Cause for Concern / Red Flags - Heol y Glyn Development, Glynneath

The complaint of Misconduct in Public Office against the NPTCBC Leader, Stephen Karl Hunt, and of potential Corporate Manslaughter against Neath Port Talbot County Borough Council, is made by myself (David Richards) in my role as a Company Director at Rugby Relics Ltd in support of the employees and the residents in the surrounding area who have given me their permission to represent them in relation to the planning process at the Heol y Glyn housing development. This group is known as the East Glynneath Residents Against Contamination. I am also the Chairman of the political organisation Glynneath Residents Against Contamination which has similar objectives.

I use the criminal offences Misconduct in Public Office and Corporate Manslaughter as an observational guide to why I have made the complaints. I would suggest that it the role of South Wales Police is to define the offences based upon their status as the regulatory authority for crime within the county borough of Neath Port Talbot. An agreement reached with DS Peach of the South Wales Police on 19/1/23 has identified the following process to help DS Peach present our case to his line manager, a Detective Inspector.

1. We will provide evidence of cause for concern.

2. We can provide evidence of [our group] following the correct government protocols if necessary.

3. We will provide evidence of companies and public officials refusal to follow the correct government protocols and legislation.

BACKGROUND

LANDFILL SITE - The Heol y Glyn site has been for the majority of the last 85 years, a landfill site, (since around 1937) it was initially a council ash tip. (source: Glynneath resident, Moira Harris, granddaughter of original site manager, video evidence available)

CUDDY GROUP OWNERSHIP - The Cuddy Group Ltd were a demolition and asbestos removal company who tipped on the Heol y Glyn landfill site for approximately 14-20 years, 1997-2017. The purpose for the tipping on planning applications was given as 'to raise ground levels' for a housing development. There is no evidence the Cuddy Group intended to build houses. (source: NPTCBC planning documents, satellite and resident images, resident testimonies, eyewitness reports.)

ENZO HOMES OWNERSHIP - In 2017 the Cuddy Group Ltd went bankrupt and the land was eventually purchased by Enzo Homes Ltd who submitted plans to the NPTCBC. Following the approval of these plans. In October/November 2020 Enzo Homes broke several conditions in relation to the planning approval that included moving land around and off the site to an unlicensed (for contamination) facility in Powys. An enforcement notice was made against Enzo Homes. A contamination test provided to Enzo Homes by Terra Firma Ltd shows that the land Enzo Homes was moving around and off the site is contaminated. This breaches two UK environment laws. The 1974 Control of Pollution Act and the 1990 Environmental Protection Act. (video and documentary evidence available)

SHORT BROTHERS OWNERSHIP - In 2021 Enzo Homes sold the land to Short Bros Ltd.

