Registered Charity Number:515757
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The Porthcawl Civic Trust Society was formed in 1970 and is one of a number of Civic Trusts to be found in Wales.
The main aims of the Civic Trust are:
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1. Data Protection:
The only information held electronically by the Porthcawl Civic Trust Society is the email addresses of those members who have expressed a willingness to receive information by email. Members' email addresses are not made available to third parties.
2 History of Porthcawl (February 2020):
The Society has produced 3 reports under the general heading 'Porthcawl: Much More Than Meets the Eye' and and a fourth report will be completed as time permits. All reports are over 100 pages long. The 3 reports are now available for veiwing and downloading.
The following is a very brief synopsis of each report.
Stage 1 covers the early residential area of the town ie The Square, Dock Street, Hillsboro Place etc together with the history of the inner and outer docks, the Eastern Prom. the Jennings Warehouse and Cosy Corner.
b) Stage 11 Part A, covers Newton, Nottage and the western part of the Porthcawl It looks at the history of the Rest Home, Rest Bay, Locks Common and the Prom and some of the main buidings in that area. The deveopment of golf and sea sports is also examined
c) Stage 11, Part B, covers 'old Porthcawl', as well as South Road, John Street, Wells Street, Lias Road, Station Hill and New Road. It also includes the areas around Griffin Park, the fairground and Trecco Bay Holiday Park.
d) The final report will concentrate on those areas of the town that haven't previously been covered.
In order to download the reports, please go to the History Of Porthcawl
The following is a very brief synopsis of each report.
Stage 1 covers the early residential area of the town ie The Square, Dock Street, Hillsboro Place etc together with the history of the inner and outer docks, the Eastern Prom. the Jennings Warehouse and Cosy Corner.
b) Stage 11 Part A, covers Newton, Nottage and the western part of the Porthcawl It looks at the history of the Rest Home, Rest Bay, Locks Common and the Prom and some of the main buidings in that area. The deveopment of golf and sea sports is also examined
c) Stage 11, Part B, covers 'old Porthcawl', as well as South Road, John Street, Wells Street, Lias Road, Station Hill and New Road. It also includes the areas around Griffin Park, the fairground and Trecco Bay Holiday Park.
d) The final report will concentrate on those areas of the town that haven't previously been covered.
In order to download the reports, please go to the History Of Porthcawl
3 Regeneration
Report March 2023
Collaboration: the Council will collaborate with residents, visitors and end users of this project to ensure successful and sustainable development and outcomes
Involvement: ongoing engagement with the community will be an important facet of this project
2. In a letter to the Society dated 21 December 2021, the Office of the Future Generations Commissioner pointed out that Planning Policy Wales had stated:
‘It is crucial when, in developing plans, planning authorities engage with people in their own communities, facilitating a collective, participatory process which focuses on achieving sustainable places. This requires engagement which goes beyond the statutory minimum for consultation set out in planning legislation and in accordance with the involvement principle set out in the Well-being of Future Generation Act’ (Our bold)
3. It is against these criteria that the Society believes the level of BCBC’s consultation and commitment should be measured.
EXAMPLES OF BCBC’s LACK OF MEANINGFUL CONSULTATION
Revised Local Development Plan (RLDP)
BCBC is arguing that Porthcawl’s residents were given the opportunity to comment on the regeneration plan when consultation took place regarding the RLDP and BCBC provided a good deal of information about the methods used to keep residents informed about the RLDP and to give them the opportunity to comment. It is accepted that BCBC followed the correct procedures as required under planning legislation. However, although BCBC considered the consultation to have been ‘highly effective’, out of a population of 145,000 (2021 census) just 1,221 representations were received – less than 1% of the population. This suggests that there was either widespread apathy or that, despite BCBC’s efforts, the vast majority of residents were not aware that they had the opportunity to comment.
The Committee wrote to BCBC on 22 September 2022, to suggest that very few residents will have heard of the RLDP, let alone taken part in any consultation. We asked:
‘The information which you have requested is exempt under Section 21 of the Freedom of Information Act which states
Information accessible to applicant by other means
The information requested is already in the public domain on the BCBC website via the following links.’
