DESIGN & ACCESS STATEMENT

(INCLUDING MODIFICATIONS AS REQUIRED UNDER TAN 12 DATED JUNE 2009 AND TAN 22 DATED 22 SEPTEMBER 2010)

FULL PLANING APPLICATION

PROPOSED INDUSTRIAL UNIT, WITHIN THE DEMISE OF COMPLETE CORE, UNIT 6 YNYSBOETH ESTATE, CF45 4SF

INTRODUCTION

Complete Core Ltd. are a well established packaging company, who expanded into their own premises at Ynysboeth Estate, Abercynon, during the course of July 2011.

The company is growing from strength to strength, and now requires additional warehouse facilities, within the curtilage of their site.

This Application therefore outlines the details of those additional facilities.

SITE ASSESSMENT

The site chosen for the new storage facility, is to the immediate North of Complete Core’s main production facility, and is currently a large area of tarmacadum, unused by the company, other than for the storage of various surplus materials, which at present are accommodated within an external environment.

Complete Core’s main building has a generous area of operational and non-operational areas, associated with their building.

The main production facility circa. 3173.12 m² (34,156 sqft), is located in the South West corner of the site, leaving an extensive area of tarmacadum both to the East and to the North of their building.

LOCATION

Ynysboeth Estate is a small industrial estate, located approximately midpoint, between the interchange with the A470 to and the Town of .

The site is accessed by a heavily wooded road, accessed off the A459. This access, being located at the Northern end of what was previously a more extensive industrial location.

However, in recent years, the Southern part of the site, comprising a former electronics factory, has been developed, in favour of small scale private residential accommodation. At present therefore, there are only 2 – 3 industrial units remaining on the site, which (as indicated), are accessed via an access to the North of the site.

SUSTAINING AND ENHANCING LOCAL CHARACTER

As indicated below, the introduction of a further small industrial unit, will clearly enhance the immediate local character of this part of the site. As such, the proposals clearly promote legible development.

THE BRIEF

The main principle of our brief, is to provide important undercover storage facilities for our Clients.

Early on in the design process, our Clients identified the Northern tarmacadum area within their site, as being surplus to requirements, whilst at the same time, being ideally located to provide separate but linked storage facilities, ideally located to service their existing production facility.

Therefore, whilst the main purpose of the building is to solely provide an undercover storage facility.

PROMOTING RELATIONSHIP BETWEEN PUBLIC AND PRIVATE SPACE

The interface between the public access roadway to the site, and the private curtilage of our Clients premises, will be unaffected by the proposal.

THE DESIGN SOLUTION

Constructing small scale industrial buildings, is relatively expensive. Ideally, most manufacturers seek to purchase existing buildings, as it is often more cost efficient to purchase a redundant industrial building, rather than construct a new build. Certainly the Regulations associated with new build, and under some instances, the Requirements of BREEAM and other Legislation, also add significantly to the cost of construction.

The sole use of the building, is as indicated, for storage purposes. Our Clients have therefore chosen to propose a pre-fabricated building, which will be economic to construct, and quick to erect.

The proposal therefore envisages a simplistic industrial portal frame building, constructed from cold rolled steel work, rather than traditional hot rolled steel work.

As the buildings requirements are therefore purely functional, combined with the site’s completely hidden location, the aspects of Promoting Innovative Design are therefore not applicable to our Clients requirements.

COMMUNITY SAFETY

Complete Core’s Legal demise, has been well secured with 2.5 m high security fencing.

As indicated, there are housing areas both to the South and to the West of the industrial estate. However, they themselves are well segregated from the estate, not only by natural vegetation, but also by security fencing.

Security through natural surveillance, is therefore generally not possible, on the Ynsyboeth Estate. Hence the buildings and the site are well secured by security fencing and regretfully, roller shutters appear on all exposed windows to the building.

In summary, the site’s hidden and well landscaped location, coupled with our Clients need simply to provide additional but economic storage facilities, has been the main thrust of the design proposals. Cladding colours associated with the new building, will harmonise with those of the existing.