type	further information / evidence	notes
Historical actions generic / character witness Personal character of Michael Cuddy	several resident interviews available on video or in person.	The Cuddy Group Ltd were a company owned by the Cuddy family of Glynneath. The Managing Director, Mike Cuddy is known personally to many of our group. He has a history of shady dealings, both personal and business within the community and no-one, without exception trusts this man. There is a historic precedent with his personal character that the Cuddy Group Ltd under his directorship would fail to follow the rules and regulations with respect to the Heol y Glyn site, that they would cut corners and dump asbestos or contaminated waste without consideration as to the consequences or care for the community. Cause for concern: We were concerned that the Cuddy group would willingly have broken the rules and regulations to make money.
Historical actions generic / conflicting purpose of actions No evidence of building houses		There is no evidence of the Cuddy Group housing development company, Primrose Homes ever building a house. There is no evidence of any intent of the Cuddy Group Ltd to build houses at the Heol y Glyn site. No groundwork was completed including the main access road onto the site. (source - historic satellite images, resident photos, resident testimonies and NPTCBC planning information.). No building materials were imported onto the site. Following the sale to Enzo Homes, the developer started to take the spoil off the site to make it suitable for development and the development manager stated in his presentation that there was too much spoil on the site and it would need to be taken off. The Glynneath Councillor Del Morgan stated that the amount of spoil on the site was 'crazy'. Cause for concern: We were concerned that the tipping of material at the Heol y Glyn site that was 'intended to raise ground levels' for the building of a housing development was in fact a front for the tipping of waste products from the demolition and asbestos waste removal arm of the Cuddy business.
Historical action specific / conflicting purpose of actions Inappropriate levels of spoil dumped		In 2016 there was clearly a danger of the site slipping as it started to reach Aberfan proportions. We (the residents) followed protocol to prevent any further tipping at the site and an enforcement notice was placed on the Cuddy Group preventing them from tipping further spoil. At this point the site had reached its current level and the latest plans (P2021/0546) suggest that 21,000 cubic metres needs to be taken off site or moved towards residents houses. This confirms that the Cuddy Group over tipped at the site. In late 2016 the Cuddy Group applied for planning permission (P2016/0974) to tip a further 6,000 cubic tons of spoil at the site and this planning application was put forward by the planning department at NPTCBC, there is no evidence available that the planning department or NRW investigated the actions of the Cuddy Group. This confirmed our suspicions that the housing development was a front for the Cuddy demolition and asbestos removal operation and that the Cuddy Group had no intention of building houses. It also suggests that the planning department at NPTCBC are working with the Cuddy Group to facilitate their objectives in relation to the tipping allowing them to submit an application that increased the height of an already over height land form. Cause for concern: We were concerned that the planning department are working with an unscrupulous developer to facilitate the dumping of industrial waste as a front for a housing development.
Historical action specific / conflicting purpose of actions Potential barrels of toxic waste identified at the site	resident interview https://youtu.be/uugKZC7N7Cs	Nigel Taylor witnessed lorries dumping in the dark and full barrels of an unknown substance on the site. He went on site to physically check if the barrels were full or empty. Nigel Taylor was witness to backfilling at the site as was I. Nigel reported this information to councillors and nothing was done. The wife of one councillor, aged approximately 35-40, who lived 3 houses away from Nigel overlooking the site, died of unnatural causes in approx 2010. Local knowledge suggests that the cause of death may have been related to a neurodegenerative disorder. The councillor moved away from the area shortly afterwards and refuses to provide cause of death information. Cause for concern: We are concerned that the barrels that Nigel witnessed and physically tested that were to be dumped at the site contain toxic waste. The Cuddy Group are known to have demolished and remediated chemical plants that would contain toxic waste such as BP Llandarcy and the Monsanto Chemical works in Sully near Barry.
Deliberate avoidance of government rules & regulations. Council failure to follow Contaminated Land protocol 2008-2010		A chemical test was submitted as part of a planning application in 2008 along with safety considerations relating to the building process and a remediation strategy. The remediation should have taken place in order to protect people from the identified toxins. However, these plans were withdrawn. The site was then re-defined as brownfield in a new planning application which was approved. The brownfield status was then withdrawn and the land misrepresented in the Local Development Plan allowing the contamination to remain at the site un-remediated and the safety measures (human health risk assessment) were also ignored. Cause for concern: We are concerned that chemicals that remain on the site and have not been remediated in line with the council's Contaminated Land protocol will cause the death of residents. The removal of the requirement to remediate the land allowed the Cuddy Group to further tip industrial waste.
Deliberate avoidance of government rules & regulations Council failure to follow their published Contaminated Land protocol since 2020		In 2020 the land was tested again and found to be contaminated. Subsequent to this, the planning department worked together with the new developer, Enzo Homes and local councillors to remove the requirement for further testing of this contaminated area. Council officials have refused to provide a human health risk assessment as required by the Contaminated Land protocol. Cause for concern: We are concerned that chemicals that remain on the site and have not been remediated in line with the council's Contaminated Land protocol have already caused the death of residents and will cause further deaths if not remediated.
