COMMENTS ON THE CLWYD STRUCTURE PLAN SECOND ALTERATION DEPOSIT These comments are to accompany the Objections and Statements of Support made by Flintshire and Cheshire Green Parties. They are numbered, so that the forms can refer to specific comments. Most of these comments are to be seen as part of an explanation of why the Objection or Support has been given. SC. Strategic Context. SC1. The 'Strategic Context', as it is portrayed leading up to 'Aims' and 'Strategy', is completely unbalanced, considering mainly the economic context and partly the political context, but ignoring other aspects, such as: ecological historical cultural lingual social general lifestyle of the people. These aspects of the context are important for drawing up a strategic development plan such as this Structure Plan Alteration. Therefore we want to see this part rewritten to include specific discussion of these aspects of the context. SC2. The section on neighbours (1.2) is likewise unbalanced. Most of the discussion concerns a stretch of boundary that is only one eighth of Clwyd's boundary with neighbours, namely that with Cheshire/Wirral. To say "Clwyd's major external links are with Cheshire and Wirral" is only true from the point of view of transport and built environment. From other land-use factors, such as ecological, agricultural, aesthetic (landscapes), and the like, the other seven eighths of the boundary are important, and should not be ignored. The Plan seems to see Clwyd as the poor relation of Cheshire and Merseyside. This is unfortunate to say the least. The Plan should build on Clwyd's strengths and unique points, for the good of the whole area, not just follow lamely where others lead. It is admitted that Clwyd's economy is 'relatively weak' but economy is not the only aspect, as mentioned above. The section does not discuss what Clwyd's contribution or responsibility is to her neighbours. The section should therefore be rewritten in accordance with the above comments. SC3. Aims The aims are too demand-led. ("have special regard to the aspirations") In this, they go against recent PPGs. While the "needs" of local communities should be important, to be led by their "aspirations" is dangerous. SC4. Reduction of unemployment should not be the first aim. Rather, Aim iii is better at the head of the list, since "Clwyd's ability to meet its own needs" includes ensuring long-term employment opportunities. Aim i is thus a sub-set of Aim iii. SC5. However, even Aim iii is flawed. "Clwyd's ability to meet its own needs" is dangerous since what are "Clwyd's own needs"? Without definition, they will be defined in the future in an ad hoc way by vested interests or vocal groups. We propose that the concept of "Sustainability" replace "Clwyd's own needs". Many local authorities now are moving toward this concept (e.g. Cheshire, Warrington). Sustainability includes many factors, and planning for it will help to ensure that no important factor is ignored. Social and ecological factors are more fundamental, and therefore more important, than economic. SC6. Even if reducing unemployment is taken to the first aim, two means to achieve this, "encouragement of existing firms" and "attraction of inward investment" are dangerous and likely to be counter-productive. "Existing firms" include those that have come in from outside because of subsidies rather than because they believe Clwyd has any intrinsic value to them, and thus they have no loyalty. They can close down their operations with even greater ease, leaving Clwyd vulnerable. Therefore, this phrase should be replaced by "encouragement of locally-controlled firms". Such firms have intrinsically a closer link with Clwyd. "Inward investment" makes this situation even worse. Policies that attract inward investment act against local firms. The incomers, with their greater financial mass, can unfairly compete with local firms, and put them out of business. If anything, inward investment should be discouraged rather than attracted. The attraction should be for locally owned and controlled firms. SC7. The Aims conflict with the Strategies. SC8. We support the strategy of "Using existing resources". SC9. We support the strategy of ".. reducing the need to travel." SC10. In 1.4.6 the words "affordable" and "adequate" need definition. As it stands, any house is "affordable" in the sense that somebody has afforded it. So it should be replaced by a more defined term, such as "low cost". "Adequate rural housing" could open the door to creeping suburbanisation of the rural areas and especially villages. GDP. General Development Policies GDP1. Policy GEN2. We both support and object to policy GEN2. We believe it is important that development should minimise resource consumption, including all the sub-clauses shown. GDP2. Policy GEN2. We wish a further sub-clause to be added: "G Existing non derelict commercial, business and industrial allocations shall be fully used before derelict ones are used." The reason is that often 'derelict' sites are valuable as wildlife habitats. GDP3. GEN2. While we generally agree with the sentiment and content of this policy, we strongly object to the wording of the policy on the grounds that it is malformed. The inclusion of the words "for example" severly weakens the policy to the extent that it is not worth including. Policies should be precise, and not list examples. The reason is that examples are not binding. Any developer can twist a list of 'examples' to his own ends. The place for examples is in the accompanying text, not in the policy itself. It is accepted that the list given is not exhaustive, but in that case some more general statements should be made that encompass the things desired. However, we believe that the sub-clauses as given are strong enough to stand as they are. Therefore we propose: delete the words "for example". GDP4. Policy GEN3. In B remove the words "where appropriate", since this is against PPG. GDP5. GEN3. In C, "where they can be served by public transport" weakens the clause to the extent of being meaningless. As it is worded, anywhere on the road system would fulfil this condition, because it "can" (i.e. is in theory able to be) be served