2 links were provided but the Committee was unable to find the information it had requested.
As a result, the Committee emailed Cllr Neelo Farr on 24 February to ask whether she could sort this out. Cllr Farr responded on 27 February by forwarding the following statement by a BCBC officer.
‘Dear Cllr Farr,
There has been extensive consultation on the LDP at various stages of its preparation.
It will be very difficult to pinpoint exactly how many representations specifically are from Porthcawl residents or whether they support the regeneration proposals. (Our bold)
The deposit draft consultation yielded over 1200 responses from the plan area.
All relevant information is available on line as part of the examination document library where the council has responded to the comments that have been made.’
A link was provided and the Society was able to find some of the information it had requested.
Having found some information on the link, it was clear from the comments made by Porthcawl and Pyle residents that they were responding to a questionnaire form and, as a result, each respondent had provided a number of comments. So, although BCBC lists about 210 comments in total, the number of respondents would have been considerably less than that number – only BCBC can provide this information. It was not easy to analyse the responses but, as far as one could tell, it seems that about 12 were broadly supportive of BCBC’s proposals while about 80 expressed opposition or concern regarding the number of dwellings to be built on Salt Lake and Sandy Bay and/or the loss of car parking facilities.
The Society’s concern is that, while BCBC has claimed that ‘There has been extensive consultation on the LDP at various stages of its preparation’. it is still unable to say whether Porthcawl residents ‘support the regeneration proposals.’
The Food Store
No consultation took place as required under the Well-being Act. Indeed, BCBC has agreed that:
‘Consultation on this project was principally managed via the planning process -----’
This is tantamount to admitting that the terms of the Well-being Act were not followed.
Cosy Corner
In an article about Cosy Corner that appeared in the April 2021 issue of Seaside News, Cllr Hywell Williams stated:
‘You can expect to see an opportunity for people to comment upon the plan very soon’
This was repeated in June 2021 by Cllr Charles Smith in a paper produced on the BCBC website when he said:
‘We will be organising a public engagement later in the year for people to comment on the plans before they are finalised.’
However, in a Report by the Corporate Director Communities dated 19 October 2021, it was stated:
Collaboration: Further action on Cosy Corner as outlined above will take place in collaboration with partners though the Harbour Operations Group and the Harbour board
Involvement: Proposals relating to the future of Cosy Corner will be developed and delivered in close partnership with key stakeholders. Discussions and development with key BCBC officers will be undertaken.
No mention was made of the previous proposals for the involvement of residents and, again, the terms of the Well-being Act were ignored.
Griffin Park
While it is accepted that the proposal to appropriate part of Griffin Park was advertised as require by planning legislation, the question remains – did this engagement go ‘beyond the statutory minimum set out in planning legislation and in accordance with the involvement principal set out in the Well-being of Future Generations Act’?
We asked whether BCBC could provide examples of how the consultation went ‘beyond the statutory minimum’. No reply has been received.
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Action taken by the Committee.
5 December 2022: A letter was sent to the Office of the Future Generations Commissioner pointing out BCBC’s continuing failure to abide by the requirements of the Well-being of Future Generations Act.
15 December 2022: A reply was received saying the that they were unable to take on casework functions. The Commissioner suggested we contact the Auditor General.
20 January 2023: A further letter was sent to the Commissioner saying that, while we recognised that the Commissioner could not look at every individual case where councils failed to honour the terms of the Well-being Act, could the Commissioner take up the matter with BCBC due to its constant failure to abide by the terms of the Act.
14 February 2923: In the reply, the Commissioner that said ‘we have a lot of sympatry for the concerns you and the community have raised and understand that this response is disappointed, but for the reasons we have outlined above and in previous letters, we cannot get involved on this occasion.’
30 November 2022: Formal complaint put to BCBC regarding its failure to honour the terms of the Well-being of Future Generations Act.
