PLANNING, DESIGN AND ACCESS STATEMENT

MERTHYR TYDFIL HOUSING ASSOCIATION

LAND AT EAST STREET AND UPPER UNION STREET,

PLANNING, DESIGN AND ACCESS STATEMENT

On behalf of: Housing Association

In respect of: Land at East Street and Upper Union Street, Dowlais

Date: July 2018

Reference:

Author: ST/OR

DPP Planning Sophia House 28 Cathedral Road CF11 9LJ

Tel: 029 2066 0265 E-mail [email protected]

www.dppukltd.com

CARDIFF LEEDS LONDON MANCHESTER NEWCASTLE UPON TYNE

Merthyr Tydfil Housing Association

Contents

1.0 INTRODUCTION ...... 4

2.0 APPLICATION SITE AND CONTEXT ...... 6

3.0 SUMMARY OF THE APPLICATION PROPOSAL ...... 12

4.0 PLANNING HISTORY AND PRE-APPLICATION ADVICE ...... 15

5.0 PLANNING POLICY CONTEXT ...... 19

6.0 PLANNING ASSESSMENT ...... 24

7.0 DESIGN & ACCESS CONSIDERATIONS ...... 30

8.0 CONCLUSIONS ...... 39

APPENDICES

Appendix 1 – Site Location Plan

Appendix 2 – Conservation Area Plan

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Merthyr Tydfil Housing Association

1.0 Introduction

1.1 This Planning, Design and Access Statement has been prepared in support of a planning application, submitted on behalf of Merthyr Tydfil Housing Association, in relation to the following development proposal:

“Proposed development of 12 new build affordable residential development, including associated retaining walls, parking, access and new footpath arrangements.”

1.1 This Statement outlines the context within which the application is made, and provides a detailed examination of the main planning considerations raised by the proposals, together with reasoned justification in support of the proposed development.

1.2 The statement is structured as follows:

• Section 2 provides a description of the characteristics of the site and surrounding area, and details regarding the planning history associated with the site; • Section 3 provides details of the development proposals; • Section 4 outlines the background and planning history of the site; • Section 5 outlines the relevant planning policy framework in relation to the site and the development; • Section 6 assesses the proposals in terms of the planning considerations; • Section 7 assesses the proposal in terms of its Design & Access; • Section 8 sets out our conclusions.

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APPLICATION SITE AND CONTEXT

Merthyr Tydfil Housing Association

2.0 Application Site and Context

2.1 The application site is located in Dowlais and is bounded by East Street, Commercial Street, and Upper Union Street as outlined in the plan below along with a copy of the location plan is enclosed in Appendix 1. The application site measures approximately 0.18ha in area. The site is a relatively steeply sloping site - falling to the south towards East Street.

2.2 The site is bounded to the north by Upper Union Street and the Cancer Aid Merthyr unit. To the east of the site beyond Commercial Street is Dowlais Market Gardens and Market Street. To the south is East Street, a predominantly residential street which accommodates two storey dwellings which, due to the topography of the area, are set at a lower level to the street. West of the site is a car park associated with Dowlais Library and open land.

2.3 The proposed site is located within the settlement limits of Dowlais as defined by the Local Development Plan (LDP) and is located to close to local amenities.

The Conservation Area

2.4 The site is located within the Dowlais Conservation Area. The plan below has been extracted from the Conservation Area Management Plan, with the application site circled blue ( larger scale version of the plan is appended in Appendix 2. The area embraces the surviving examples of the Dowlais industrial, social and religious heritage. The building are mostly Victorian with some Georgian era properties generally incorporating stone and render finishes with slate or concrete tiled roofs. At the core of the conservation area is an area of public open space (to the east of the site), which historically accommodated the old market hall and police station. It is identified in the Dowlais Conservation Area Character and Management Plan that the development of the site in question offers the potential to improve the quality/ character of the area.

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2.5 The below historical image (with the application site outlined red) indicates that this block was previously made up of buildings fronting onto the surrounding streets, with the Market Buildings to the east and the Stables to the north east.

2.6 The Dowlais Conservation Character Appraisal and Management Plan, adopted January 2014 acknowledges the opportunity of development potential on land adjoining the Cancer Aid Centre (the application site) to help enclose square and enhance the appearance of the area.

2.7 The key characteristics of the conservation area relevant to the consideration of this application is:

• Mostly Victorian with some Georgian era properties.

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• 2 and 3 storey buildings, interspersed with larger and taller civic buildings (church, library, social clubs) • Materials are generally stone and render with a mix of slate and concrete tiles for roofs. • Mostly residential uses interspersed with civic uses such as the library and social clubs. • Loose grid street pattern • Public open space at core of conservation area.

Built Form and Character

2.8 The below images seek to illustrate the variations in the character of the surrounding development and which are relevant to the discussion in respect of the design of the scheme:

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2.9 The above images are reflective of the key characteristics of the conservation area in that they highlight the use of stone, render and varying roof finishes. The more recent addition to the conservation area, the Cancer Aid Centre (bottom left) shows how a modern interpretation of the established character can be sympathetically incorporated, in that the elevations are predominantly render but the design includes some stone elements.

Accessibility

2.10 Dowlais is located to the north east of Merthyr Tydfil itself, however, it benefits from a good range of facilities and services. The below plan seeks to illustrate the main facilities and services, and the bus stops in the area.