by "public transport" (in the shape of mini- buses). Having thus located such "major trip generating developments", there will be nothing that can stop people from using their cars to get there, even if "public transport" were provided. So the condition is meaningless as it stands. The intention of the clause is, of course, to aid the shifting of transport away from private car. To achieve this, bus is not the answer. Instead, the real answer is to locate next to rail facilties, and also to ensure that access by cycling is a real possibility. Of course, since Clwyd has only a skeleton rail system locating next to rail means that the rail system must be expanded. Therefore there should be policies under Transport to start this process. GDP6. GEN4. Sub-clause D should be removed. Providing parking actually attracts private cars, and hence works against the strategy of minimizing travel demand. T. Transport policies. T1. General. This section is a disaster, and will work against the strategy of "reducing the need to travel". There is very little on rail, and almost nothing on cycling, walking and water as means of transport. T2. Rail. While policy TRANS1 is useful, there should be more policies on rail, including: 1. Protection of rail trackbed from being developed so that in future the rail route can be re-opened if necessary. 2. Identification of routes for rail access to industrial and commerical areas, and protection of those routes from development. So that in future the businesses are not precluded from using rail when it is deemed right to do so. 3. Identification of rail routes for which initial action should be taken to (re-)open them. Especially to bring rail services back to Mold. 4. While identification of sites for new or re-opened stations might be the prerogative of Borough Plans, the Structure Plan should have a general policy of support for the re-opening of rail stations. It should identify communities for which rail access would be useful. T3. Cycling. Cycling is an important means of transport, for both work, shopping and leisure. However, it is jeopardised by being ignored, so that for instance roads that used to be safe for cyclists become unsafe. We want the following polciies: 1. No traffic-generating development will be allowed on quiet roads, since they are or are likely to be used by cyclists. 2. In heavily populated areas cycle routes separated from car routes will be identified and where necessary constructed or brought about by traffic management schemes. These cycle routes to be designed according to the real needs of cyclists (as flat and direct and direct as possible), and be surfaced according to the need of cyclists (i.e. smooth). (Flat: where road and cycle route cross the cycle route should be flat and the road made to pass over it, not the other way round; since a steep uphill portion will repel would-be cyclists.) 3. Facilities for cyclists will be required in all developments. All commercial and industrial development to install lockable cycle racks. All area developments (e.g. housing estates, office estates) to provide separate direct cycle routes. T4. Walking. Well over 50% of journeys are made by walking. All journeys start and end with walking (even if it is only a few yards). Walking enhances the health of the people of Clwyd. Walking produces no polluting gases. When walking, people notice things about their locality and come to value it more. When walking, people are more sociable to each other. But walking needs to be pleasant. Too often what used to be a convenient walking route to the shops is made inconvenient and ugly by the design of a new road system. Far too little consideration has been taken of this in the past. There should be policies on walking. 1. All developments, and all road developments, to survey the current pattern of walking, and be designed not to damage it. 2. All developments to be designed to make access on foot very easy. 3. If a local shop has high walking access, then no developments to be allowed that will threaten its viability. 4. All shopping developments to have the shops close enough together as to encourage walking between them. (Many out-of-town shopping developments have the units so far apart psychologically that people use their cars to go a couple of hundred yards from one to the other.) 5. All walking routes to be kept under good repair and, where vandalism is high, well lit. T5. Water for transport. Use of canals as means of transport should be explicitly recognised and encouraged. T6. Car parking. Car parking and Park-and-Ride should be located at railway stations where possible. T7. TRANS2. Remove "Mostyn Docks". T8. TRANS4. "To reduce travel costs" should not be "first priority" since it works directly against the strategy of "reducing the need to travel". T9. TRANS5,6. Bypasses might reduce local congestion for a while, but do not solve the real problem. It: a) merely shifts the congestion to the next bottleneck b) encourages more traffic, and so c) makes the traffic problem worse after a few years. A case in point is the Edinburgh bypass. Since the bypass was built, the traffic in Edinburgh has actually increased. The same traffic-generation effect pertains to trunk road provision. It acts both in the short term and the long. In the short term people perceive that the road to so-and-so is 'easier' and so will, on average, make that journey more often. In the longer term business, industry and housing will locate further down the road, so that trips to and from them become longer. Building new and better roads also causes other well known problems, such as destroying SSSIs and other wildlife habitats, cutting wildlife movement, cutting farms and thus damaging their economic vitality as farms. A particular problem is that when a trunk road is built into an area "to open it up" then outside firms start entering, and putting the local firms out of business. So both TRANS5 and TRANS6 should be deleted. Now that we must face the problem of too much traffic, congestion should be seen as the planner's friend. If they cannot be deleted in their entirety, then we wish to discuss those schemes that will be the more damaging at the EIP.