Comment DBCC-8076
Dear Secretary to the Commission,
Please find attached our observations on the Commission’s consultation document in the form of a submission. We would welcome an acknowledgement.
Kind regards
[REDACTED]
SUBMISSION TO THE DEMOCRACY & BOUNDARY COMMISSION CYMRU
Background:
1. By Section 17 Senedd Cymru (Members and Elections) Act 2024 (the 2024 Act), Schedule 2 thereto makes provision for the functions of the Democracy and Boundary Commission Cymru (the Commission) in determining which constituencies are to be paired for a general election in Wales held after 6 April 2026 and before regulations under section 49J of the Democracy and Boundary Commission Cymru etc Act 2013 take effect.
2. We are residents of Tongwynlais within the Cardiff North-Gogledd Caerdydd UK Parliamentary constituency and have been so for over 40 years. We have the following observations to make in response to the Commission’s consultation document on new Senedd constituencies.
3. Paragraph 1 of Schedule 2 of the 2024 Act provides that each new Senedd constituency must consist of the combined areas of two contiguous UK parliamentary constituencies in Wales.
4. Paragraph 4 of Schedule 2 of the 2024 Act provides that:
When considering the possible combinations of UK parliamentary constituencies in Wales, the Commission may take into account—
(a) local government boundaries that exist on the review date;
(b) special geographical considerations, including in particular the size, shape and accessibility of a proposed Senedd constituency;
(c) any local ties (including local ties connected to the use of the Welsh language) that would be broken by the proposed pairings.
5. We look at these factors below but before doing so it is worth drawing out the implication of paragraph 1 of Schedule 2: that the Commission is building on the work and decisions of the Boundary Commission for Wales (BCW) which also restrict the scope of its ability to fix
boundaries.
6. For Cardiff North-Gogledd Caerdydd, the contiguous constituencies which meet the requirement in Paragraph 1 of Schedule 2 above are Caerphilly-Caerfffili, Cardiff East- Dwyrain Caerdydd, Cardiff South & Penarth- De Caerdydd a Phenarth, Cardiff West- Gorllewin Caerdydd, Newport West and Islwyn- Gorllewin Casnewydd ac Islwyn and Pontypridd.
Local authority boundaries that exist on the review date
7. Inevitably where Senedd constituencies cross local authority boundaries Senedd Members must build up expertise on the administration and policies of more than one local authority which
involves more work and greater demands on the Senedd Members’ time.
8. On this ground alone it is therefore highly desirable that crossing of boundaries is minimised and we would rule out pairing with Caerphilly, Newport West & Islwyn and Pontypridd and we accept that the best outcome for Cardiff North is to be achieved by pairing with another Cardiff borough constituency.
9. But, as previously noted above, because the Commission must accept UK Parliamentary boundaries as they are, crossing borders cannot be ruled out altogether as Cardiff borough constituencies fixed by the BCW already do so.
10. In the case of Cardiff South and Penarth which straddles the boundary between the City and County of Cardiff and the Vale of Glamorgan County Borough, this is long-standing. Pairing Cardiff North and Cardiff South & Penarth would involve the Senedd Members having to wrestle with the policies of three local authorities, the City and County of Cardiff, the Vale of Glamorgan County Borough and the County Borough of Rhondda Cynon Taf1. We submit this is highly undesirable and a reason for ruling out such a pairing.
11. More recently, because of recent amendment to the Parliamentary Constituencies Act 1986, which introduced the UK Electoral Quota (UKEQ)2 and the 5% deviation rule, both the UK Parliamentary borough constituencies of Cardiff North and Cardiff West cross the boundary between the City and County of Cardiff and the County Borough of Rhondda Cynon Taf.
12. The boundary is crossed in Cardiff North where the Whitchurch and Tongwynlais ward of the City and County of Cardiff and the Taff’s Well ward of the County Borough of Rhondda Cynon Taf meets, and in Cardiff West where the Creigiau/St Fagan’s ward of the City and County of Cardiff and the Pont-Y-Clun ward of the County Borough of Rhondda Cynon Taf meet.
13. Rhondda Cynon Taf County Borough administration and policies will therefore impact on both Cardiff North and Cardiff West and, as explained in numbered paragraph 7 above, demand wider expertise and involve more work for a Senedd Member. We submit that this can be most efficiently achieved through a team of Senedd Members from a single Senedd constituency. The natural implication is, therefore, that Cardiff North and Cardiff West should be paired. If Cardiff West is paired with Cardiff South & Penarth, it faces the same problem as would Cardiff North in such a pairing, viz, wrestling with the policies of three (3) local authorities. This is a most inefficient way to proceed and a recipe for confusion.