Local Centre

Community Centre

Primary School

Infants School

Library

Post Office Bus Stops

2.11 In terms of accessibility, the site can be easily accessed by a number of modes of transport. Bus stops are located on Victoria Street beyond Church Street to the west of the site and on High Street which is located south of East Street. Services 28 and 35 operate from Victoria Street, with services 1, 2 and X4 from High Street. All of these services provide direct access to either Merthyr Town Centre, or to other locations where additional services and facilities can be accessed.

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2.12 Two schools are located within very easy walking distance of the site, additional services, including a library, post office and other shops are also within easy walking distance with the local centre being the furthest away, albeit still at a very accessible location.

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THE APPLICATION PROPOSAL

Merthyr Tydfil Housing Association

3.0 Summary of the Application Proposal

3.1 Merthyr Tydfil Housing Association seeks planning permission for the erection of 12 affordable residential units (C3 Use Class) together with associated retaining walls, parking and access arrangements. The 12 residential units will be set out as follows:

• 4 x 2 bed 4 person houses; • 6 x 1 bed person walk up flats; • 2 x 2 bed 3 person adapted bungalow.

3.2 The two bungalows will be located at the northern end of the site accessed off Upper Union Street. The front courtyard will be shared and include four parking spaces, incorporating a turning area. As can be seen on the illustration below, the building will be finished in a mix of stone and render, reflecting the character of the adjoining Cancer Aid unit and wider conservation area.

3.3 In terms of the houses, these are traditional two storey dwellings with rendered elevations and good qualityartificial slate roofs. The properties are located directly onto the new footpath on the northern side of East Street which ensures additional space at the rear for amenity space. Due to the topography of the land, the rear gardens are terraced - providing two reasonable, DQR compliant, spaces. Two parking spaces for each unit is provided off East Street.

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3.4 In terms of the flatted development, again this is a two-storey structure which turns the corner onto commercial street. Three flats are provided on the ground floor with an additional three at first floor level. Five of the six flats will be accessed from East street whereas one of the first-floor units will be accessed off Commercial Street.

3.5 The two main elevations of this building are proposed to be clad in stone with the East Street elevation including a rendered porch structure.

3.6 As highlighted above, a new footpath is proposed along the northern side of East Street and turning the corner up commercial street, joining onto an existing footpath which currently ends outside the Cancer Aid unit.

3.7 Car parking and operational space will be provided within the development. The parking allocations comprise of 1 parking space per flat, 2 per house and 2 per bungalow. As such, a total of 18 car parking spaces are proposed to serve the residential development.

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PLANNING HISTORY AND BACKGROUND

Merthyr Tydfil Housing Association

4.0 Planning History and Pre-Application Advice

Planning History

4.1 Full planning permission was previously granted for the erection of 2 no. semi-detached dwellings and 5 no. detached dwelling on the 5 June 2009. The permission previously granted allowed for a total of 10 units and follows a similar layout to the current application proposal. Whilst this permission has lapsed, it is clearly relevant to the consideration of this proposal for 12 affordable residential units within the site.

Site Layout of previous scheme approved under permission P/08/0214

4.2 The above permission establishes that two properties at the northern end of the site are acceptable, in this case these were two storey dwellings. Whilst the above scheme proposed detached dwellings along East Street, the principle of dwellings fronting onto East Street was accepted and considered acceptable. In addition, two parking spaces are provided for each site.

4.3 In terms of design, the properties were proposed to have rendered or stone elevations. Limited detail is available in respect of the roof finishes.

4.4 In terms of the existing Cancer Aid Centre, located directly adjacent to the proposed site at the junction of Upper Union Street and Commercial Street was approved on the 2 March 2006 (ref no. P/05/0633). The Cancer Aid Centre is a single storey property and utilises materials that are in

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keeping with the surrounding properties i.e. stone and render on the elevations with a slate roof, albeit the slate used is of poor quality and is deteriorating.

Pre-Application Advice

4.5 Pre-application advice for a proposed residential development was originally sought from the Council in February 2017 for a proposed residential scheme comprising 10 dwellings. The pre- application response supported the principle of development at the site by stating:

‘The proposed site is located within the settlement limits as defined by the Local Development Plan (LDP). As such the principle of the residential development is considered to be acceptable and is generally supported by policy BW4 of the LDP. The site is also situated in the Primary Growth Area where the majority of new development is encouraged by policy BW1 of the LDP.

It is acknowledged that planning permission has previously been granted on site (P/08/0214), comprising 10 two storey dwellings following a similar layout to this current proposal. Whilst this permission has lapsed, it is considered that there remains scope to consider a potential scheme for up to 10 residential units within the site.’

4.6 As part of this pre-application response, the Officer, Mr David Cross prepared a plan illustrating how the site could be laid out, and how the corner abutting the junction of East Street and Commercial Street could be addressed. Below is an extract from this:

4.7 The main points identified from a design perspective are:

• Pairs or triplets of double fronted cottages would be appropriate;

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• Bungalow to the north would relate well to the Cancer Aid Centre and complement it in design terms utilising similar materials and continuing boundary wall with railings above; • Concern that parking will dominate the frontage of the bungalows – potential for 1 parking space (if they’re 1 bed); • Frontage development on East Street is acceptable, but need to turn the corner onto Commercial Street; • Design and landscaping will be important in the overall quality; • Design of the retaining wall will be a key consideration.