23 December 2022: A 7 page reply was received though nothing new was included
25 January 2023. Having made a formal complaint to BCBC, the Committee was now able to make a complaint to the Public Services Ombudsman for Wales
7 February 2023: A reply was received saying the Ombudsman could not become involved as no individual had suffered as a result of BCBC’s actions.
Latest Action
!) We are in touch with Jamie Strong and Gemma Lewis, A voice for the Future – Porthcawl, and Margaret Minhinnick, Sustainable Wales, who share the same concerns as ourselves regarding BCBC’s regeneration plan.
2) A Welsh Assembly Government inspector is currently examining BCBC’s Local Development Plan and the Committee has written to explain our concerns..
What next?
The possibility of writing to the Auditor General will be discussed at the Committee’s next meeting.
Comments
Would be welcomed.
4 Letter to Auditor General
7 April 2023
Dear Auditor General,
The Porthcawl Civic Trust Society (the Society) is writing to you at the suggestion of the Future Generations Commissioner for Wales
As you may be aware, Bridgend County Borough Council (BCBC) has presented plans for the regeneration of Porthcawl, some elements of which have been met with strong opposition from residents. It is widely felt that insufficient consultation has taken place especially bearing in mind the requirements of the Well-being of Future Generations Act 2015 and of Planning Policy Wales.
Collaboration: the Council will collaborate with residents, visitors and end users of this project to ensure successful and sustainable development and outcomes
Involvement: ongoing engagement with the community will be an important facet of this project
2. In a letter to the Society dated 21 December 2021, the Office of the Future Generations Commissioner explained that Planning Policy Wales had set out the following policy:
‘It is crucial when, in developing plans, planning authorities engage with people in their own communities, facilitating a collective, participatory process which focuses on achieving sustainable places. This requires engagement which goes beyond the statutory minimum for consultation set out in planning legislation and in accordance with the involvement principle set out in the Well-being of Future Generation Act’ (Our bold)
3. It is against these criteria that the Society believes the level of BCBC’s consultation and commitment should be measured.
The Society’s concerns fall into 2 main categories.
THE OVERALL PLAN
BCBC has stated that residents have had 2 opportunities to make their views known regarding its overall plan for the town, namely:
BCBC is arguing that Porthcawl’s residents were given the opportunity to comment on the regeneration plan when consultation took place regarding the RLDP. BCBC has provided a good deal of information about the methods used to keep residents informed and, as far as the Society can tell, BCBC seems to have followed the correct procedures as required under normal planning legislation. Nevertheless, although BCBC regarded the exercise as being ‘very successful’, only 1221 responses were received (0.9% of the population of the borough).
The Society wrote to BCBC on 22 September 2022, to suggest that very few residents will have heard of the RLDP, let alone taken part in any consultation. We asked:
Following our third attempt to obtain answers to the above questions, by making use of the Freedom of Information Act, BCBC replied on 14 February, as follows:
‘The information which you have requested is exempt under Section 21 of the Freedom of Information Act’:
BCBC went on to say:
‘The information requested is already in the public domain on the BCBC website via the following links.’
2 links were provided but the Society was unable to find the information it had requested.
As a result, the Society emailed Cllr Neelo Farr on 24 February, to ask whether she could help the Society gain access to the information requested. On 27 February, Cllr Farr forwarded the following response from a BCBC officer:
‘Dear Cllr Farr,
There has been extensive consultation on the LDP at various stages of its preparation.
It will be very difficult to pinpoint exactly how many representations specifically are from Porthcawl residents or whether they support the regeneration proposals. (Our bold)
The deposit draft consultation yielded over 1200 responses from the plan area.
All relevant information is available on line as part of the examination document library where the council has responded to the comments that have been made.’
So, despite the ‘extensive consultation’ that took place regarding the RLDP, when Porthcawl’s residents had the opportunity to comment (and have their views taken into account?) and BCBC’s statement that ‘The information requested is already in the public domain on the BCBC website’ BCBC is still unable to say how many Porthcawl residents responded to the consultation or whether they ‘support the regeneration proposals.’