As indicated on the site cross sections, the scale of the proposed buildings, is similar to the existing buildings, other than the eaves height is slightly higher, whilst the ridge height will be slightly lower, when compared with the existing factory building.

Our overall assessment, is that a triangle based on ‘the Site’, the ‘Clients brief’ and ‘the Planning viewpoint., are well balanced by the proposals.

PRE-APPLICATION DISCUSSIONS

There have been no formal pre-Application discussions with the Local Authority Planning Department in respect of this Application.

However, we have considered that pre-Application discussions with the Environment Agency () are paramount in connection with this Project. We therefore wrote to EA (Wales) on 2 February 2012, to explore any concerns which they may have had with regards to the site’s potential for development.

This letter, plus the EA (Wales) response dated 27 February 2012, being enclosed within Appendix A to this document.

The EA (Wales) position at the time of writing this report, is that an FCA is required for the site.

However, we have subsequently identified that an FCA associated with Application 06/0937/10, concluded that the land levels associated with the site, are higher than EA (Wales) had been led to believe.

As part of the Application 06/0937/10 was concerned, an FCA was therefore not required. This was based upon the assumption that the criteria were based on predicted 1.100 year flood levels.

EA (Wales) current advice is that the criteria is 1.1000 years. Based on their initial information, their advice is that the FCA is required. To clarify this matter, we have written to EA (Wales) as of 22 May 2012, enclosing the original RS Drayton report on flood risk (November 2005) and asked them to finally clarify matters prior to our Clients expending substantial funds in respect of an FCA.

For your information, a topographic survey of the site related to Ordnance Survey datum, was sent to EA (Wales) as part of that communication.

Once we receive a response from EA (Wales) we will further advise you as to whether an FCA is to be undertaken.

ENVIRONMENTAL SUSTAINABILITY INCLUDING ENHANCING BIO-DIVERSITY AND DESIGNING FOR CHANGE

As identified above, the brief from our Clients, is to provide an undercover storage facility, both for packaging raw materials (i.e. corrugated card) , and packaged goods, awaiting delivery to Clients.

We do not envisage that the building will be heated, although the external walls will comprise composite thermally insulated panels. The roof to the building and the gable spandrel panels, will however comprise a stretch fabric material, which will in itself, provide some thermal resistance, therefore assisting with the internal temperature control of the building.

The aspects of the ‘efficient use’ and ‘protection of natural resources’ and ‘Design For Change’, have not been key elements in respect of the Project.

That said, our Clients business is expanding in difficult economic circumstances. However, having regards to the proposed use of the building and its location onto an existing hard standing area, we consider that (in this particular instance), the issue surrounding the use of natural resources, and developing our designs for future climatic change, have been proportionately considered within the context of the proposals.

The site itself is however surrounded by mature woodland on at least two sides. Clearly these areas will have developed their own bio-diversity, and ecological environment.

Our Clients proposals do not interfere with this environment.

DESCRIPTION OF THE SITE

The immediate site context, has been examined in the first part of this Statement. It comprises an under-utilised tarmacadum area, which is being partly utilised for the storage of surplus materials, along its Northern and Eastern boundaries.

The development will therefore regularise these materials to an external compound, assuming that they are not actually stored within the building context itself.

EXISTING USE OF THE SITE

The site is a well established industrial location, and is currently the main headquarters of Complete Core Business Solutions Ltd.

Both operational and non-operational car parking, are well defined and separated on the site, and will continue to be so, as part of the new proposals. At present, the site can comfortably accommodate a minimum of 23 parking spaces. Other non-operational spaces are identified within the rear and side service areas, but are not required either from a staffing viewpoint.

Our assessment of the non-operational parking requirement, being:

 40 spaces associated with the existing building

 17 spaces associated with the proposed building.

In both cases, non-operational parking can be easily accommodated, leaving sufficient area available for operational car parking, associated with both buildings. This totals 1628 m² whereas the requirement is 467 m² (combined operational space).