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PLANNING POLICY CONTEXT

Merthyr Tydfil Housing Association

5.0 Planning Policy Context

5.1 This section addresses the relevant policies in both the national and local development framework. The statutory development plan for Dowlais comprises of the Merthyr Tydfil Local Development Plan 2006- 2021, adopted on the 25th May 2011.

National Policy

5.2 National Policy contained within Planning Policy (Edition 8, January 2016), and specifically the following chapters, are most relevant to the site:

• Chapter 6 – Historic Environment; • Chapter 8 – Transport; • Chapter 9 – Housing.

Historic Environment

1.1 Due to the site falling within the Dowlais Conservation Area, consideration is given to the historic setting.

1.2 PPW at Paragraph 6.1.1 confirms the importance of protecting the historic environment, setting out a series of objectives which development proposals should seek to achieve. Of key relevance to the application is the following:

“Ensure that conservation areas are protected or enhanced, while at the same time remaining alive and prosperous, avoiding unnecessarily detailed controls over businesses and householders.“

1.3 Paragraph 6.1.2 advises that local planning authorities have an important role in securing the conservation of the historic environment, whilst ensuring that it accommodates and remains responsive to present day needs. Paragraph 6.4.6 further states that development plan policies should make it clear that development proposals will be judged “for their effect on the character and appearance of conservation areas” to ensure that any new development is in accord with the area’s special architectural and historic interest. It goes on to set out that “whilst the character or appearance of conservation areas must be a major consideration, it cannot prevent all new development.”

1.4 It is confirmed at Paragraph 6.5.17 that there will be a strong presumption against the grant of planning permission should any proposed development conflict with the objective of preserving or enhancing the character or appearance of a conservation area, or its setting. Nevertheless, it is stated “the Courts have held that the objective of preservation can be achieved either by development which makes a positive contribution to an area’s character or appearance, or by development which leaves character and appearance unharmed.”

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Housing

5.3 Chapter 9 of PPW sets out ’s approach to housing. The approach, as set out in the National Housing Strategy is to:

• Provide more housing of the right type and offer more choice; • Improve homes and communities, including the energy efficiency of new and existing homes; and • Improve housing-related services and support, particularly for vulnerable people and people from minority groups.

5.4 Crucially, Chapter 9 states in para. 9.1.15:

“Affordable housing also makes an essential contribution to regeneration and social inclusion. It is desirable in planning terms that new housing development in both rural and urban areas incorporates a reasonable mix and balance of house types and sizes so as to cater for a range of housing needs and contribute to the development of sustainable communities. For affordable housing it is important that authorities have an appreciation of the demand for different dwelling sizes and types of housing (i.e. intermediate and social rented) in relation to supply, so that they are well informed in negotiating the required appropriate mix of dwellings for new developments.”

5.5 Due to the nature of the application by a Affordable Housing Provider, the 12 residential units proposed are 100% affordable housing. As such, the application complies with the Welsh Government’s approach to housing, as set out in Chapter 9 of PPW insofar that it improves housing- related services and support, particularly for vulnerable people and people from minority groups who can demonstrate their need for social housing.

Local Policy

5.6 The Merthyr Tydfil Local Development Plan (adopted May 2011) outlines at a local level the relevant policies against which the proposals will be assessed. This document also confirms the various designations relevant to the site. The red line on the below extract from the LDP Constraints and Proposals Map identifies that the site is:

• Within the Dowlais Conservation Area (Policy BW6); • Within the Merthyr Tydfil Landscape of Historic Interest (Policy AS4); • Within the Mineral Buffer Zone (Policy TB9 – Foss-y-Fran); • Within the Settlement Boundary Line (Policy BW4).

Strategic Objectives

5.7 The Vision and Primary Aim of the LDP has influenced the development of a variety of environmental, social and economic objectives. The following strategic objectives set out in the LDP are consistent with the proposal:

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i. Strategic Objective 6 – to provide a range of dwelling sizes and types, including affordable and special needs housing, which support the needs of the local community, attract new inhabitants to the area and create mixed and socially inclusive communities; ii. Strategic Objective 8 – To promote social inclusion and ensure equality of opportunity through reducing the need to travel and providing better access by sustainable means to employment opportunities, community facilities and services; iii. Strategic Objective 10 – To ensure good quality design of new development and the creation of safer communities.

Borough Wide Strategic Policies

5.8 Policy BW1 provides policy guidance in relation to the allocated primary growth areas in Merthyr Tydfil. Under this policy, the LDP targets the majority of new development towards the main Merthyr Tydfil settlement, which is classed as the Primary Growth Area. This community of Dowlais, in which the site is located is designated as a Primary Growth Area and the policy recognises that there is greater capacity for regeneration and development in this area than anywhere else in this .

5.9 Policy BW6: Townscape and Built heritage states that the Council will protect and support the enhancement of the unique built heritage of the County Borough. Development proposals will only be permitted where it can be demonstrated that they would preserve or enhance the architectural quality, character and setting of any of heritage assets.

5.10 Policy BW7 of the LDP, Sustainable Design and Place Making sets out that the Council will support good quality sustainable design and sets out a number of criteria against which any development proposal would be assessed. These include, amongst others, matters relating to scale and massing, amenity, and inclusive design.