In the Society’s view, this clearly demonstrates BCBC’s failure to seek, make note of or act upon, the views of residents or abide by the requirements of the Well-being of Future Generation Act or of Planning Policy Wales. This is, of course, also contrary to Principle 4 of The Gunning Principles which states:
‘conscientious consideration’ must be given to the consultation responses before a decision is made
Decision-makers should be able to provide evidence that they took consultation responses into account.
(Local government Association)
2. The Placemaking exercise
This exercise was carried out by Austin-Smith:Lord (ASL) in the latter half of 2021 and had ASL been given a blank piece of paper, so enabling the views of those organisations taking part to be fully reported and acted upon, this would have been a useful and important exercise. However, as can be seen from item 2.2 of the report, this was not the case.
‘Item 2.2 PLANNING CONSENT
The Placemaking strategy has been developed within the existing Planning Policy context of the existing Local Development Plan and associated Supplementary Planning Guidance and also informed by separate consultation on the Replacement Local Development Plan.
With specific regard to the existing planning policy context the site is currently allocated for mixed development within the existing Local Development Plan. Policy PLA3 of the Adopted Local Plan sets out the council’s objectives for mixed use regeneration of brownfield, underutilised sites and identifies the Porthcawl Regeneration Area as being a significant part of this strategy through its allocation as site PLA3(8). This allocation is supported by adopted Supplementary Planning Guidance (SPG) often referred to as the Seven Bays Project – Porthcawl Waterfront SPG’
As can be seen, the result of the exercise was largely predetermined as any recommendations made in the report had to be in line with the masterplan that had already been decided. As such, although there was some change to the plan for Salt Lake, the exercise was largely a waste of time and the ‘consultation’ that took place could not be described as meaningful. This would seem to conflict with Principle 1 of The Gunning Principles which states:
Proposals are still at the formative stage.
A final decision has not yet been made, or predetermined, by the decision makers.
(Local Government Association)
DETAILED ELEMENTS OF THE PLAN
Indeed, BCBC has agreed that:
‘Consultation on this project was principally managed via the planning process -----’
This is tantamount to agreeing that the necessary ‘engagement which goes beyond the statutory minimum for consultation set out in planning legislation’ did not take place.
On 2 occasions (April 2021 and June 2021) prior to the commencement of the development, BCBC announced that people would have the opportunity to comment on the plan before any final decision was made for the area. Despite these assurances, no such consultation took place.
Indeed, in a Report by the Corporate Director Communities dated 19 October 2021, it was stated:
Collaboration: Further action on Cosy Corner as outlined above will take place in collaboration with partners through the Harbour Operations Group and the Harbour Board
Involvement: Proposals relating to the future of Cosy Corner will be developed and delivered in close partnership with key stakeholders. Discussions and development with key BCBC officers will be undertaken.
No mention was made of the previous proposals for the involvement of residents.
We asked whether BCBC could provide examples of how the consultation went ‘beyond the statutory minimum’. No reply has been received.
Conclusion
The main concerns being expressed by residents relate to BCBC’s proposals to build 1150 dwellings on 3 sites along Porthcawl’s waterfront and the resulting loss of well over 1000 car parking spaces. While it is accepted that some housing is required which will inevitably lead to some reduction in car parking spaces, BCBC has declined to enter into any real consultation on these 2 matters. Porthcawl is a seaside town and sufficient car parking facilities are essential if the town is to survive. BCBC has announced that a multi storey car park is planned but, again, there has been no attempt to enter into any consultation regarding that intention.
Although BCBC has not said so, it may have it in mind to consult with residents once the plans are more settled but the Society believes that consultation needs to take place at an early stage so that the views of residents can be taken into account before the plans are progressed.
The Society hopes that you will be able to take issue with BCBC over its repeated failure to honour the conditions of the Well-being of Future Generations Act and the policy set out by Planning Policy Wales. The Society hopes that BCBC will agree to enter into meaningful consultation with residents. Even then, such consultation will only be of value if BCBC is prepared to listen to and act upon the wishes of residents.
