Now what follows will not make a lot of sense unless...You remember the pictures of the road falling into the sea? Well the brilliant solution of Gwynedd County Council is to drive a new road through the Sarn Garden...stone walls and vegetation untouched since the late 18th century, through the Plas Yn Rhiw National Trust woodlands-semi natural ancient woodlands protected by National Assembly, Joint National Conservation Committee Special Area of Conservation status etc..
Strangely The National Trust do not appear that fussed...what is this all about.??..I know it is not Cliveden..but I thought the preservation of the demotic and quotidian was in fashion........so we have been having a little work!!
Gruffydd Morris
Planning Manager
Dwyfor Area Office
Gwynedd County Council
Ffordd Y Cob
PWLLHELI
Gwynedd
LL53 5AA
October 24 2002
Dear Gruffydd Morris,
Planning Application CO2D/0382/30/R3Q-Proposed road at Rhiw
I gather that the above planning application will be considered by the Dwyfor Area Services Committee at its meeting of November 4th 2002.
You will, I hope, forgive me for writing such a long letter; however I believe the issue is of sufficient importance to merit such. I apologise too that I have not provided a bi-lingual version.
The work that has gone into this application has continued over a long period of time during which I have believed it was better that I should not be involved, nor express a view. The property, Sarn Y Plas, which is leased to me by the National Trust is at the heart of this planning application, together with those properties of Treheli, Bryn Ffowc and Plas Yn Rhiw.
I am sure you also know I am the son of R.S.Thomas and M.E.Eldridge to whom, as well as myself, the Sarn Y Plas property was gifted, on lease, by the Keating sisters in recognition of both friendship and the contribution that my parents were making to Welsh literary and artistic life.
But it does appear that these things may be moving to some kind of conclusion and that I should request that yourself and the officers of the Council and members of the Dwyfor Area Committee consider what follows.
Two previous attempts have been made, over the last 30 years, to stabilise the road from Llandegwning to Y Rhiw against the effects of coastal erosion. It, sadly, appears that the second of these attempts has also been unsuccessful. Whether more might have been done, historically, particularly had funds been available, is a conjecture; as is whether, had modern technologies been available, different engineering solutions might have been successful. Whatever the case a great deal of money has been spent in vain.
However you will know that the continuing erosion of the road has been drawn to the Council's attention over the years, particularly by Rhiw Community Council.
I am very sensible of the fact that the Highway Authority and Dwyfor Area Committees find themselves in a difficult position. On the one hand some local residents believe that a new road is essential and some also appear dismissive of any objections or alternatives; elected councillors will be sensitive to that opinion; on the other hand you have to consider the wider picture of the irreparable damage that will be done to a significant area of land and the considerable weight of local and national opinion that opposes a proposed new road.
I think that strong arguments against the proposal to construct a new road behind Treheli Farm, through the Sarn Y Plas garden and the Plas Yn Rhiw woodlands can be made on at least four major grounds.
These are Planning Policy and Practice, Transportation and Routes, Environmental and Technical, and Heritage
1. Planning Policy and Practice
The planning application appears to be in contradiction and breach of the planning policies and priorities of The National Assembly, Gwynedd County Council and Dwyfor itself with regard to the environment, transportation and heritage. Indeed it is on the basis of contradictions in respect of National Assembly policy in particular that a request has been made for the application to be 'called in'. The application appears in contradiction to the National Assembly policy with regard to 'ancient natural or semi-natural woodlands' and in contradiction of the the County Council's Environmental Strategy with regard to both The Natural Environment and Transportation
a. The application proposes that a road be constructed through an area of ecological, conservation and heritage significance. The application gives little or no regard for the national governmental and European recognition of the designated special status of the area of land the implemented proposal will destroy. Indeed the applicant maintains that 'the area has little or no environmental value!'
b. In preparing the proposal the applicant has carried out an Environmental Impact Assessment (EIA), commissioned from Axis. This is an inadequate low level assessment which fails to meet the requirements for assessing projects of this scale and impact. The EIA itself is so fundamentally flawed by contradictions as to open the application to serious challenges.
c. The applicant has carried out a geo-technical survey which fails to come to satisfactorily measurable and certain conclusions on two particular and fundamental matters:
Firstly it is vague as to whether there is even sufficient bedrock on which to build a new road, the absence of which would render the whole project pointless
Secondly it fails to address one of the major causes of erosion, other than tidal erosion, which is water run off through the particular geological structure of the area
As a consequence of the above and of what is detailed under section 3 below a considerable number of organisations with National and Local remits have seen fit to raise objections to this proposal.