STATUTORY SERVICES

All Statutory Services associated with the proposals are available on the site. Information we have received to date, is enclosed as part of Appendix B to this report.

We are aware from our site inspection, that some form of surface water culvert passes within the vicinity of the site, and outfalls in an Easterly direction, below the railway track, towards the Avon Cynon.

Information obtained from the topographic survey, identifies a series of onsite surface water drains, leading to a large diameter (450 mm) outfall drain, towards the Avon Cynon.

Our proposals whilst affecting these drainage runs to a marginal extent, tend to minimise the external hard standing, rather than increase it.

Surface water from the new building, will therefore continue to connect into this existing on site system.

MATERIAL CONSIDERATIONS

We consider that the following Written and non-Written Material Considerations, are relevant to our Clients Application: NON-WRITTEN MATERIAL CONSIDERATIONS

 Our Clients business employs local staff, and continues (on a small scale) to expand in difficult economic conditions.

 The business immediate requirement is for an undercover storage area, which is satisfied by what is essentially a pre-fabricated building, being erected on the site.

 The building is of straightforward design, and harmonises well with the industrial form of the other on site buildings.

 The site at Ynysboeth Estate is extremely well screened and surrounded by mature woodland and advantageous topography, which contributes to the site’s attractive yet hidden nature.

 The building will be constructed on an existing tarmacadum area, and will therefore not be detrimental to the site’s immediate or adjacent ecological environment.

 The building will sustain the current employment levels within the valley, and may possibly contribute to increasing employment within the valley.

 Adequate car parking and serviced areas are easily provided by the existing site, with little if any physical alteration.

 Whilst a free standing building, the building is linked to the existing on site use, and therefore merely extends an existing well established business.

WRITTEN CONSIDERATIONS

The main Written Considerations associated with the site are associated with the following documentation:

 The adopted RCT Local Development Plan (March 2011)

 Planning Policy Wales 2010 – but subject to various revisions and consultations

RCT LOCAL DEVELOPMENT PLAN

This document was adopted as of 2 March 2011, and contains the following Policies we consider to be in support of our Clients Application:

Chapter 4 Core Strategy and Policies

 Paragraph 4.16 – identifies the importance of smaller settlements. Abercynon is listed as a ‘Small Settlement’ and the site is within Settlement Boundaries.

 Policy CS 1 – identifies criteria for development in the Northern strategy area. There are nine criteria listed, some of which are related to our Clients proposals. In particular, Criteria 1 and 9, are relevant.

 Paragraph 4.28 – identifies Policies to create sustainable communities in the Northern area. The proposals at Ynysboeth, are in line with this Policy.

 Policy CS 6 – identifies strategic employment sites, within the North and Southern areas. Ynysboeth, is not a Strategic Site.

 Paragraph 4.57 – raises concerns with regards to redundant industrial space. The Policy concludes that redevelopment and modernisation of existing employment sites will be fully supported.

Chapter 5 Area Wide Policies

 Policy AW 2 - sustainable locations – this Policy identifies that development proposals will only be supported in sustainable locations. There are 9 criteria, associated with definition of a sustainable location. The majority of these criteria are met by the design proposals. With regards to criteria 5, this deals with the aspect of sites which are vulnerable to flooding.

 Policy AW 4 – deals with Planning obligations. It lists criteria where Planning obligations may be sought. None of the criteria are relevant to the Ynysboeth Application, and therefore the imposition of a Planning obligation, is not applicable.

 Paragraph 5.23 – identifies that certain sites would become uneconomically viable if they were subjected to a Planning obligation. The Policy concludes that the Council may conclude that the benefits of the development outweigh the benefits of seeking to secure a higher quality scheme. We suggest that this is the case at Ynysboeth Estate.