5.11 Policies BW11 and BW12 of the LDP relates to transport, cycling and pedestrian proposals. Under this policy, proposals for new transport, cycling and pedestrian facilities will be favourably considered where they can demonstrate any new vehicular, pedestrian and bicycle movements can be safely accommodated within the site and provide safe access to wider routes.

5.12 Policy BW19 deals with the County Borough’s affordable housing target. Under Policy BW19, the Local Development Plan will provide 260 affordable dwellings across the County Borough in order to contribute to the identified level of housing need.

5.13 Due to the designation on the proposals map, Policy AS4: Historic Landscape is relevant. Under this policy, there will be a presumption in favour of the protection, conservation and enhancement of the main settlement of Merthyr Tydfil in accord with their status as Landscapes of Historic Interest in Wales.

5.14 Policy AS22: Affordable Housing contributions sets out that in order to ensure the delivery of affordable housing across the County Borough there will be a requirement to make a contribution

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towards affordable housing. Given this is an affordable housing scheme, this is largely irrelevant, however, the supporting text for Policy AS22 recognises that a considerable need for affordable housing has been identified across the County Borough and seeking appropriate levels of affordable housing in appropriate locations is an important factor in the Council’s drive to achieve more sustainable communities. It is therefore important that the Council maximises affordable housing provision wherever possible.

5.15 Policy TB11: Access, parking and accessibility of local facilities states that proposals for development should ensure that:-

• Any new highways are designed and constructed in accordance with the Manual for Streets and include operational and non-operational parking provisions according to adopted standards set out in CSS Wales – Wales Parking Standards, and the land use , density and location proposed; and • The access needs and mobility requirements of all sections of the community, particularly those with special needs and disabilities, are met.

Policy Conclusions

5.16 Assessed in terms of the objectives and general principles of PPW and the relevant provisions of the Development Plan, we conclude that:

• The application site lies within Dowlais, identified as a Primary Growth Area within the LDP and represents a use that is entirely appropriate for its location; • The site is well located in order to integrate into the surrounding settlement of Dowlais and connect to existing services and community facilities; • The proposal will be accessible by a variety of modes of transport and is, therefore, in accordance with the objectives of PPW and the Development Plan; • The proposal will provide 100% social housing and will address the identified need for social housing within Merthyr Tydfil; • The proposal will result in the enhancement of the Dowlais Conservation Area, through the regeneration of vacant land which makes no contribution to the character of the area.

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PLANNING ASSESSMENT

Merthyr Tydfil Housing Association

6.0 Planning Assessment

6.1 In light of the policies summarised within the previous section, the main issues for consideration are considered to be:

• The principle of development in this location; • Design and Heritage • Amenity; • Highways and Accessibility; • Arboriculture; • Archaeology; and • Ecology.

Principle of Development

6.2 The site falls on undeveloped land located within the settlement limits of Dowlais as defined by the Local Development Plan (LDP). The site is surrounded by existing residential development. Accordingly, the principle of residential development, and specifically affordable housing, in this location is considered to be acceptable and is generally supported by Policy BW4 of the LDP, subject to other material considerations.

6.3 The site is also situated in the Primary Growth Area where the majority of new development is encouraged by BW1 of the LDP.

6.4 Whilst this proposal would be compliant in and of itself, it is noteworthy that the principle of the use is supported by previously approved application on this site (ref: P/08/2104) for the erection of 8 dwellings, along with the positive response to a more recent pre-application advice request for the erection of 10 dwellings at the site. The proposal has therefore been informed by both these responses.

6.5 A key strategic objective of the LDP, under SO3 is to ‘promote regeneration through the use of suitable and appropriate brownfield land rather than greenfield sites.’ Due to this proposal falling on a previously developed site, it is compliant with LDP Strategic Objective SO3. The LDP follows the principle of a brownfield strategy putting the emphasis on the development of previously developed land rather than greenfield sites. The Plan also aims to achieve high-density development where appropriate and seeks the use of imaginative and sustainable design solutions.

6.6 Strategic objective SO8 aims to promote social inclusion and equality of opportunity through reducing the need to travel and providing better access by sustainable means to employment opportunities, community facilities and services.

6.7 The proposal is entirely compliant with Policy BW17, given its nature as a 100% affordable housing scheme within the local defined settlement boundary – thereby promoting equal opportunity and social inclusion. Furthermore, the proposal seeks to provide high density accommodation where

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access to services and facilities is optimal with the site providing excellent access to sustainable means of employment within the surrounding areas.

6.8 A key strategic objective within the Local Authority, as underpinned by policies SO6 and BW19 is to provide a range of dwelling sizes and types, including affordable and special needs housing, which support the needs of the local community, thereby attracting new inhabitants to the area and create mixed and socially inclusive communities. The proposed scheme delivers this goal by providing a mix of units which are deemed to be in demand in the area.

6.9 In the light of the above, it is considered that development of the application site for new residential development is complaint with both national and local planning policy and is entirely appropriate in the context of surrounding land uses.

Design and Heritage

6.10 The site is located within the Dowlais Conservation Area and therefore the design and heritage considerations are key to the success of the scheme. It is noteworthy that the Conservation Area appraisal identifies that there are two main areas of vacant land within the designation that have been assessed as being a ‘weakness’ – thereby detracting from the overall character of the area, but also that this is therefore an opportunity to make improvements to the character and appearance of the Conservation Area. This site is one of those areas.

