (AMBER)
See PEN009
PEN037 Wood Lane Farm (North) 3.48232 duplicate (see PEN040)
Complies (GREEN)
It is not clear how this site complies with the Spacial Strategy where others do not. The community have been suspicious about the intentions for this land since the access road was built and the application went in on the Hawarden Road site. There are serious concerns about access, the loss of agricultural land, the use of the by pass as a boundary and above all the size of the potential development - potentially over 100 home is not sustainable in a single development.
Place Plan References:
3.06 Size
The will of the village that there is no more growth under the LDP but if developments are permitted, the maximum acceptable size of an individual site must not exceed 25 homes.
3.07 Candidate sites above 1.6 hectares should be discounted as too large for the settlement. The Plan for 2030 section highlights the candidate sites the community believe should be assessed under the LDP - this does not represent part of this Plan, merely advisory and based on local knowledge. Nor does it represent an endorsement of any of the remaining sites.
3.02 The A550 Pen-y-fford bypass (constructed in 1986) does not represent the settlement boundary.
PEN038 Chester Road 7.69755
Complies but with constraints (AMBER)
Application for 186 houses is ubject to a public inquiry and considered an excessive incursion into open countryside and too large to be sustainable in both the UDP inspectors report and the Planning Officers report on the Redrow application. Should have been a 'red' does not comply with the strategy in this consultation.
Place Plan References:
3.13 Ensure that the settlement boundary does not extend towards Broughton from Penymynydd particularly in light of the plans for the strategic development of Warren Hall.
3.07 Candidate sites above 1.6 hectares should be discounted as too large for the settlement. The Plan for 2030 section highlights the candidate sites the community believe should be assessed under the LDP - this does not represent part of this Plan, merely advisory and based on local knowledge. Nor does it represent an endorsement of any of the remaining sites.
PEN039 Rhos Road 1.57806 (duplicate?)
Now has planning permission
Duplicate site see PEN014
PEN040 Wood Lane Farm (Combination of duplicates) 4.8156
Complies but with constraints
Combination of sites PEN037 and PEN009
Place Plan References:
3.07 Candidate sites above 1.6 hectares should be discounted as too large for the settlement. The Plan for 2030 section highlights the candidate sites the community believe should be assessed under the LDP - this does not represent part of this Plan, merely advisory and based on local knowledge. Nor does it represent an endorsement of any of the remaining sites.
3.02 The A550 Pen-y-fford bypass (constructed in 1986) does not represent the settlement boundary.
PEN041 School 5.71775
See PEN034
PEN043 Abbots Lane Fields (housing) 1.81334
Windfall potential (AMBER)
See PEN034
Place Plan References:
3.07 Candidate sites above 1.6 hectares should be discounted as too large for the settlement. The Plan for 2030 section highlights the candidate sites the community believe should be assessed under the LDP - this does not represent part of this Plan, merely advisory and based on local knowledge. Nor does it represent an endorsement of any of the remaining sites.
PEN044 Penyffordd School (mixed) 1.14844 (duplicate)
Windfall potential (AMBER)
See PEN031
See PEN031
Place Plan References:
3.07 Candidate sites above 1.6 hectares should be discounted as too large for the settlement. The Plan for 2030 section highlights the candidate sites the community believe should be assessed under the LDP - this does not represent part of this Plan, merely advisory and based on local knowledge. Nor does it represent an endorsement of any of the remaining sites.
Comments specific to Dobshill:
21.1 The disused Council depot site at Dobshill – DOB004 is already earmarked by the Council for development of 24 affordable homes. Dobshill should have no other growth aside from this Council development.
Place Plan References 3.08 Growth in Dobshill is limited to development of the brownfield former council depot only; 3.24 Dobshill depot needs to be reused for development or open space – it should not remain in the current state.
Appendix 1
Table 3
LDP Site Analysis