 Paragraph 5.29 – identifies that new development should be highly accessible. Walking and cycling are identified as having an important role to play, in the management of movement across the County Borough. Developers will be required to ensure that new developments encourage walking and cycling. As indicated in the other part of this DAS, there is already evidence that some of the staff may either walk or cycle to the site. This is emphasised by the lack of onsite vehicles, during our site visit.

 Policy AW10 – environmental protection and public health – this Policy identifies that development proposals will not be permitted where they would cause or result in risk of unacceptable harm to health. There are nine points identified within the Policy context, none of which are applicable to the proposals at Ynysboeth. To reiterate, the proposals at Unit 6 Ynysboeth, are simply concerned with the storage of raw materials associated with packaging, or package goods, awaiting despatch to customers.

Chapter 6 Northern Strategy Area

 Paragraph 6.2 - identifies the areas considered to be within the Northern strategy area. Abercynon is located in the Northern strategy area.

 Policy NSA 12 – states that development will be permitted within the defined Settlement Boundaries, subject to seven criteria. The proposed development at Ynysboeth, lies within the Settlement Boundary, and is therefore subject to NSA 12. With regards to the seven criteria, the first four are relevant to our Clients Application and can all be satisfied by the proposals.

 Policy NSA 16 – is concerned with redevelopment of vacant redundant industrial sites. Whilst Ynysboeth Estate is still an active location, some parts of the Estate have in the past been redeveloped, as a result of over supply of industrial land. That redevelopment of the site is also in line with Policy.

 Paragraphs 6.72 and 6.73 – consider proposals for employment led mixed use schemes. Whilst these paragraphs are not specifically related to our Clients proposals, they do emphasise that schemes which are employment led, will be favourably received. The proposals at Ynysboeth Estate, comply with the principles of this Policy.

 Appendix 1 Section B – employment allocation – this section identifies key employment allocation in both the Northern and Southern strategy areas. Ynysboth, is not mentioned within these allocations, and is therefore not a key employment location as far as the LDP is concerned.

The second relevant document is:

PLANNING POLICY WALES, EDITION 3, JULY 2010

PPW 10 in simple terms, provides an overview of the Planning system in Wales. The document published in July 2010 has been subject to a number of updates since that time, the latest of which is a series of consultation documents, associated with Chapter 7, these happen to deal with supporting the economy.

Whilst these documents are still within the consultation process, a draft revised PPW Chapter 7, forms part of the documents, from which we note the following paragraphs which are offered in support of our Clients Application:

 Paragraph 7.21 – the draft suggests that the local plans and decisions should be based upon locally specific evidence which demonstrates the suitability of the existing employment land supply in relation to the location and development requirements of business.

 Paragraph 7.22 – Planning Authorities are required to ensure that the economic benefits associated with a proposed Project, are understood and that these are given equal consideration with social and environmental issues in the decision making process.

 Paragraph 7.6.1 – states that Planning Authorities should adopt a positive and constructive approach to applications for economic developments…..in determining Applications for economic land uses, Authorities should take account of the likely economic benefits of the development based on robust evidence. There are three sub paragraphs identified as key factors in this statement, some of which are relevant to the development at Ynysboeth.

From the July 2010 PPW documents, we offer the following actual and adopted Policy Statements:

 Paragraph 7.1.6 – identifies that all communities need employment opportunities. The Policy suggests that the Local Authority should give particular regard to the needs of small and medium sized enterprises.

 Paragraph 7.6.1 – the Policy states that in determining Planning Applications for industrial and commercial uses, Planning Authorities should have regards to a number of points which include:

o Impact of the development on the environment, particularly with regards to its scale, design and use of materials. o Proximity to and compatibility with residential areas o Compatibility with existing industrial and commercial activities – very important. o Whether intensification of industrial/commercial use is appropriate.

CONCLUSION

This report clearly identifies that our Clients brief, the design solution associated with that brief, and the Planning context in which this proposal will be considered, are generally all balanced and therefore should be acceptable.

The key issue on the site relates to a Flood Consequences Assessment and whether the building will upon further consideration be within the 1.1000 year flood plain.

