Planning, Design & Access Statement
Land to the North & East of Cypress Gardens, Newton, Porthcawl, Bridgend, CF36 5BZ
Outline Planning Application For Residential Development
C.H Knight & Partners
August 2020
Client: C.H Knight & Partners Report Title: Planning, Design & Access Statement
Contents
1. Introduction ...... 3
2. The Site: Location & Extent ...... 5
3. Pre-Application Dialogue & Design Evolution ...... 10
4. Planning Policy Context ...... 13
5. Design and Access Proposals ...... 20
6. Key Material Considerations ...... 26
7. Summary ...... 34
Appendices
Appendix I Site Location Plan
Appendix II Indicative Site Layout Plan
Appendix III Proposed Access Arrangements
Appendix IV Candidate Site Representation to BCBC’s Revised Local Development Plan (2018-2033)
Figures
Figure 1 Site Location Plan
Figure 2 Extract from LDP Proposals Map
Status: Draft v1 Date: 03 August 2020
For and on behalf of Avison Young (UK) Limited
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1. Introduction
The Purpose of this Statement
1.1 This Planning, Design and Access Statement has been prepared to accompany and support an outline planning application to develop the vacant scrubland located to the north and east of Cypress Gardens in Newton for residential purposes, together with associated parking, landscaping and ancillary works.
1.2 The application is submitted to Bridgend County Borough Council (BCBC) by Avison Young, on behalf of C.H Knight & Partners.
1.3 The extent and location of the site is shown on the Site Location Plan below.
Figure 1: Site Location Plan
Structure of this Statement
1.4 This statement has been prepared in line with the requirements and recommendations of Technical Advice Note 12: Design (TAN 12), BCBC’s own guidance on Design and Access Statements (DAS) and having regard to the ‘Design and Access Statements in Wales Why, What and How’ (June 2017) guidance, which builds on that understanding and responds to legislative requirements for DAS under the Planning (Wales) Act 2015.
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1.5 This statement seeks to demonstrate the acceptability of the proposed development in the context of relevant planning policy, taking into account the context of the site and the surrounding forms of development. The remainder of the statement is, therefore, structured as follows:
▪ Section 2 provides an explanation of the context of the application including site details, relevant planning history, a description of the proposal and the rationale behind the application;
▪ Section 3 provides the detail of the pre-application enquiry submitted to the Council and a summary of the Council’s response;
▪ Section 4 provides a review of the planning policy context relevant to the proposal;
▪ Section 5 interprets context and policy analysis into a set of guiding principles for the development of the site before going on to describe the proposed development in greater detail, giving specific details regarding the evolution of the scheme, and design and access considerations (as required by TAN 12);
▪ Section 6 considers the primary planning issues, providing a comprehensive analysis of how this proposal conforms with relevant policy and planning considerations, and
▪ Section 7 provides an overview and concludes the statement, confirming that there are a number of material benefits arising from the proposals which ought to justify the grant of planning permission.
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2. The Site: Location & Extent
Location & Context
2.1 The application site extends to approximately 0.68 hectares and is situated to the north and east of Cypress Gardens, which is located in Newton, on the eastern side of Porthcawl.
2.2 The site comprises unused land that is well suited for residential development, immediately bounding Cypress Gardens to the south and a public right of way to the north, beyond which is a belt of vegetation and tree cover that screens the properties fronting Lime Tree Way. To the east is open land that extends along the coastline towards Candleston Castle.
2.3 The surrounding area is predominantly residential in character and form, largely consisting of detached dwellings benefitting from front and rear gardens, with respective driveways accessed from cul-de-sacs served by the main estate roads.
2.4 There is plentiful informal, formal and incidental open space located within the vicinity, much of which is located to the east of the site and south of Cypress Gardens, including a Council owned playing field.
2.5 Newton benefits from a range of existing facilities including plentiful open space, a children’s equipped play area, a day school, football pitches, tennis courts, churches and numerous public houses.
2.6 The site is positioned on the eastern edge of Newton in close proximity to the route of the Wales Coast Path, overlooking Merthyr Mawr Warren and Newton Burrows. The village of Newton dates from the 12th Century, although there has been significant residential development in more recent years taking advantage of the good access links offered by the A4106 (Bridgend Road).
2.7 Beyond Newton, to the west, lies Porthcawl (identified in the adopted Local Development Plan (LDP) as one of the four strategic growth areas in the County Borough). The site is circa 1.5 miles from Porthcawl town centre and the retail, employment and community facilities offered there. The town also benefits from a significant historic and natural amenity resource.