2. Transportation and Routes
The application appears to breach Gwynedd CC's Environmental Strategy in terms of Transportation. This strategy seeks to reduce dependency on private vehicles and to attempt to reduce the amount of fuel consumed.. It also aims to reduce the need for travelling while recognising the needs of rural communities.
a. Whether or not the existing course of the road can be repaired appears to me still uncertain. While there may be objection to repair on the ground of cost, longevity and appearance I gather that none of these factors have been taken into consideration for the proposed new road. No estimate of final cost, nor cost benefit analysis has been provided.
b. While the longevity of a repaired existing road has been put at circa.40 years, no longevity of the proposed road appears agreed-indeed the rate of coastal erosion between Llandegwning and Tyn Y Parc is such that any new stretch of road at Plas Yn Rhiw might be rendered inaccessible within 40 years by that erosion.
c. The application for the proposed route seems additionally invidious given the number of alternative routes available. While most of them would require some upgrading there are presently some 6 alternative routes between Bryn Ffowc, Plas Yn Rhiw, Talafon and Rhiw to Sarn Meylltern, Botwnnog, Nefyn, Pwllheli, Abersoch and beyond. These roads to the SE and NW of Mynydd Rhiw and via Bryncroes have been used by the community, while the road in question is closed, with an added journey time that has been estimated at 5 minutes-not the 20 minutes that has been suggested. If the UK traffic policy is to slow traffic down in towns, it surely cannot be to speed it up in rural areas.
d. I find it quite unusual that, with the availability of modern technology, no proper CAD and 3D Computer generated visuals of the proposed road have been provided to you by the applicant. While there are suggestions that, among the grounds for not repairing the old road, there are matters of unsightliness, I see nothing that would lead one to suppose the proposed new road was sightly in a manner appropriate to its location.
e. I am very surprised that some very simple analyses of the traffic flows and actual usage of the road that is now closed do not appear available. On the basis of living in Sarn Y Plas I would estimate that traffic in most months was of the order of 20-30 vehicles a day. In the tourist months of July and August, obviously, a little higher.
The issue of access to employment, goods and services and leisure is, of course, critical to local communities. However, in this instance, whatever the wider arguments for improving accessibility for rural communities are, I cannot really believe that Dwyfor nor The National Assembly, let alone Gwynedd CC, believes that it is worth expending the sums involved, the destruction of rare habitats, rejecting Planning Policy and the destruction of a major piece of Welsh heritage and tourist attraction for the convenience of this number of persons and with the existence of alternative routes.
3. Environmental and Technical
(I)Environmental
a. An application has been made to drive a new road through a National Trust property. While this is in itself unusual, the proposed road would also be built in on land which is part of the Llyn Area of Outstanding Natural Beauty, the Joint National Conservation Committee Llyn Coastal Special Area of Conservation (UK 0030271), the Heritage Coast and and Environmentally Sensitive Area. All of these are designated and recognised areas at a National and European level.
It would impact severely on the flora and fauna of these areas area. The JNCC itemises many of these, through its programmes such as The British Biodiversity Scheme .
However the applicant, surprisingly, asserts in the environmental statement that " the scheme would not significantly impact on any nationally or internationally designated sites of conservation interest" which I hold to be simply not true.
b. The Gwynedd CC Environmental Strategy has as its mission for 'The Natural Environment' section of its Environmental Strategy that "The natural environment, landscape and biodiversity of the county will be protected and enhanced."
and states one of its aims 'to protect and enhance the landscape and valuable. I fail to see how destroying one of the major habitats of barn and tawny owls, woodcock, voles and mice, adders and rare lizards, let alone butterflies, dragonflies, equisetum, orchis, heartstounge ferns, lichens and mosses and wood anemones, the presence of many of which attracts tourists to Plas Yn Rhiw, contributes to any policy of protecting and enhancing our local environmental heritage.
c. A proposed road would also destroy an area of ancient natural or semi-natural woodland, the protection of which forms part of National Assembly policy as well Local Dwyfor Planning Guidelines Policy E17 (8.3.42). Indeed it is probably one of only two or three such remaining woodlands west of Pwllheli.
d. The Environmental Impact Assessment carried out by the applicant appears capable of being challenged in many areas; not least that it was only a Phase 1 assessment when a Phase 11 would have lent more weight. or at least further surveys of lichens, bryophytes, wild flower species, dormice and National Vegetation Classification types might have been commissioned, because of the scale of this scheme and the importance of the nature conservation interest i.e. ancient woodland
Specifically the applicant's EIA statement includes these additional inconsistencies
. ".....trees and other vegetation which is of limited botanical importance" Why then has it been designated ancient woodland and all planning references state that it should be protected if it's not important?