Yours sincerely,
Don Tickner
Porthcawl Civic Trust Society
Report March 2023
- Since September 2020, BCBC has repeatedly stated~
Collaboration: the Council will collaborate with residents, visitors and end users of this project to ensure successful and sustainable development and outcomes
Involvement: ongoing engagement with the community will be an important facet of this project
2. In a letter to the Society dated 21 December 2021, the Office of the Future Generations Commissioner pointed out that Planning Policy Wales had stated:
‘It is crucial when, in developing plans, planning authorities engage with people in their own communities, facilitating a collective, participatory process which focuses on achieving sustainable places. This requires engagement which goes beyond the statutory minimum for consultation set out in planning legislation and in accordance with the involvement principle set out in the Well-being of Future Generation Act’ (Our bold)
3. It is against these criteria that the Society believes the level of BCBC’s consultation and commitment should be measured.
EXAMPLES OF BCBC’s LACK OF MEANINGFUL CONSULTATION
Revised Local Development Plan (RLDP)
BCBC is arguing that Porthcawl’s residents were given the opportunity to comment on the regeneration plan when consultation took place regarding the RLDP and BCBC provided a good deal of information about the methods used to keep residents informed about the RLDP and to give them the opportunity to comment. It is accepted that BCBC followed the correct procedures as required under planning legislation. However, although BCBC considered the consultation to have been ‘highly effective’, out of a population of 145,000 (2021 census) just 1,221 representations were received – less than 1% of the population. This suggests that there was either widespread apathy or that, despite BCBC’s efforts, the vast majority of residents were not aware that they had the opportunity to comment.
The Committee wrote to BCBC on 22 September 2022, to suggest that very few residents will have heard of the RLDP, let alone taken part in any consultation. We asked:
- How many of Porthcawl’s residents responded to the consultation?
- How many supported BCBC’s proposals for Salt Lake and Sandy Bay?
- Does BCBC believe that the limited consultation that took place, fully meets the requirements of the Well-Being of Future Generations Act?
‘The information which you have requested is exempt under Section 21 of the Freedom of Information Act which states
Information accessible to applicant by other means
- Information which is reasonably accessible to the applicant otherwise than under section 1 is exempt information
- For the purpose of sub section 1
- Information may be reasonably accessible to the applicant even though it is accessible only on payment, and
- Information is to be taken to be reasonably accessible to the applicant if it is information which the public authority or any other person is obliged by or under any enactment to communicate (otherwise by making the information available for inspection) to members of the public on request, whether free or on payment.
- For the purpose of sub section (1), information which is held by a public authority and does not fall within sub section (2) (b) is not to be regarded to as reasonably accessible to the applicant merely because the information is available from the public authority itself on request, unless the information is made available in accordance with the authority’s publication scheme and any payment required is specified in, or determined in accordance with the scheme.
The information requested is already in the public domain on the BCBC website via the following links.’
2 links were provided but the Committee was unable to find the information it had requested.
As a result, the Committee emailed Cllr Neelo Farr on 24 February to ask whether she could sort this out. Cllr Farr responded on 27 February by forwarding the following statement by a BCBC officer.
‘Dear Cllr Farr,
There has been extensive consultation on the LDP at various stages of its preparation.
It will be very difficult to pinpoint exactly how many representations specifically are from Porthcawl residents or whether they support the regeneration proposals. (Our bold)
The deposit draft consultation yielded over 1200 responses from the plan area.
All relevant information is available on line as part of the examination document library where the council has responded to the comments that have been made.’
A link was provided and the Society was able to find some of the information it had requested.
Having found some information on the link, it was clear from the comments made by Porthcawl and Pyle residents that they were responding to a questionnaire form and, as a result, each respondent had provided a number of comments. So, although BCBC lists about 210 comments in total, the number of respondents would have been considerably less than that number – only BCBC can provide this information. It was not easy to analyse the responses but, as far as one could tell, it seems that about 12 were broadly supportive of BCBC’s proposals while about 80 expressed opposition or concern regarding the number of dwellings to be built on Salt Lake and Sandy Bay and/or the loss of car parking facilities.