2.8 Access to the site can be achieved from Cypress Gardens, which benefits from an existing turning head that abuts the site’s southern boundary. The information that supports this application demonstrates that Cypress Gardens can be extended from the existing turning head to provide sufficient access via an adoptable highway and private drives.
2.9 The site location plan, attached at Appendix I, clearly defines the site and its context.
The Application
2.10 The application is submitted in outline form, with all matters reserved for future consideration except for the access arrangements.
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2.11 The description of development for the proposed scheme (on the outline planning application form) reads as follows:
“Residential development, together with car parking, landscaping and ancillary works.”
2.12 The indicative site layout plan and details of the proposed access arrangements are included in Appendix II & III of this statement.
Relevant Planning History
2.13 Based upon a search and review of the Council’s online planning records, there are a number of historic planning permissions of relevance to the site. The most significant planning permissions are listed below:
Planning History Schedule
LPA Ref: Applicant Proposal Decision
Full planning application for residential Tythegston development – 12 no. detached dwellings, new P/04/1726/FUL Millennium Refused 29/03/2005 access onto Cypress Gardens and associated Trust landscaping.
C.H. Knight & Outline planning application for residential P/99/426/OUT Refused 06/07/1999 Partners development - 4 no. detached dwellings
(N.B. the above is based on a desktop inspection of available information on Bridgend County Borough Council’s website)
2.14 We understand the 2004 planning application (LPA reference P/04/1726/FUL) was partly refused on the basis of highway safety in connection with limited carriageway width. The Council’s Highway Engineers suggested that a reduced form of development may be given sympathetic consideration as the associated traffic movements are unlikely to generate significant adverse effects on the local highway network.
2.15 In addition, we note that a representation was made for the site’s development for residential purposes (LDP Candidate Site reference 792.B1) to the candidate site consultation stage of the then emerging LDP.
2.16 A representation was also submitted to the Deposit LDP objecting to the Plan Strategy, the Proposal Map and Strategic Policies SP1, PLA1, ENV3 and COM2. This representation objected to the Plan on the basis the site should not be excluded from the proposed settlement boundary, should not be included in the Special Landscape Area and that it was not identified as a residential land allocation.
2.17 We also note the Inspector of the Unitary Development Plan (UDP), which preceded the LDP, accepted the site would represent a logical rounding off of development, the protective designations should be removed and the site included in the settlement boundary. However, the ‘Alternative Sites Consultation Report’ for the LDP failed to support the allocation of the site (LDP Alternative Site reference AS007) or the extension of the settlement boundary, regardless of acknowledging the site being located within a Strategic Regeneration Growth Area (SRGA) and adjoining settlement limits.
2.18 For ease of reference, we have included the UDP Inspector’s comments below:
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“… An illustrative plan was submitted with the objection showing how four dwellings might be accommodated on the site. A proposal for development on these lines could, in my opinion, be considered on its merits under Policy H3, which permits small scale infilling and rounding off in main settlements including Porthcawl. However, I conclude that there is no reason to allocate it under Policy H1 of the UDP.”
2.19 The Inspector further stated that:
“The objectors (CE Knight & Partners) argue that the objection site, which is located within the coastal zone, is surrounded on three sides by housing development and is inappropriately included within the coastal zone. I accept that it is important to protect the unspoilt beauty and character of the coastline, but I consider this site to be almost enclosed by residential development and different in character from the open land immediately to the east. The site is outside the Heritage Coast, Merthyr Mawr SSSI and the proposed Newton Burrows Local Nature Reserve….”
2.20 These comments clearly remain pertinent to the consideration of this site and support the allocation of the site or, indeed, the extension of the settlement boundary to include it.
The Proposals
2.21 It is proposed is to develop the site for residential purposes. The proposed residential scheme would comprise private market dwellings with the policy compliant level of affordable housing (i.e. 30%).
2.22 An indicative site layout plan has been prepared by Powell Dobson Architects which demonstrates that 20 no. dwellings can be suitably accommodated on the site, comprising a mixture of detached and terraced units.
2.23 The proposed dwellings would each have front and rear gardens with on-plot parking and garages or dedicated parking conveniently located. The policy compliant level of parking provision will be provided within the site.
2.24 Due consideration has been given to the legislative requirement to provide sustainable drainage systems on the site. As such, the indicative layout includes an attenuation pond and rain garden features, which will provide sustainable urban drainage and enhance the aesthetics of the site.