6.11 This section should be read in conjunction with the Design & Access Considerations chapter later in this Statement, however, as identified within previous sections, the main design and heritage considerations are considered to be:

• Scale and mass of dwellings; • Frontage development; • Materials; • Relationship with Market Garden; • L:andscaping; and • Retaining walls;

6.12 In general terms, the properties conform with those approved as part of the previous approval on the site. In addition, they are considered to be in accord with the pre-application feedback received for a similar scheme last year.

6.13 In terms of scale and mass, the bungalows off Upper Union Street replicate the scale of the Cancer Aid Centre to the west, albeit their ridge lines are lower so as to avoid ‘competing’ with the Centre. The two storey dwellings on East Street are reflective of the surrounding scale and mass, and the approved scheme from 2009, and are therefore reflective of a relatively simple style of architecture which is characteristic of this area.

6.14 Properties front the public spaces - creating enclosure to East Street, Upper Union Street, and where possible along Commercial Street. Parking is provided mainly to the side of the buildings,

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creating ‘breathing space’ between these units. These properties reflect the traditional terraces found on Market Street, in that they back almost directly onto the back of the footpath.

6.15 In terms of materials, the surrounding context is mixed, however, the conservation area is characterised by a mixture of render, stone, slate and concrete tiles (as confirmed that the Conservation Area Appraisal). The proposed use of render and stonework – particularly on the elevation facing the Market Garden is therefore entirely in-keeping with the surrounding. Given the mixed nature of roof finishes, the proposal is to include good quality artificial slates. It is noteworthy that the use of such material has been considered appropriate within other MTCBC Conservation Areas, notably in Merthyr itself on the site developed by MTHA on Lower Thomas Street – the former Adulum Chapel site.

6.16 One of the main opportunities resulting from the pre-application discussions was the potential to create an enclosure to Market Gardens. Whilst the cost and ability to construct a building in line with that illustrated on the pre-application responses is prohibitive for an affordable housing scheme, the proposals have addressed this point and created active elevations on Commercial Street along with an access into one of the flats directly from the street. Accordingly, the proposals have successfully addressed this opportunity.

6.17 In terms of the retaining walls, the proposal has sought to stay away from a crib-lock system and are proposing a concrete wall. To create interest, it is proposed that the wood grain from the moulds would be retained creating a wood effect onto the face of the concrete.

6.18 Accordingly, it is considered that the design of the scheme will make a positive contribution to the character and appearance of the Conservation Area through the development of a vacant piece of land which currently detracts from the character of the area. The materials used are reflective of those that surround the site. The properties seek to address and enclose the Market Garden, and the properties provide frontage development onto East Street and Upper Union Street. The proposal is therefore considered to be in accordance with policies of the Local Plan which seek to protect or enhance the character of the Area’s heritage assets – namely Policy BW6

Amenity

6.19 The proposed scheme has carefully considered any potential impact on the neighbouring properties. The neighbouring properties that have the greatest potential to be affected by the developed are the Cancer Aid Centre adjoining the northern part of the site and the residential properties along East Street.

6.20 Key to the consideration of this proposal is the previous permission on the site from 2009. The proposals put forward initially for this historic scheme were 2.5 storey in height and it appears that during the negotiation of this application the height was reduced – partly we would suggest for design purposes, but also to reduce any potential impact on the amenity of existing properties along East Street. The eventually approved scheme proposed two storey cottage style dwellings which were considered acceptable in terms of their impact on amenity.

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6.21 Considerations relating to amenity have not changed since this previous application was approved. Accordingly, given that the scheme proposed as part of this submission is almost identical, it is considered that the proposal would not give rise to unacceptable impacts on the amenity of adjoining residential properties.

Highways and Accessibility

6.22 The site is located within the settlement boundary of Dowlais, and is therefore in planning terms considered a sustainable location and benefits from services and facilities.

6.23 Two parking spaces are provided for each dwelling, with the exception of the flats where only one space is provided. Accordingly, the development accords with the parking requirements. In addition, where necessary, vehicles are able to turn within the site and exit in a forward gear, albeit given the nature of the road network in this area, with low speeds, relatively narrow carriageways, and low car movements, it is not considered that being able to enter the carriageway in a forward gear is of paramount importance in highway safety terms.

6.24 Notwithstanding this, the site is sustainably located and within easy walking distance of bus stops which provide regular and direct services into Merthyr and beyond. These stops are located some 230m to the south along High Street and 70m to the west along Victoria Street.

6.25 In addition, Dowlais library is located adjacent to the site, Dowlais Infants and Primary Schools are located within a similar distance to the bus stops, a selection of local shops are located some 400m to the north of the site along Victoria Street. Finally, Dowlais Community Centre is located some 170m to the north.

6.26 It is evident therefore that the site is sustainably located close to local amenities so that any resident without a car can comfortably access services and facilities with little difficulty.

Arboriculture

6.27 An Arboricultural Report has been commissioned to inform the design of the development. The report identifies one group of trees on site but classifies this as grade ‘C’ I,e, being of low quality and contributed very little to the character of the area – further describing the tree as being “a group of sprawling untidy goat willow, multistemmed from ground level, short lived species prone to branch/stem failure, some dead and declining stem noted, and limited future. “

6.28 The arboricultural assessment concludes that the site has potential to accommodate development with no significant trees on or adjacent to the subject site that should be given due consideration in the development design process.