"the woodland .....contains no really ancient trees " then goes on to contradict itself by saying there are some "significant veteran trees providing specialised niche habitats."
The specialist, commissioned by The National Trust from ACS Consulting asked to survey the trees noted:
" there are numerous trees of significant girth and height not included in the topographical plan...most appear to be within the proposed road line. There are trees just outside the roadline that would have benefited from being accurately plotted to assess their relationship with the road"
Indeed I understand a more accurate assessment is now available of the significant number of species, sizes ,ages % mass in the woodland etc. which shows there are more trees affected than stated in the environmental impact assessment/survey. I trust this is available to the committee.
An additional hazard not considered is that of fallen trees. The root systems of the trees in the Woodland are extremely unstable due to the high water content in the soil. The creation of a new road will open the Council and thus the area committee to the charge, that in the event of accidents or worse deaths as a result of fallen trees, they approved this proposed road knowing the danger but failed to take it into account
It is also proposed that ..."the ancient field layer....of ecological antiquity....should be relocated into recently planted woodland elsewhere on the upslopes of Plas yn Rhiw".
This methodology has failed in various sites around Britain, and CCW (Countryside Council for Wales have published research to this effect
(ii)Technical
a. I gather there are considerable uncertainties about the actual geology of the land on which it is proposed to build a road. While some conjectured bedrock has been located it is my understanding that neither the consultants nor the applicant actually know what they will find until they start work. This is hardly a confident basis on which to start an engineering project
If you will permit an observation from someone who has lived at Sarn Y Plas for a large part of the last 20 years: The geological character of the land boulder clay and dolerite outcrop. The whole area from Treheli to Bryn Ffowc is characterised by being waterlogged for some seven months of the year. You can see the boulders forming the basis of the Sarn Y Plas house and elsewhere on the hillside. One effect of this is for the whole soil and subsoil of the area to move inexorably seawards.To anyone living in Sarn the main feature of seven months of the year is water draining off and through the hillside; and in the case of Sarn through the house!
b. Astonishingly there are no detailed proposals for dealing with this water run off which must have been one of the main causes of the collapse of the old road I am seeing no proposals for how the issue of draining the route of the proposed road is to be handled. If the road water simply drains off into the lower Sarn field it will simply hasten the slippage of the remaining field and house into the sea. When both of the two last road repairs were done, I was present. There was considerable debate and far greater concern about this; and the course of the stream from the 'Sarn Well' was diverted from in front of the house to try and assist run off. However if you stood, after a period of rain, at the bottom of stone embankments water could be seen pouring through the stones in the wire cages.
I have watched a stepped sloping field change to a single incline within 20 years. I believe that any proposed road will be built on an inherently unstable base. The council would therefore find itself facing mounting repair and maintenance costs as the years progress.
4. Heritage
This is not easy for me to say ButI
I had rather thought, at the outset of all this, that Dwyfor would fight tooth and nail to protect and preserve the heritage of Llyn residents that is the Plas Yn Rhiw woodland, the Sarn Y Plas field, the unusual and important habitats of both as well as the ambience of the former home of one of Wales's most famous writers
Nontheless, it is beginning to appear to me that;
--in spite of all considerations- ecological-environmental and heritage and
in spite of the inadequacies, uncertainties and incompleteness of the geo-technical and environmental surveys--
the Dwyfor Area Committees might actually be willing to consider sacrificing this unique location, with which it has been entrusted, for the sake of a perceived responsibility to a vocal minority in the local community, at the expense of the medium and long term considerations for economic and tourism growth for future community members; and this for the provision of a road that will accommodate traffic of possibly 20 vehicles a day!
I do appreciate that The Area Committees will be giving the fullest attention to the matter and that decisions will not be taken lightly. But I do wonder that, so far, there does not seem to have been any objection either in principle or on the basis of the fundamental threat to the heritage and environment from you yourself
Clearly it is invidious to try and speak for others. I only express below what I suppose I might have wished to hear members of the Dwyfor Area Committee say. Perhaps it has been said? What I would have expected the Dwyfor councillors' line, in order to protect its heritage, residents interests' and constituency would be that you
Have
a responsibility to all who live and work in the area and to those who visit to enjoy the outstanding natural beauty of this area:
Are
a provider and encourager of employment and
a guarantor of the visits of many kinds of tourists to the area who spend their money with local businesses.
Have a responsibility through due processes and consultation to propose policies and plans for the area which in both the short and for the future will protect our communities and heritage, albeit at the cost of some local inconvenience.