The Society’s concern is that, while BCBC has claimed that ‘There has been extensive consultation on the LDP at various stages of its preparation’. it is still unable to say whether Porthcawl residents ‘support the regeneration proposals.’
The Food Store
No consultation took place as required under the Well-being Act. Indeed, BCBC has agreed that:
‘Consultation on this project was principally managed via the planning process -----’
This is tantamount to admitting that the terms of the Well-being Act were not followed.
Cosy Corner
In an article about Cosy Corner that appeared in the April 2021 issue of Seaside News, Cllr Hywell Williams stated:
‘You can expect to see an opportunity for people to comment upon the plan very soon’
This was repeated in June 2021 by Cllr Charles Smith in a paper produced on the BCBC website when he said:
‘We will be organising a public engagement later in the year for people to comment on the plans before they are finalised.’
However, in a Report by the Corporate Director Communities dated 19 October 2021, it was stated:
Collaboration: Further action on Cosy Corner as outlined above will take place in collaboration with partners though the Harbour Operations Group and the Harbour board
Involvement: Proposals relating to the future of Cosy Corner will be developed and delivered in close partnership with key stakeholders. Discussions and development with key BCBC officers will be undertaken.
No mention was made of the previous proposals for the involvement of residents and, again, the terms of the Well-being Act were ignored.
Griffin Park
While it is accepted that the proposal to appropriate part of Griffin Park was advertised as require by planning legislation, the question remains – did this engagement go ‘beyond the statutory minimum set out in planning legislation and in accordance with the involvement principal set out in the Well-being of Future Generations Act’?
We asked whether BCBC could provide examples of how the consultation went ‘beyond the statutory minimum’. No reply has been received.
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Action taken by the Committee.
5 December 2022: A letter was sent to the Office of the Future Generations Commissioner pointing out BCBC’s continuing failure to abide by the requirements of the Well-being of Future Generations Act.
15 December 2022: A reply was received saying the that they were unable to take on casework functions. The Commissioner suggested we contact the Auditor General.
20 January 2023: A further letter was sent to the Commissioner saying that, while we recognised that the Commissioner could not look at every individual case where councils failed to honour the terms of the Well-being Act, could the Commissioner take up the matter with BCBC due to its constant failure to abide by the terms of the Act.
14 February 2923: In the reply, the Commissioner that said ‘we have a lot of sympatry for the concerns you and the community have raised and understand that this response is disappointed, but for the reasons we have outlined above and in previous letters, we cannot get involved on this occasion.’
30 November 2022: Formal complaint put to BCBC regarding its failure to honour the terms of the Well-being of Future Generations Act.
23 December 2022: A 7 page reply was received though nothing new was included
25 January 2023. Having made a formal complaint to BCBC, the Committee was now able to make a complaint to the Public Services Ombudsman for Wales
7 February 2023: A reply was received saying the Ombudsman could not become involved as no individual had suffered as a result of BCBC’s actions.
Latest Action
!) We are in touch with Jamie Strong and Gemma Lewis, A voice for the Future – Porthcawl, and Margaret Minhinnick, Sustainable Wales, who share the same concerns as ourselves regarding BCBC’s regeneration plan.
2) A Welsh Assembly Government inspector is currently examining BCBC’s Local Development Plan and the Committee has written to explain our concerns..
What next?
The possibility of writing to the Auditor General will be discussed at the Committee’s next meeting.
Comments
Would be welcomed.
4 Letter to Auditor General
7 April 2023
Dear Auditor General,
The Porthcawl Civic Trust Society (the Society) is writing to you at the suggestion of the Future Generations Commissioner for Wales
As you may be aware, Bridgend County Borough Council (BCBC) has presented plans for the regeneration of Porthcawl, some elements of which have been met with strong opposition from residents. It is widely felt that insufficient consultation has taken place especially bearing in mind the requirements of the Well-being of Future Generations Act 2015 and of Planning Policy Wales.