Archaeology

6.29 The Archaeological desk-based assessment undertaken by Archaeology Wales in May 2017 states that the site lies within the registered Historic Landscape (HLW (MGL) 2) and more specifically

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within the Historic Character Area of Dowlais (HLCA 007). The proposed development is considered to have a Minor impact on this Historic Landscape Character Area.

6.30 The assessment states that the proposed development will partially impact upon views of the Grade II* Listed Dowlais Works Blast Engine House (LB 11491) to the southeast. This impact however is considered to be negligible. No further listed buildings, scheduled ancient monuments or historic parks and gardens will be impacted upon by the proposed development.

Ecology

6.31 A Phase 1 Ecological Assessment prepared by David Clements Ecology, provides a range of recommendations to minimise any adverse impacts to wildlife features and protected species.

6.32 The habitats on site, comprising grassland, scrub and scattered trees are considered to be of some value to fauna such as foraging bats and birds and invertebrates, but are unlikely to have any significance in this regard. These habitats therefore are considered to have no more than Local Value for wildlife. Development of the site will result in the loss of the majority of habitats within the site.

6.33 Notwithstanding the above, and on the basis of evidence currently available, it is concluded that the site could be redeveloped without causing significant adverse impacts to wildlife. It is therefore considered that the proposed development of this site would not be unacceptably constrained by biodiversity issues.

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DESIGN & ACCESS CONSIDERATIONS

Merthyr Tydfil Housing Association

7.0 Design & Access Considerations

7.1 Planning Policy Wales (2016) identifies in Paragraph 9.3.4 that in determining planning applications for residential uses, local planning authorities should seek to ensure that proposals do not damage an area’s character and amenity with high quality design being of particular importance.

7.2 TAN 12 – Design (2016) identifies the role of design in improving the quality of the places we live and work. The key objectives of good design are considered to be access, character, movement, community safety and environmental sustainability. Paragraph 1.5 of TAN 12 confirms the statutory requirement for submission of a Design and Access Statement that examines the proposals in the context of the key design objectives.

7.3 The below discussion seeks to establish the main constraints and opportunities before discussing the proposal under the main relevant headings.

Constraints and Opportunities

7.4 The below plan seeks to identify the main opportunities and constraints of the site, and which have informed the design of the scheme:

Market Garden

Relationship with Cancer Aid Centre Sloping Land Frontage Development Important Corner Relationship with Market Garden Sun Path Overgrown vacant land contributing nothing to character of area.

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7.5 The opportunties that arise from this assessment is the potential to:

• Remove an area of overgrown vacant land which contributed very little to the character and appearance of the area; • Create frontage development onto East Street; • Frontage development onto Upper Union Street; • Frontage development onto Commercial Street – albeit the topography of the site means that frontage development that turns the corner onto Commercial may be difficult to achieve; • Provide some enclosure to Commercial street to enclose the Market Garden; • Potential to turn the corner at the junction of East Street and Commercial Street.

The Proposal

7.6 The proposed development has been set out in detail in Chapter 3, however, below is a summary of the proposals:

The above plans shows how the site is proposed to be laid out with the two bungalows at the northern end, the four dwellings fronting East Street, and the flatted development turning the corner of East Street and Commercial Street. Below are extracts from the context elevations submitted alongside the application.

Land at East Street and Upper Union Street, Dowlais 31

Merthyr Tydfil Housing Association

East Street Elevation

Commercial Street Elevation

Upper Union Street Elevation

Assessment of Design & Access

Character

Placemaking

7.7 An important element of the design of the scheme, and therefore its success in creating a sense of place, is that it results in frontage development onto East Street and Upper Union Street. The development also turns the corner onto Commercial Street, however the ability to create full frontage development along Commercial Street is limited due to the topography and depth of the site at this location.

7.8 The cost of creating a building which turned the corner (as illustrated in the pre-application response) would be prohibitive and would not necessarily create adequate accommodation to meet affordable housing standards. Nevertheless, the building on the corner provides active elevation to Commercial Street thereby effectively turning the corner. In addition, an access to the top floor flat is provided off Commercial Street – thereby creating additional activity along this frontage.

Land at East Street and Upper Union Street, Dowlais 32

Merthyr Tydfil Housing Association

7.9 Accordingly, the design of the scheme creates frontage development which, as far as is possible given modern design standards, is in-line with the historic grain of the site and successfully creates a sense of place.

Amount and Density

7.10 The topography of the site does restrict the amount of development that can be achieved. The previous permission on the site achieved 8 units, and the pre-application discussions undertaken more recently indicated 10 units would be acceptable. This application now proposes 12 units altogether – consisting of two bungalows (semi-detached), four two bedroomed dwellings (again semi-detached), and six 1-bed flats within a single block

7.11 Planning Policy Wales makes it clear that existing brownfield sites should be utilised to their fullest to reduce pressure on greenfield sites. In addition, given the cost of retaining structures on site, the development needs to deliver a certain number of units. Notwithstanding this, the provision of 6 flats on the corner of Commercial Street and East Street means that additional units can be achieved whilst not resulting in over development of the site.

7.12 The density of development is in keeping with those around the site particularly the historic terraces found within the conservation area, albeit modern design standards and modern living demands, means that the same level of density can not be achieved.

7.13 The amount of development is therefore considered to be in line with the previous approvals on the site and the pre-application feedback, whilst also makes a positive contribution to the character of the conservation area.

