Wednesday 10 January 2024

Reasons to oppose the 455 homes on the circus fields off the A483

On 8 January 2024, Wrexham Council's planning committee narrowly approved plans by Russell Homes to build 455 houses on green fields next to the A483.

The site was allocated under the council's controversial Local Development Plan, approved on 20 December 2024 and still open to appeal.

Plaid Cymru councillors Pete Howell (Gwersyllt South) and Marc Jones (Grosvenor) spoke against on the following grounds:

1. Air quality
There are signs on the A483 stating that pollution kills and we need to cut our speed to cut our emissions because of the pollution. Yet this plan will put a children's play area right next to this busy road and this planning committee is being asked to approve this strategy of placing young lungs in an area deemed of greatest risk. This is despite an Air Quality Act currently making its way through the Senedd and which, I believe, should be given significant weight. That's not an encouraging start.
The Air quality assessment considers Nitrogen Dioxide and particulates known as PM10 and PM2.5. PM2.5 is the most toxic and deadly micro-particulate, because it is smaller and gets into the lungs. In light of the newly adopted LDP policy on air quality, I believe the council needs a new updated assessment because the report has not been updated to confirm that the number of “receptors” (i.e. humans affected) takes into account recent developments in the area.

2. Health 
Health provision is also raised in the report - we all know where we are with accessing GPs, A&E and ambulances in the area now. Betsi Cadwaladr health board raises "significant concerns about the sustainability of local Primary Care services if the proposal goes ahead and about the physical space available within current Primary Care facilities to accommodate more patients in the area, as well as clinical staffing concerns."
That should give us all pause for thought. Where are the people that would move onto this estate going to access a GP? We have a planning system that states it's not our problem. It's there in black and white in this report. We acknowledge we're making things more difficult for the NHS but tough.
That's not the fault of planning officers but it is why I believe our planning system is broken. It's not fit for purpose if it doesn't take a holistic view of the impacts of its decisions.

3. Highways matters 
As you'd expect with a housing estate of 455 homes on a greenfield site, there will be additional traffic movements. There will be thousands of them every day despite the talk of it being a highly sustainable location. The access to the site is via the Mold Road next to the farm shop and on the Stansty Chain Link, a country lane, that comes under the A483 by Ysgol Plas Coch. Let's look at those two roads in detail because there are a number of junctions that are significantly impacted by this proposed new development.
Firstly the Stansty Chain link - there is already significant gridlock at key times in this part of my ward - people seeking to drop off children at Ysgol Plas Coch, which now has capacity for 315 pupils, so there is already significant pressure at peak times. The police have been monitoring traffic issues on this stretch of the road. The developer's traffic assessment states that the additional traffic outside the school will be 23% - a quarter more vehicles - at that point during the morning peak hour and 73% during the evening peak hour. 
From there, traffic will need to move on to either the Plas Coch roundabout and then the B&Q roundabout or via Stansty Bridge underpass to the Walnut junction, where an additional 7.8% of traffic is anticipated in the morning peak and 7.7% in the afternoon peak.
During the evening peak as well the traffic survey estimates an increase of 15% in the traffic travelling down the Stansty Lane towards this new development as people opt to take this frankly dangerous, unlit and narrow country lane as a rat run to get home. 

This brings me, in passing, to another concern that is unaddressed by these plans - namely pedestrian safety. Much is made of the active travel route whereby everyone from the estate is expected to walk or cycle down Stansty Chain Link, this windy, unlit and narrow country lane to get to town. Despite the application noting no fatal accidents between 2014-18, there have been fatalities on this road in the past decade and there have been serious car accidents more recently. It's a very poor road and there are no plans to make it safer in this application. It will remain a two-way country lane which will have many additional road movements along it if this application is allowed. In addition, once people walk or cycle to Plas Coch, there is no pedestrian crossing for them at either the B&Q roundabout or further along Stansty Road. 

Critically, this area already has junctions that are over-capacity at peak times. The B&Q roundabout, the Plas Coch retail park access roundabout, the main A483 Mold Rd roundabout are all over-stretched in peak hours. The increasing number of vehicles accessing Plas Coch in recent years is due to a series of incremental planning permissions - The Range, a hotel, Costa Coffee, M&S Food Hall, expanded Aldi and a still outstanding application for a McDonalds drive thru - that have put added pressure on these junctions. The traffic assessment produced by the developer accepts that some of the junctions are over-capacity and will be over-capacity in 2030, when it would be likely that this scheme would be nearing completion. So what is the mitigation put in place?