- Since September 2020, BCBC has repeatedly stated:
Collaboration: the Council will collaborate with residents, visitors and end users of this project to ensure successful and sustainable development and outcomes
Involvement: ongoing engagement with the community will be an important facet of this project
2. In a letter to the Society dated 21 December 2021, the Office of the Future Generations Commissioner explained that Planning Policy Wales had set out the following policy:
‘It is crucial when, in developing plans, planning authorities engage with people in their own communities, facilitating a collective, participatory process which focuses on achieving sustainable places. This requires engagement which goes beyond the statutory minimum for consultation set out in planning legislation and in accordance with the involvement principle set out in the Well-being of Future Generation Act’ (Our bold)
3. It is against these criteria that the Society believes the level of BCBC’s consultation and commitment should be measured.
The Society’s concerns fall into 2 main categories.
THE OVERALL PLAN
BCBC has stated that residents have had 2 opportunities to make their views known regarding its overall plan for the town, namely:
- Replacement Local Development Plan (RLDP)
BCBC is arguing that Porthcawl’s residents were given the opportunity to comment on the regeneration plan when consultation took place regarding the RLDP. BCBC has provided a good deal of information about the methods used to keep residents informed and, as far as the Society can tell, BCBC seems to have followed the correct procedures as required under normal planning legislation. Nevertheless, although BCBC regarded the exercise as being ‘very successful’, only 1221 responses were received (0.9% of the population of the borough).
The Society wrote to BCBC on 22 September 2022, to suggest that very few residents will have heard of the RLDP, let alone taken part in any consultation. We asked:
- How many of Porthcawl’s residents responded to the consultation?
- How many supported BCBC’s proposals for Salt Lake and Sandy Bay? (2 main elements of the regeneration plan)
- Does BCBC believe that the form of consultation that took place, fully meets the requirements of the Well-Being of Future Generations Act?
Following our third attempt to obtain answers to the above questions, by making use of the Freedom of Information Act, BCBC replied on 14 February, as follows:
‘The information which you have requested is exempt under Section 21 of the Freedom of Information Act’:
BCBC went on to say:
‘The information requested is already in the public domain on the BCBC website via the following links.’
2 links were provided but the Society was unable to find the information it had requested.
As a result, the Society emailed Cllr Neelo Farr on 24 February, to ask whether she could help the Society gain access to the information requested. On 27 February, Cllr Farr forwarded the following response from a BCBC officer:
‘Dear Cllr Farr,
There has been extensive consultation on the LDP at various stages of its preparation.
It will be very difficult to pinpoint exactly how many representations specifically are from Porthcawl residents or whether they support the regeneration proposals. (Our bold)
The deposit draft consultation yielded over 1200 responses from the plan area.
All relevant information is available on line as part of the examination document library where the council has responded to the comments that have been made.’
So, despite the ‘extensive consultation’ that took place regarding the RLDP, when Porthcawl’s residents had the opportunity to comment (and have their views taken into account?) and BCBC’s statement that ‘The information requested is already in the public domain on the BCBC website’ BCBC is still unable to say how many Porthcawl residents responded to the consultation or whether they ‘support the regeneration proposals.’
In the Society’s view, this clearly demonstrates BCBC’s failure to seek, make note of or act upon, the views of residents or abide by the requirements of the Well-being of Future Generation Act or of Planning Policy Wales. This is, of course, also contrary to Principle 4 of The Gunning Principles which states:
‘conscientious consideration’ must be given to the consultation responses before a decision is made
Decision-makers should be able to provide evidence that they took consultation responses into account.
(Local government Association)
2. The Placemaking exercise
This exercise was carried out by Austin-Smith:Lord (ASL) in the latter half of 2021 and had ASL been given a blank piece of paper, so enabling the views of those organisations taking part to be fully reported and acted upon, this would have been a useful and important exercise. However, as can be seen from item 2.2 of the report, this was not the case.