Are
not alone in being concerned at the coastal erosion that is occurring in Llyn, one consequence of which has been the unfortunate collapse of the road between Llandegwning and Y Rhiw. That you appreciate the need of the population of Rhiw to have easy and speedy access to Pwllheli and the rest of Gwynedd. You believe that, even if the possibility of re-instating the old road, albeit in the shorter term, proves impossible, nonetheless you should seek imaginative and cost-effective alternative proposals; including the upgrading of existing alternative routes, that even at the present standard of road provision, add, at the most, 5 minutes to journey times from Rhiw
and that
Consequently you should oppose the creation of a new road that will destroy both ancient, contemporary and future woodland, wildlife and heritage habitats .
It may not be what the you as a member of Dwyfor Area committee thinks; but it is what I would hope you thought!
So I urge you, on the basis of these cogent objections to decline this application.
Finally it must be said that one cannot see the Irish Government consenting to the building of a road through the garden of W.B.Yeats's Tower at Gort, nor Dyfed Council agreeing to a Marina at Dylan Thomas's Laugharne home. Nor can I see Warwickshire CC agreeing to a road in the garden of Anne Hathaway's cottage.
There are not a significant number of houses and gardens in Dwyfor which have a central place in world literature. If you consider the enormous international awareness of the significance of Sarn Y Plas as a central locus in the work of R.S.Thomas and M.E.Eldridge (Blwddyn Yn Llyn is mainly about Sarn, all his work from 1978 on was written there; M.E.Eldridge's book In My Garden illustrates the very garden that is at risk)I cannot believe you would wish to be remembered as an officer of the council or member of the committee that voted to destroy one of Wales's literary landmarks!
Maybe at the end I should let RS speak for himself:
Sarn Rhiw
So we know
she must have said something
to him - What language,
life? Ah, what language?
Thousands of years later
I inhabit a house
whose stone is the language
of its builders. Here
by the sea they said little.
But their message to the future
was: Build well. In the fire
of an evening I catch faces
staring at me. In April,
when light quickens and clouds
thin, boneless presences
flit through my room.
Will they inherit me
one day? What certainties
have I to hand on
like the punctuality
with which, at the moon's
rising, the bay breaks
into a smile, as though meaning
were not the difficulty at all?
No doubt one certainty he would have hoped to hand on was that Sarn Y Plas Pen Llyn was safe in your hands
I hope you will contact me if you wish to deal further with any matter of this letter. I hope it helps, as intended, in the your coming to a wise decision
With all good wishes
Gwydion Thomas
NOTE
This letter has been sent by email to those persons whose address I have, with a hard copy following. To others a hard copy has been sent. Please accept my apologies if your hard copy did not arrive before November 4.
cc. Members of Dwyfor Area Services Committee: Councillors M.Sol Owen, michael_sol_owen@hot,ail.com M.J. Clishem, D.B.Evans, Tomos Evans, tomosevans78@hotmail.com W.A.Evans, Simon Glyn, enlli@aol.com E.H. Griffith, evieg@griffith.fpnet.co.uk Margaret Griffith, mgiad_griff@hotmail.com J. Griffiths, jgriffiths@clara.co.uk R.G.Hughes, R.P. Hughes, richard@y-we.co H. Jones, W. Penri Jones, M.Lewis, maldwynlewis@cymru1.net I. Roberts, W. Gareth Roberts, R.G.Trenholme, D.W.Thomas, A. Williams, O. Williams, R.H. Wyn Williams. Wynabersoch@cwcom.net
Copies to Geraint Jones, CEO Gwynedd CC, A.E. Roberts, R. Daimond , Henry Roberts, Gruffydd Morrys, Elfyn Williams Gwynedd CC
This substance of this letter has is also being sent in the first instance, in some cases with a slightly different wording, to:
Fiona Reynolds CBE, Director General of The National Trust
John Broomhead, John Morgan and John Neale of the National Trust for Wales
The Members of The National Trust Committee for Wales: Richard Cuthbertson, Dan Clayton-Jones, Dr. Naylor Firth, Gerwyn Griffith, Roger Jarman, Dame Judy Ling Wong, Mark Mainwaring, Ann Markwick, Nigel Perle CBE , Dr. Jeremy Rye, Robert Thomas, Valerie Thompson, Gareth Wardell, Professor Gareth Wyn Jones and George Yeomans.
The National Assembly: John Saunders
Countryside Council for Wales: Roger Thomas, John Lloyd Jones and Peter Stutthard,
Arts Council for Wales: Joanna Weston, Sybil Crouch
The Guardian : Paul Brown
Council for the Protection of Rural Wales: Merfyn Williams, Morlais Owens
Wildlife Trust for Wales, Geoff Pedley
Woodlands Trust Graham Bradley,
RSPB Mike Webb