2.25 Access and egress will be provided by a continuation of Cypress Gardens, which will provide an adoptable spine road into the development site. Private driveways will extend from the spine road to the east and west.
Rationale for the Proposals
2.26 The application site is surrounded on three sides by the settlement boundary and within close proximity to Porthcawl, which is defined by the LDP as a Strategic Regeneration Growth Area (SRGA). It is not within open countryside and is close to an established settlement; being on the urban fringe, opposite existing and proposed dwellings, served by existing infrastructure associated with the surrounding housing development and can be integrated easily into the neighbouring built up area. The site, therefore, presents a sustainable,
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realistic and deliverable opportunity to provide much-needed new homes in Bridgend; representing a logical extension of (or rounding off of) an established and well served key settlement.
2.27 Technical Advice Note (TAN) 1 and the requirement therein for a five-year supply of housing land was revoked by the Welsh Government by the Ministerial letter issued on 26th March 2020. This letter sets out that high quality new homes in the right locations are essential for our future wellbeing. Accordingly, a number of changes were announced including:
▪ Revisions to the ‘Housing Delivery’ section of Planning Policy Wales, Edition 10. The changes remove the five-year housing land supply policy and replace it with a policy statement making it explicit that the housing trajectory, as set out in the adopted LDP, will be the basis for monitoring the delivery of development plan housing requirements as part of LDP Annual Monitoring Reports.
▪ The revocation of Technical Advice Note (TAN) 1: Joint Housing Land Availability Studies (January 2015) in its entirety as a consequence of the policy change to PPW.
▪ Publication of the Development Planning Manual, Edition 3 (DPM) which provides additional guidance on the process of monitoring against the housing trajectory.
2.28 Given the infancy of this policy change, it seems appropriate to review and comment on the County’s historic rate of housing delivery.
2.29 The 2019 Joint Housing Land Availability Study (JHLAS) for Bridgend was the sixth assessment of the County Borough’s housing land supply since the adoption of the LDP in September 2013. It was also the third successive assessment demonstrating that Bridgend has a housing land supply for the Plan area below the 5 year requirement identified within TAN1 (the 2017 JHLAS identified a 4.0 year supply, the 2018 JHLAS identified a 3.4 year supply, whilst the 2019 JHLAS identified a 2.9 year supply). This is reflected in Annual Monitor Reports (AMRs) which have been published to date.
2.30 BCBC is required to commence a full review of the LDP every four years, the process for which has commenced. This will assist in meeting the 2021 deadline for having an adopted revised LDP in place to avoid having a local policy vacuum that the new Regulations threaten to create. At present, the LDP period will cease on 31st December 2021; meaning a revised LDP will need to be in place by 1st January 2022.
2.31 TAN 1 stated that where a shortfall in the housing land supply is identified, the LPA, in its AMR, should consider the reasons for the shortfall and whether the LDP should be reviewed either in whole, or in part. The LDP has been monitored on an annual basis with the publication of 3 AMRs. The AMR assesses the extent to which the LDP’s strategy, policies and allocations are being delivered and how effective it has been in delivering the Plan’s overall vision and objectives.
2.32 In terms of housing delivery to-date, a total of 579 new dwelling completions (general market and affordable) were recorded between 1st April 2018 and 31st March 2019. Cumulatively, there has been a total of 2807 dwelling completions recorded since the Plan’s adoption (i.e. 18th September 2013). This is significantly below the annual need of 1136 dwellings and the total housing requirement of 9690 dwellings over the Plan period (2011 – 2021), as identified by the LDP. Put simply, there is a shortfall of 5572 dwellings. It is evident that key housing sites are not being delivered as anticipated, which suggests the need for
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additional site allocations and windfall sites or, indeed, a change to planning strategy to assist with housing delivery.
2.33 The LPA has identified a clear issue needing to be addressed in respect of the lack of a five year housing land supply and the need for new sites to come forward to allow for the Plan to better reflect and deliver the housing requirements through to 2033.
2.34 The LDP Review Report was published in June 2018, with a recommendation agreed by Members that a ‘full’ review of the LDP should be undertaken. The Review identified that consideration would be given to adopted spatial strategy to determine whether it remains ‘fit for purpose’ and it will be necessary to allocate additional sites.
2.35 The need for a full revision of the LDP is, therefore, essential given the necessity to review housing supply to ensure that it is sufficient and reflective of the amended growth requirements evidence.
2.36 The preparation of the Revised Bridgend Local Development Plan (RLDP) (2018 – 2033) has begun and a representation for the residential development of the application site (RLDP Ref: 345.C1) was submitted to BCBC following the invitation to submit candidate site details.