‘Item 2.2 PLANNING CONSENT
The Placemaking strategy has been developed within the existing Planning Policy context of the existing Local Development Plan and associated Supplementary Planning Guidance and also informed by separate consultation on the Replacement Local Development Plan.
With specific regard to the existing planning policy context the site is currently allocated for mixed development within the existing Local Development Plan. Policy PLA3 of the Adopted Local Plan sets out the council’s objectives for mixed use regeneration of brownfield, underutilised sites and identifies the Porthcawl Regeneration Area as being a significant part of this strategy through its allocation as site PLA3(8). This allocation is supported by adopted Supplementary Planning Guidance (SPG) often referred to as the Seven Bays Project – Porthcawl Waterfront SPG’
As can be seen, the result of the exercise was largely predetermined as any recommendations made in the report had to be in line with the masterplan that had already been decided. As such, although there was some change to the plan for Salt Lake, the exercise was largely a waste of time and the ‘consultation’ that took place could not be described as meaningful. This would seem to conflict with Principle 1 of The Gunning Principles which states:
Proposals are still at the formative stage.
A final decision has not yet been made, or predetermined, by the decision makers.
(Local Government Association)
DETAILED ELEMENTS OF THE PLAN
- The Food Store
Indeed, BCBC has agreed that:
‘Consultation on this project was principally managed via the planning process -----’
This is tantamount to agreeing that the necessary ‘engagement which goes beyond the statutory minimum for consultation set out in planning legislation’ did not take place.
- Cosy Corner
On 2 occasions (April 2021 and June 2021) prior to the commencement of the development, BCBC announced that people would have the opportunity to comment on the plan before any final decision was made for the area. Despite these assurances, no such consultation took place.
Indeed, in a Report by the Corporate Director Communities dated 19 October 2021, it was stated:
Collaboration: Further action on Cosy Corner as outlined above will take place in collaboration with partners through the Harbour Operations Group and the Harbour Board
Involvement: Proposals relating to the future of Cosy Corner will be developed and delivered in close partnership with key stakeholders. Discussions and development with key BCBC officers will be undertaken.
No mention was made of the previous proposals for the involvement of residents.
- Griffin Park
We asked whether BCBC could provide examples of how the consultation went ‘beyond the statutory minimum’. No reply has been received.
Conclusion
The main concerns being expressed by residents relate to BCBC’s proposals to build 1150 dwellings on 3 sites along Porthcawl’s waterfront and the resulting loss of well over 1000 car parking spaces. While it is accepted that some housing is required which will inevitably lead to some reduction in car parking spaces, BCBC has declined to enter into any real consultation on these 2 matters. Porthcawl is a seaside town and sufficient car parking facilities are essential if the town is to survive. BCBC has announced that a multi storey car park is planned but, again, there has been no attempt to enter into any consultation regarding that intention.
Although BCBC has not said so, it may have it in mind to consult with residents once the plans are more settled but the Society believes that consultation needs to take place at an early stage so that the views of residents can be taken into account before the plans are progressed.
The Society hopes that you will be able to take issue with BCBC over its repeated failure to honour the conditions of the Well-being of Future Generations Act and the policy set out by Planning Policy Wales. The Society hopes that BCBC will agree to enter into meaningful consultation with residents. Even then, such consultation will only be of value if BCBC is prepared to listen to and act upon the wishes of residents.
Yours sincerely,
Don Tickner
Porthcawl Civic Trust Society
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The Officers of the Porthcawl Civic Trust Society:
Chairman: Anthony Hontoir 01656771775 Vice Chairman: Mike Mansley 01656784755 Secretary: Caroline Vaughan 01656788549 Treasurer and Membership Officer: Marilyn Smith 01656782999 Committee members Tudor Griffiths Diana John Julie Smith Jill Sweet Marilyn Tickner Don Tickner David Vaughan Website and technical support: Steven Flett 07817478577 Email: porthcawlcivictrust@hotmail.co.uk |
