USW Consultation on Proposed Housing Development
The 2008 ambient EU air quality directive (2008/50/EC) sets legally binding limits for concentrations in outdoor air of major air pollutants that impact public health such as particulate matter (PM10 and PM2.5) and nitrogen dioxide (NO2).
The current EU legal limit is 40 micrograms of Nitrogen Dioxide per cubic metre.
We attach 2016 recorded levels of Nitrogen Dioxide levels for the Caerleon High Street / central one-way system. There is presently an Air Quality Management Area (AQMA) in operation on the High Street.
- The main High Street recorded an average reading of 42.1 although it did reach a raw high 65.1 in November 2016.
- 15 High Street recorded an average reading of 54.1 although it did reach a raw high of 76.9 in June and 82.2 in December 2016. This is more than double the amount outlined in EU legislative law.
- 18 High Street recorded an average reading of 49.3 although it did reach a raw high of 75.2 in both November & December 2016.
- 9 High Street recorded an average reading of 44.4 although it did reach a raw high of 75.2 in December 2016.
- 9 Castle Street recorded an average of 37.0 although it did reach a raw high of 59.2 in December 2016. It also exceeded a raw high above 40 on ten of the twelve months.
- 6, 1 & 7 Castle Street also all displayed average readings under 40, however they did all present raw readings above 40 in various months through the year with 1 Castle Street displaying 51.3 in January 2016. They are precariously near and over EU regulatory levels.
- Although Goldcroft Common saw lower levels of air pollution (because of it’s open space) it did in fact still exceed a raw reading of 41.3 in December 2016.
THE CAMPUS DEVELOPMENT / TRAFFIC LEVELS
We are led to believe the USW housing proposal consists of 263 homes and 42 flats. This could potentially place another 500 vehicles on to Caerleon’s roads, given one household will operate at least one to two vehicles. Even a conservative estimate would place the number at 300 vehicles, which is still a high number. This will directly increase traffic levels and will increase NO2 levels on the one-way system. Caerleon is in a unique position whereby the one-way system (leading to Caerleon Rd) is only major route South leading in-and-out of the town. The only other route South is the Pillmawr Rd Lane, which is totally inadequate as a major route.
The nitrogen dioxide levels on the High Street in Caerleon are dangerously high. This is outlined and backed-up by solid recorded evidence. This will only increase should a new large housing development occur at the USW Campus site.
The USW claim that since the closure of the University Campus, traffic has decreased in Caerleon due to less vehicles going to and from the Campus. However, they have not accounted for increased traffic levels due to new housing developments at Trinity View and the Green Meadows estate. Traffic has also increased at St.Cadocs Hospital. Either way, this irrelevant anyway as the NO2 levels presently exceed EU regulatory levels on the main one-way system – and have done since 2012.
NO2 levels have not dropped since the closure of the Campus.
NATIONAL BACK-DROP / CAERLEON HEALTH CONCERNS
In February 2017 Britain was sent a final warning to comply with EU air pollution limits for nitrogen dioxide (NO2) or face a case at the European Court of Justice. An estimated 50,000 Britons die prematurely each year from respiratory, cardiovascular and other illnesses associated with pollutants such as NO2 particulate mater (PM) and ozone. Admittedly, the 50,000 number is an estimate, however a report in November 2016 from the European Environment Agency said the UK had 11,940 premature deaths in 2013 from Nitrogen dioxide (NO2). In October 2017 this figure was revised to 52,240 deaths for 2014. This was the second worse statistic in Europe after Italy. The situation is believed to have worsened in the 4 years since 2013.
Given the national backdrop above, it should now be highlighted that Charles Williams Primary School is located directly on the High Street / one-way system. Caerleon Comprehensive is located within 300 yards of the one-way system. It is estimated that during the daily school-run anywhere up to 500 children may walk through Air Quality Management Zone and are at direct danger from the heightened levels of Nitrogen Dioxode (NO2). Caerleon has a sizeable elderly population who are also at a greater risk of ill health from high Nitrogen Dioxide (NO2) levels.
Local Authorities (Councils) have a legal obligation to adhere to EU legislation. It is our view that it is impossible for Newport City Council to grant approval for the application in it’s current format. This would directly contravene EU legislation. We believe that even if this application were sent to the Welsh Government on appeal, it is highly likely to be rejected also.
In conclusion, the Caerleon & Christchurch Conservative Party Group does not support the proposed application and will strongly oppose it in it’s current format. We are working closely with the Caerleon Civic Society. We will also work with representatives from the Caerleon Labour Group on this matter.
Finally, we believe the USW should have fully researched – in advance – before pressing ahead with the closure of the Campus in respect of the sale of the site. It was highly likely the sale would be made to housing developer. We do not feel the USW properly understood the ramifications of how Caerleon’s complex infrastructure problems would have on any future sale and redevelopment. The situation is a mess.
We are calling for this matter to be sent to the Welsh Assembly Government in respect of detailed scrutiny.
Councillor Joan Watkins.
and Caerleon Resident
2017 Air Pollutions were not presently available when requested as a year-end average has not been calculated. We have not yet seen out 2017. It is highly unlikely they have fallen since the last full-year readings from 2016. The previous 4 years of readings have also shown EU regulatory levels have been exceeded also.