Streets

7.14 Given the nature and size of the site, there are no internal streets within the development. A clear aspiration of the development, however, is to relate well to existing streets around the site. Accordingly, by creating frontage development onto East Street, Upper Union Street, and part of Commercial Street, the proposal addresses existing streets and provide enclosure to them – reinforcing the character of the area.

Spaces and Public Realm

7.15 Similarly, to the streets section above, the nature and size of the site does not lend itself to providing any public or open space. The development seeks to reinforce street enclosure by setting buildings as close to the street as possible – a clear characteristic of the historic grain of this conservation area. Parking is therefore provided to the side of the dwellings, save for the bungalows on Upper Union Street, and a footpath created along East Street.

7.16 In terms of the bungalows off Upper Union Street, parking is provided on the frontage, within properties set back from the frontage.

Land at East Street and Upper Union Street, Dowlais 33

Merthyr Tydfil Housing Association

7.17 The spaces and public realm created are therefore considered to be in line with the character and appearance of the conservation area, thereby making a positive contribution.

Scale

7.18 The previously approval on the site, and the advice provided within the pre-application response indicates that a mixture of single storey and two storey dwellings are appropriate for the site. The scale of the buildings are in-line with this aspiration and are therefore considered acceptable in the context of the conservation area.

Layout

7.19 As highlighted above, the layout of the site has been informed by the need to address the surrounding streets. The historic grain of built form in the area is of terraced housing built up to the back of the footpath. Again, whilst modern design and living requirements do not allow this to be fully implemented on this site -particularly given its topography, every effort has been made to replicate this grain by siting dwellings wherever possible close to the back of the footpath and locating parking spaces to the side of properties.

7.20 In terms of the flatted element of the scheme, a communal car park is proposed which is overlooked by the flats creating natural surveillance. In addition, the public spaces around the development are overlooked – again aiding in creating a sense of ownership and community safety.

7.21 In terms of Commercial Street three of the six flats front onto the street, with one of the flats being accessed directly from it. This in turn creates activity and legibility to the street.

Materials

7.22 As identified within the Conservation Area Appraisal, and within the assessment of the context of the site, the Conservation Area is characterised by a mixture of rendered or stone elevations, and slate or concrete roofs. The larger, more civic type buildings are almost exclusively built in stone with little or no render. The day-to-day residential style properties are more of a mixture of render and stone.

7.23 The proposal has therefore sought to reflect this in its finish. In terms of East Street, the semi- detached dwellings are characterised by rendered elevations with good quality artificial slate roofs. Their designs are relatively clean with no overtly fussy architectural features to reflect the architectural character of some of the terraced housing within the conservation area.

7.24 The flat building which turns the corner onto Commercial Street is finished in stone on both the East Street and Commercial Street elevations. The use of stone provides a different character to this corner unit – distinguishing it from the properties on East Street and thereby creating interest on this important corner of the site. Again, good quality artificial slate is proposed on the roof of the building.

Land at East Street and Upper Union Street, Dowlais 34

Merthyr Tydfil Housing Association

7.25 The bungalows seek to reflect the design of the adjoining Cancer Aid Centre in being predominantly render, but with Stone finish to the front gable ends.

7.26 The use of good quality artificial slate can provide as positive an appearance as slate. As is evident from the slate used on the Cancer Aid unit, the use of natural slate can result in issues of discolouration which reduces the effectiveness of their use. MTCBC have previously, and very recently, accepted the use of artificial slate within the Merthyr Tydfil Conservation Area. This is the former Adulum Chapel site (application ref. P/16/0371) where a Redland cambrian slate in slate grey colour was accepted. This slate includes 60% recycled slate and has the appearance of slate. It is considered that this would be in keeping with the character of the area, whilst ensuring that the properties remain affordable in construction terms.

7.27 In light of the above, it is considered that the proposed materials are acceptable and will enhance the character and appearance of the conservation area.

Access

7.28 Given the nature of the scheme – being 100% affordable housing development, access for all and meeting space standards is at the heart of the design. Notwithstanding this, the nature of site does restrict the ability to create level spaces without the need for some stepped access – particularly to some garden spaces.

7.29 Notwithstanding the above, all accesses into the properties at the front are level – ensuring that everyone can access the units. The parking courtyards are largely level, and any changes in level are accommodated by a slightly sloping gradient.

7.30 In terms of external private amenity spaces, these are level where possible. The dwellings off East Street require significant retaining walls, however, the scheme has sought to minimise the impact of these by providing a tiered approach – creating two different spaces for the properties. A reduction in the number of parking spaces could improve the extent of the amenity space at ground level for each dwelling, however this would need to be discussed as part of the planning application.

7.31 Overall, given the nature of the scheme, accessibility for all is at the heart of the proposals. As an affordable housing provider, MTHA need to ensure that a range of different abilities can be accommodated. The scheme therefore reflects this through the provision of a range of house types and level accesses provided wherever possible.

Movement

7.32 Whilst Dowlais is a comparatively small settlement, it benefits from a number of services and facilities. The site is well located to access these services both on foot or by bike. The site offers wider connections to Victoria Street and High Street which again provide excellent services via public transport to Merthyr Tydfil town centre and also other settlements in the area.