Should the building be determined to be inside the 1.1000 year criteria, certainly an FCA will be required. That does however not mean that the proposals should not be acceptable.

Technical Advice Note 15, Development and Flood Risk (2004) - paragraph 5.1 of TAN 15 (figure 2) categorises general industrial development, as less vulnerable development. Therefore, if an FCA is required, the development may still be acceptable, dependent upon the recommendations, concluded within such a report.

Given the principles as identified above, we consider that in General Development Terms, the Application is acceptable.

ACCESS STATEMENT

INCLUSIVE DESIGN

The principles of Inclusive Design have been carefully considered from the outset with regards to this development.

The principles of Inclusive Design are:

 People are at the heart of the design process  That it acknowledges diversity and difference  That it offers choice for different users  That it provides for flexibility in use  That it provides buildings and environments that are convenient and enjoyable to use for everyone.

Inclusive Design

The principles of Inclusive Design, constitute a specific approach to barrier free environments. In particular, issues relating to access to the development, generally need to be dealt with. In many instances, the principles of Inclusive Design are relevant to buildings within the public realm.

In this specific case, the building is a single storey development, and is a large warehouse structure. The areas leading to the building are also within reason level, and (subject to some minor areas of ramped paving, outside critical access doorways), both the existing building and the new proposal, will be highly accessible, to both ambulant, semi ambulant and disabled persons.

The main construction legislation which governs the requirement for both access and facilities within commercial buildings, being Part M 2 / 3, of the Building Regulations. Our designs, will therefore comply with these requirements.

MOVEMENT

Technical Advice Note 12 – design – identifies that a heading under the section of ‘movement’ should be considered.

Consideration to be given to:

 The potential to cycle or walk  Connection to the existing transport infrastructure  The integration of different transport types  The ease of movement to and from the development for sustainable forms of transport  The provision for onsite facilities for sustainable forms of transport, are to be considered.

The site at Ynysboeth Estate, is within reason, accessible, via various means of transport such as:

 Private motor car  Public transport, access from the A459 (mainly bus routes)  Via walking or cycle routes, from the residential areas which are close to the Industrial Estate.

As can be seen from the site photographs taken on Friday 8 June (Appendix C), the factory staffing levels, whilst not 100% (at the time of our visit), were reasonable within the building. Yet there were substantially less than 5 on site parked vehicles.

The proposals constitute primarily warehouse facilities, and whilst staffing levels may be increased, there is more than sufficient capacity on the site, to cater for this.

CAR PARKING

The minimum car parking spaces available on site at the front of the building are 23 spaces. These are located on the Western boundary to the unit demise.

In addition, non operational car parking is available throughout the rear service area. Our proposals drawing rationalises this area into formal operational and non-operational parking.

The proposals associated with formal non operational parking, being set out on drawing reference no. 1489 PL 01. These total a minimum of 58 spaces.

There is an adequacy of both operational and non-operational space provided as part of the existing and proposed development. (See Schedule shown in Appendix D attached to this Report).

ACCESS

The objective of access as identified under TAN 12, is ensuring ease of access for all.

We have already identified the general approach to providing barrier free environments, early in this section.

Within the building, the requirements of M2/3, will govern the principles of access doorways and other facilities. These facilities, will provide access for all sections of society, including ambulant, semi ambulant, disabled, and older people.

As part of our process, we will be obtaining advice from both Access Officers and Local Access Groups. Consultations with groups representing staff members with disabilities, will also be consulted.

In general terms, there are no physical barriers to providing access for all groups within the site, Statutory Regulations will determine a requirement, for other access related items.

CONCLUSION

This Access Statement complies with the requirements of the GDPO 1995, and the requirements for Inclusive Design, as set out within the provisions of TAN 12.

There are no particular issues with regards to movement in and around either the existing building, or the proposed building.

We therefore believe that our Clients have met the requirements of both the GDPO and the new Welsh Assembly Government documentation dated 1 June 2009.

1489designandaccessstatement