Special geographical considerations, including in particular the size, shape and accessibility of a proposed Senedd constituency:
14. To the north Cardiff is bounded geographically by the range of hills which stretch across Cardiff North - Craig Llysfaen, The Wenallt and Craig yr Allt at Nantgarw – to Cardiff West – the Garth and Soar - thereby uniting Cardiff West and Cardiff North. To the south the boundary formed by the coast unites Cardiff South & Penarth and Cardiff East. It is submitted this is a special geographical consideration which supports pairing Cardiff North with Cardiff West, and Cardiff East with Cardiff South & Penarth.
1 See numbered paragraph 11
2 Defined in paragraph 2 of Schedule 2 to the Parliamentary Constituencies Act 1986 as amended.
15. Cardiff’s Local Development Plan contains a protected area called the Green Wedge. The area is protected to prevent urban sprawl and maintain the separation between Cardiff and surrounding communities. It is primarily located to the north of Cardiff stretching from Creigiau in Cardiff West to Old St Mellons in Cardiff North. This common feature between the two Parliamentary borough constituencies is another special geographical consideration which supports the pairing of Cardiff North and Cardiff West.
16. Whilst we note that for the purposes of determining the boundary of the UK Parliamentary constituencies the River Taff-Afon Taf affords a natural feature separating Cardiff North from Cardiff West, we submit that when assessing the larger picture required by statutory pairing the shared sense of belonging generated among the communities along the river valley from Taff’s Well, Tongwynlais, Whitchurch, Llandaff North and Gabalfa in Cardiff North, and Llandaf and Radyr in Cardiff West, becomes of paramount importance. The two constituencies are linked by a road bridge at Llandaf/Llandaff North wards and a road at Ynys Bridge3 connecting the Tongwynlais/Taff’s Well/Pentyrch communities, the latter including Gwaelod Y Garth. Between the two road bridges, there are also pedestrian/cycle crossings off the Taff Trail at the Iron Bridge, Tongwynlais, (leading to Gelynis Farm and Morganstown), and the Blue Bridge at Radyr (giving access to Radyr railway station). The entirety of the river’s greenfield course within Cardiff is contained in these two constituencies, and the issues of sustainability, ecology, flood protection, pollution and water quality, and use of the waterway create a common interest across the two constituencies and are a most important special geographical and accessibility consideration favouring the representation afforded by a single constituency.
17. The Stagecoach 136 service from Creigiau in Cardiff West to Cardiff City Centre journeys via Pentyrch (Cardiff West) and Whitchurch and Gabalfa (Cardiff North). This is an important public transport link and accessibility consideration supporting the pairing of Cardiff West with Cardiff North in terms of the best representation to be provided by Senedd Members.
18. Whilst Cardiff North and Cardiff South & Penarth touch at a short length of boundary between the Cathays ward in Cardiff South & Penarth and the Gabalfa and Heath wards in Cardiff North, we submit that the resulting size and long egg timer-icon-like shape is one to be avoided and is another reason to rule out pairing these two UK Parliamentary constituencies.
19. For the sake of completeness, we should also say that resulting long and unwieldy shapes and sizes is another reason for ruling out pairing Cardiff North with Caerphilly, Newport West & Islwyn or Pontypridd.
20. Alongside the River Taff, accessibility to and from, and within, Cardiff North and Cardiff West is being significantly improved by the on-going development of the South Wales Metro, including electrification of the Valley lines. A new Metro station is proposed at the Old Coal Yard in Mynachdy (Gabalfa Ward in Cardiff North). The train line connects the two sides of the river at Llandaf and Taff’s Well (Cardiff North) and Radyr (Cardiff West). The Transport for Wales new depot at Taff’s Well (Cardiff North) will become the “beating heart” of the Metro. The development is centred on the Cardiff North/Cardiff West River Taff interface. Again, the UK Cardiff North and Cardiff West Parliamentary constituencies have a powerful common interest. This is another most important accessibility consideration which favours a pairing of Cardiff
North with Cardiff West.
3 There are in fact two road bridges at Ynys Bridge one of which is a grade II listed building in the care of CADW.
21. As to road communications, the main traffic hubs giving access to Cardiff are the M4 Junctions 30 (Cardiff Gate) and 32 (Coryton) – both in Cardiff North - M4 junction 33 (Capel Llaniltern) - in Cardiff West - connected to Culverhouse House Cross by the A4232(N) - in Cardiff West – which intersects with the A48 running through Cardiff.
22. Additionally, via the A48M spur off the M4 which becomes Eastern Avenue (A48), the Gabalfa interchange/flyover in Cardiff North affords access to the Cardiff City Centre; Cardiff North via Northern Avenue/A470 leading to the Coryton interchange and the Valleys; and Cardiff West via Western Avenue (A48) leading to Ely Bridge and thence Culverhouse Cross.