Land at East Street and Upper Union Street, Dowlais 35

Merthyr Tydfil Housing Association

7.33 The proposed development ensures that these connections are taken advantage of and increases the ability of residents to access them by creating additional footpath along East Street and up Commercial Street, connecting into an existing footpath which currently ends at the access to the Cancer Aid unit.

7.34 The proposal therefore strengthens the movements patterns in the area.

7.35 In terms of the approach to parking, the general standards have been met, in that one space is provided per bedroom. Parking spaces are generally located to the side of the property or within their own courtyard. Given the accessibility to services and facilities locally, it is considered that the parking level could be reduced to the benefit of the overall scheme. Such discuissions can take place during the planning applciation process, however, as it stands the level of parking is considered appropriate and meets the policy requirement.

7.36 The level of traffic along East Street is considered to be generally low and is subjected to a 20mph speed limit. Whilst the proposed driveways along East Street would necessitate vehicles to reverse onto the highway, it is not considered to cause a significant highway safety issue. Furthermore, the provision of the new footpath along one side of East Street ensures that adequate pedestrian segregation is provided within the development.

7.37 Whilst vehicles can turn within the site for the two bungalows, it is considered that given the nature of Upper Union Street – being 20mph and a relatively low trafficked area, vehicles could reverse out onto the road without causing material highway safety issues. Further discussion on this during the course of the planning application process would be beneficial, given the benefits that would result in providing additional green space at the front of the bungalows.

7.38 Accordingly, it is considered that the proposed scheme positively contributes to the movements patterns around the site, without causing any material highway safety issues. In addition there would appear to be scope for reducing car parking numbers to the benefit of other design elements, which would enhance the development.

Environmental Sustainability

7.39 The site is considered to be highly sustainable and provides excellent access to a number of local services and facilities accordingly this is considered to reduce the need for reliance on the private car thereby encouraging walking and cycling.

7.40 In terms of the sustainability of the dwellings, they are expected to meet building regulation standards for sustainability. The properties are, wherever possible south facing and will therefore benefit from solar gain.

7.41 In terms of ecological issues, the development would not result in the loss of any statutorily protected habitats which would reduce the ecological interest of the site.

Land at East Street and Upper Union Street, Dowlais 36

Merthyr Tydfil Housing Association

Community Safety

7.42 A significant element of the design of the scheme is the frontage development onto the surrounding streets. This is a significant improvement in terms of community safety because at present, the properties which are currently on East street have limited overlooking of the street, and therefore do not provide particularly good surveillance. These properties would materially enhance this.

7.43 This is also the case for Commercial Street, where currently there is no surveillance at all. The addition of a direct access into one of the flats from Commercial Street significantly enhances the surveillance and activity along the street. In addition, windows from two other flats overlook the street, thereby further increasing surveillance.

7.44 The parking courtyard for the flats is also well overlooked with windows directly overlooking it and access into flats from it.

7.45 Accordingly, it is considered that the scheme would bring significant benefits to the area from a community safety perspective.

Conclusion

7.46 As outlined at the outset, the key design and access principles of the development in light of its location within the conservation area are:

• To remove an area of vacant land which detracts from the character of the area; • To provide frontage development; • To turn the corner from East Street to Commercial Street; • Provide a degree of enclosure to the Market Garden; and • Respect the setting of the Cancer Aid Centre.

7.47 The proposed development has addressed all of the above points in that the site will be developed for affordable housing which provides frontage development onto all adjoining streets; the materials used respect and enhance the character and appearance of the conservation area; the Market Garden will now be overlooked and enclosed by the development. Finally, the bungalows on the northern end of the site respect the setting of the Cancer Aid Centre being set at a lower level and being slightly set back from its building line.

7.48 Accordingly, it is considered that the development would result in an overall enhancement to the character and appearance of the Conservation Area, in line with policy BW6 which seeks to ensure that the County’s heritage assets are protected or enhanced. ACCESS CONSIDERATIONS

Land at East Street and Upper Union Street, Dowlais 37

CONCLUSIONS

Merthyr Tydfil Housing Association

8.0 Conclusions

8.1 In summary the site is located within a settlement boundary and in a sustainable location, in the heart of Dowlais, a recognised primary growth area within the county borough of Merthyr Tydfil.

8.2 The use of a vacant site, which currently contributes nothing to the character and appearance of the conservation area, would bring significant benefits to the area. Such benefits would include creating much needed social housing in the area and contributing to the vibrancy of the area. We conclude, therefore that the proposal will positively contribute towards sustainable development which represents a key policy objective.

8.3 The proposed scheme is in line with the previously approved scheme on the site and also reflects the pre-application discussions had last year on a similar scheme. Accordingly, it is considered that the site is fully in accordance with the Merthyr Tydfil Local Development Plan and we would therefore respectfully request that planning permission is granted accordingly.

Land at East Street and Upper Union Street, Dowlais 39

APPENDICES

Merthyr Tydfil Housing Association

APPENDIX 1 SITE LOCATION PLAN

Land at East Street and Upper Union Street, Dowlais 41

Merthyr Tydfil Housing Association

APPENDIX 2 CONSERVATION AREA PLAN

Land at East Street and Upper Union Street, Dowlais 42

Merthyr Tydfil Housing Association

Land at East Street and Upper Union Street, Dowlais 43

DPP Planning Sophia House 28 Cathedral Road Cardiff CF11 9LJ

Tel: 029 2066 0265 E-mail: [email protected] www.dppukltd.com

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