You'd imagine it would have to be substantial. But in reality it amounts to NOTHING on Stansty Chain Link and two very minor changes on the Mold Road roundabout. These amount to adding two sets of traffic lights on the Mold Rd roundabout, which in my view will reduce flow and create more back-up. The other change is so minor that it is laughable - it's to change road markings on the Mold Rd roundabout. The proposal is to change the road markings BACK to how they were a decade ago, when Wrexham Council's Highways Department recognised they were causing congestion. Now this is being proposed by a developer who clearly doesn't want to spend money on proper mitigation and to make the real improvements that would be needed to mitigate the thousands of extra vehicle movements that will occur in this area as a result of this planning application.

Is this just the view of a local councillor? 

No, I want to quote this council's own Highways response to this application dated 27 February 2020: "It is rather surprising, given the significant capacity issues that the report itself raises, that the highways consultant feels there is no justification for the provision of any additional mitigation."

This assessment also confirms that the road-marking changes would take us back a decade when the changes were made, with the approval of the Welsh Government's trunk road agency because there were issues with vehicles queuing back to the A483.

It states: "There are long-standing and well-documented capacity issues in the vicinity of the site. The A541 Mold Rd junction with the A483 at J5 and B&Q roundabout suffer serious traffic queuing issues at peak hours.

The same report describes the Stansty Chain Road as a 'narrow unlit road with poor pedestrian provision and forward visibility'. It goes on to say "It is of inadequate width to permit simultaneous passage of vehicles and is considered to be of inadequate design and layout to cater for additional traffic." 
It also states "Plas Coch Rd and Stansty Rd have both historically suffered capacity issues at peak hours."
It goes on to say that a number of transport studies have been undertaken in recent years on the Mold Rd roundabout and the B&Q roundabout - each has revealed that the junctions are ALREADY over-capacity.

The Walnut junction was the subject of an appeal and recent transport assessment and both revealed that the junction was at capacity during peak hours.
Of course since then there has been significant extra housing in the vicinity - 190 new houses are almost complete at Rhosrobin, 94 new houses are nearing completion on the University campus and work is just starting at New Broughton on 112 houses. These will feed into the B&Q roundabout as well.

The developer, in fairness, has carried out new traffic assessments to see whether demand has changed since these applications were submitted in 2020. What the new surveys show is that most are marginally lower post-Covid but - given that we're meant to be a planning committee and should be planning ahead - then we need to understand that even now these junctions are over-capacity and that the three new housing developments already granted permission amounting to 400 new houses I've just mentioned will add to the pressure. The application in front of us now is bigger than all three of those combined. We're trying to squeeze a quart into a pint pot here - and when something's already full and you keep pouring into it, then something's got to give. 

The developer referred to the 400 flats now becoming 94 homes on the Glyndwr campus. Yes, this is a reduction but they neglected to mention that the 400 flats were approved because they were said to have significantly fewer vehicles than 3 and 4 bed homes and also had an access/exit via Crispin Lane and Mold Rd. That access point is now denied to the 94 homes through a barrier on the campus, meaning that all the traffic from that new estate will have to access via the Plas Coch roundabout. So, no, that is not sufficient mitigation to push ahead with this scheme.

The Welsh Government states that a 5% increase in traffic volumes is a material increase. That means it's a material consideration for this planning committee and justifies refusal because the developer has not put in serious mitigation,

Given the very serious concerns raised by the Highways dept in their 2020 report, and it concludes with "I therefore raise concerns about the suitability of the site for a development of this size", I want to ask whether highways officers are happy with this application. Because if they believe a few road markings and a couple of extra traffic lights on the Mold Rd roundabout are going to sort out the existing over-capacity and the increased traffic this will cause, I have to say we're living in a parallel universe. 

If we get this wrong and we have gridlock, congestion and increased accidents on country lanes, we cannot unbuild these 455 homes.

In summary, there are sufficient grounds to refuse this application on Highways grounds alone but I also believe that the Air Quality issues need to be challenged. If the developer is confident that changing the road markings and adding traffic lights is sufficient to mitigate the added traffic, can we see that mitigation put in place before a single house is built?

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