23. Daily, commuters, travelling in and out of the City for work, move in a broadly north-south direction and converge on these hubs, causing congestion, (including commuters from the Valleys and in the north west around the recently attached Pont-y-Clun ward of Rhondda Cynon Taf). The M4 corridor to the north, and the A48 to the south, with the A4232(N) and A470 linking the two, form the basic traffic framework for movement across the width of a proposed Cardiff West-Cardiff North constituency. It is submitted that the two constituencies, Cardiff North and Cardiff West have a significant common interest in the control and regulation of these hubs and routes, and the journeys through and along them, and this is another accessibility reason for pairing the two constituencies.
24. The Taff Trail, which begins in Cardiff Bay, runs through Cardiff West at Sophia Gardens, Pontcanna Fields, and through Cardiff North at Hailey Park, Forest Farm, Whitchurch and Tongwynlais, before continuing North to Brecon. This is an important Active Travel route to work and for healthy living and recreation which links both Cardiff North and Cardiff West. The needs of this part of a most important cycle/pedestrian travel corridor and its users in the context of the Active Travel (Wales) Act 2013 are again best represented by a single team of Senedd Members from one Senedd constituency. This is another accessibility consideration favouring pairing of Cardiff North with Cardiff West.
Any Local Ties (including Local Ties Connected to the Use of the Welsh Language) that would be broken by the Proposed Pairings.
25. Welsh Language Ties: Cardiff is both the most numerous and fastest growing area in Wales for the Welsh language. This trend is, in fact, highly concentrated in Cardiff West and Cardiff North. Fourteen (14) wards in Cardiff have more Welsh speakers than the Cardiff average of 10.1%; of these, eleven (11) are in Cardiff West and Cardiff North, including the eight wards with the
highest percentage of Welsh speakers4. They form a contiguous block stretching West to East, from Creigiau and Pentyrch in the North West, over to Lisvane in the East, including the two
historically linked secondary schools at Glantaf and Plasmawr. It is submitted that pairing Cardiff North and Cardiff West will afford the Senedd’s target of a million Welsh speakers by 2050 a stronger and more effective voice within the Senedd and the nation. It is further submitted that “breaking ties” in this context must mean also undermining and acting in a way which does not promote the Senedd’s Welsh language policy and aspirations.
4 Defined as those able to speak, read and write in Welsh according to the 2021 Census.
26. Other ties: This same contiguous block is characterised by more rural village-based communities, in contrast with the more inherently urban nature of the city centre and much of the eastern and southern parts of the city that extend to the coastline. This is highlighted by the fact that all six of Cardiff’s Community Councils sit within Cardiff North (Lisvane; Old St Mellons; Tongwynlais) and Cardiff West (Radyr & Morganstown, Pentyrch - covering Creigiau, Gwaelod Y Garth and Pentyrch - and St Fagans). Moreover, within Cardiff North, the Taff’s Well ward of Rhondda Cynon Taf County Borough includes the village of Nantgarw and this is coterminous with the Taff’s Well and Nantgarw Community which also has its own Community Council. Uniting these communities under a common set of Senedd representatives would make it more likely that their common interests and characteristics, including governance structures, are effectively represented. Many of these common interests reflect the nature of the Taff River valley as a vital transport link for the region.
27. Additionally, in passing it is worth mentioning that locating the Rhondda Cynon Taff ward of Taff’s Well and the City and County of Cardiff ward of Pentyrch (which contains Gwaelod-y-Garth) in the same Senedd seat would promote and avoid breaking natural ties between these two small communities.
28. Finally, Tongwynlais Primary school in Cardiff North is a feeder school for Radyr Comprehensive School in Cardiff West. For a Senedd Member to provide the best representation both primary and secondary schools ought to be within his/her constituency.
Conclusions
29. The Commission has proposed the pairing of Cardiff North-Gogledd Caerdydd with Cardiff East - Dwyrain Caerdydd. We submit that applying the above-mentioned considerations listed in paragraph 4 of Schedule 2 and our own reasoning, the Commission’s proposal does not reflect the best arrangements for Cardiff North or even other Cardiff borough constituencies.
30. In the light of these considerations and reasoning we request that Cardiff North-Gogledd Caerdydd be paired with Cardiff West-Gorllewin Caerdydd and not Cardiff East-Dwyrain Caerdydd. We submit that apart from the pairing of Cardiff South & Penarth- De Caerdydd a Phenarth, this change has no other knock-on effect.
We consent to being contacted by DBCC with email updates about this electoral boundary review.
[REDACTED]
30th September 2024
Respondent type
Member of public
This comment refers to
The entire area under review.