Common cause unnatural deaths Cause of death linked to contaminated land		There have been many unnatural deaths of residents surrounding the site with potential cancer clusters in Brynhyfryd, Heol y Glyn & Waun Gron. The most significant of these is the PSP cluster in Brynhyfryd. The incidences or national average of Progressive Supranuclear Palsy cases occurring in the UK are 1 in 100,000 people per year. Glynneath is a town of just under 5,000 people. This being the case, the expected incident rate of PSP occurring in Glynneath is approximately 1 case in every 20 years or 2 cases in 40. There are no other known cases of PSP in Glynneath. That 2 cases have occurred in a group of 5 houses and that both cases were diagnosed within a period of 2 years of each other following an intense period of tipping by the Cuddy Group is a serious cause for concern. PSP deaths can be linked to a similar contaminated land occurrence in France. The image on the right contains the relevant info from the death certificates. The ignored risk assessment (bottom image) shows that dust suppression methods should have been considered. None were used. Copies of the full document that relates to the PSP Cluster and resident video testimonies by the surviving relatives and those affected are available. Cause for concern: We are concerned that toxins from the site have caused the deaths of residents. Those contaminants that remain on the site have not been remediated in line with the council's Contaminated Land protocol. They will potentially cause the death of residents in the future.
Unnatural deaths evidence of probable cause Potential transmission of toxins identified.		In a telephone interview in March 2020 and a video interview dated May 2022, resident June Wehko identified that she and her husband Glen were affected by the dust originating from the Cuddy site as earth was being tipped and moved around during the summer months (video evidence available). We have identified this as a potential transmitter of the toxins that have caused the PSP disorders in Brynhyfryd. June lived in the middle house of the cluster (red arrow on illustration). June has subsequently passed away, believed to be from a complication to an operation. Several other residents have complained about the level of dust from the site. Cause for concern: We are concerned that toxins from the site have caused the deaths of residents. Those contaminants that remain on the site have not been remediated in line with the council's Contaminated Land protocol. They will potentially cause the death of residents in the future.
Verbal fabrication of information (competitive strategy) Threat of violence (competitive strategy) Public announcement / whitewash statement (competitive strategy)		In an incident at Glynneath Rugby Club, the NPTCBC Councillor Simon Knoyle threatened a 79 year old former committee member living next to the Heol y Glyn site with violence. This followed his deliberate misrepresentation of the facts surrounding the contamination at the Heol y Glyn site. The image to the left is a witness statement from a club member and the image to the right is Councillor Knoyle's version of events published to his Councillor facebook page. Cause for concern: This is not an isolated incident. Councillor Knoyle has for the last 2-3 years posted several 'whitewash' statements on his councillor account that have incited hatred against residents surrounding the site. It should be noted that the victim in this incident (Alun Roberts) lives next to June Wehko, (see above) and in between the PSP victims, Alwyn Phillips and Tegwyn Allen. His wife, died of cancer and his daughter has also had cancer. The person collecting this information from Keith Walters, a member of Glynneath Rugby Club, is Jennifer Herbert, who was at the time a serving Glynneath Town Councillor.
Destruction of public information Resident supplied documents destroyed		A document prepared for submission to the relevant authorities Glynneath Town Council, Neath Port Talbot Council, Public Health Wales, Natural Resources Wales and South Wales Police was submitted to two of our local (East Glynneath) councillors, Haulwen Morgan and Gerry Reynolds. The documents were disposed of by the councillors and not submitted to the council. However the covering letter (only) to the report was submitted by Haulwen Morgan and discussed by the Glynneath Town Council without mention of the report. This suggests a deliberate cover-up of the unnatural deaths of residents. Cause for concern: We are concerned that council officials who are aware of the potential deaths from contamination are deliberately covering up information and documents relating to the contamination to support their historical malpractice / corruption, that of their colleagues or their own personal agendas.
Historical action specific (competitive strategy) Refusal to follow government rules & regulations (competitive strategy) Probable altering of a relevant public document. (competitive strategy)		It is probable that the chemical test provided by Terra Firma was tampered with and the contamination is far worse than that recorded. (source: Ceri Morris, Head of Planning refusal to answer Stephen Hunt question 5 - CLICK HERE) The planning department at NPTCBC have a history of approaching specialist surveyors in relation to the development and changing information within submitted documents to support the developer. (source: I&G Consulting owner stated that the planning officer Nicola Lake approached the planning GJ Planning to change the information in a document dated March 2020 against his personal recommendation - middle image). The middle image shows the exact same report with two versions of the same paragraph. The alteration of the contents of the documents can be seen to suit the developer against that of the residents and the environment. The author of the report Wendy Larcombe works as a habitat surveyor for Neath Port Talbot Council. Cause for concern: We are concerned that council officials have worked with the developer, Enzo Homes and Terra Firma Wales Ltd to misrepresent the chemical test and have removed the shallow test for TP1-6 because of a high contamination result. It should be noted that the highest contamination values in the other test pits are always in the shallow result. This is consistent with a contaminated spoil heap having been spread over the test area (video evidence available that identifies this) The test pit TP1-6 deep result is by far the worst result of all the tests, it would therefore follow that the TP1-6 shallow test would be worse again. It is impossible to have obtained the TP1-6 test deep sample without having first removed the soil that would constitute the TP1-6 shallow sample. The green triangles in an 'excel' document indicate a formula error. This is consistent with the document being altered. This also throws doubt as to the authenticity of the 2008 test also made by Terra Firma which has several test results missing from the submitted document.