2.37 The Deposit Stage of the RLDP (i.e. scheduled for consultation in the summer of 2020) provides the next opportunity to make representations on potential site allocations. However, plan preparation is an inherently slow process and the Covid-19 pandemic will likely impact the Plan’s delivery timescale. This means there will soon be no readily available avenue for new housing sites to come forward and, in any case, the current Plan is underperforming and therefore site delivery is questionable. As a result, housing needs are not being met and there is a neglected opportunity to fuel up the economy through development.
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3. Pre-Application Dialogue & Design Evolution
Preface
3.1 This section of the statement considers how the context to the site and pre-application dialogue with the council has informed the evolution of the scheme.
3.2 The proposals have been designed in response to pre-application discussions and consultations with Bridgend County Borough Council (BCBC) which were informed by a:
▪ Topographical Site Survey ▪ Preliminary Ecological Appraisal ▪ Landscape Character Visual Impact Assessment ▪ Concept Drainage Layout ▪ Illustrative Site Layout Plan & Parameters Plan ▪ Site access general arrangement and vertical alignment design (including swept path analysis) ▪ Transportation Technical Note
Pre-Application Dialogue with the Council
3.3 Avison Young submitted a planning pre-application enquiry to the BCBC on 9th March 2020 for the residential development of the land. This enquiry was accompanied by a series of proposed plans and drawings, together with a supporting cover letter and sought the council’s views of the proposals in respect of:
▪ The principle of the proposed development; ▪ The scope of the technical documents required in support of the planning application, and ▪ An assessment of the material considerations applicable to the proposals.
3.4 The enquiry was validated by the council on 18th March 2020 and a pre-application Skype meeting was held on 9th May 2020 with the following officers of the council:
▪ Mrs Hayley Kemp (Principal Planning Officer) ▪ Mr Gareth Denning (Development Planning) ▪ Mr Leigh Tuck (Highway Officer) ▪ Mr Gethin Powell (Land Drainage Officer) ▪ Mr Robert Jones (Ecology Officer)
3.5 The council issued its response to this planning pre-application enquiry on 20th May 2020 (LPA Reference PE/79/2020), which included advice from the Council’s Development Plans Officers, Environmental Health Officers, Highway Engineers, Drainage Engineers and Ecologist.
3.6 In relation to the principle of residential development, council officers highlighted the adopted planning policy position insofar as the site is located outside of the designated settlement boundary and, as such, is considered an inappropriate form of development that is both out of accord and contrary to LDP Policies
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PLA1 and ENV1 and the Preferred Strategy set out in the LDP Review. However, officers acknowledge that Policy ENV1 allows exceptions to development in such locations where it has an appropriate scale, form and detail for its context. The indicative development proposed has been designed to be sympathetic to the surrounding context, having minimal impact on the landscape and being appropriate in scale and form. This is demonstrated through the Landscape Visual Impact Assessment and illustrative site layout plan.
3.7 BCBC’s response indicates the site is within the Special Landscape Area (SLA) and the Merthyr Mawr, Kenfig and Margam Burrows Landscape of Outstanding Historic Interest. However, having queried this with the Planning Officer, confirmation has been provided that there was a typo in the pre-application response letter and the site actually falls outside of both these designated areas.
3.8 The key outcomes of the pre-application enquiry were as follows:
Visual Amenity – The submitted Landscaping Character and Visual Impact Assessment (LCVIA) appears to address the relevant criteria.
Public Rights of Way – Footpath 17 (POR/17/1) is located to the north of the site and runs from east to west. This route will need to be realigned to skirt the development site from the entry to exit points.
Agricultural Land Classification (ALC) – The Welsh Government’s predictive ALC map shows a small portion of the eastern portion of the site be categorised as Grade 2 and Grade 3b agricultural land. The illustrative layout has been revised to remove the dwellings from this land.
Residential Amenity/Design/Layout – The layout and design of the scheme is generally acceptable, subject to reorienting Plot 9 to provide better outlook for the mid-terraced properties opposite. The scheme has been redesigned accordingly.
Noise – BCBC has requested any future application is accompanied by an assessment of the construction and clearance noise levels in accordance with the British Standards. Given that outline planning permission is sought this matter can be controlled by way of a suitably worded condition.
Contamination – A former landfill site has been identified in close proximity to the application site. Whilst BCBC’s records do not show contamination at the site itself, officers have requested an assessment of the nature and extent of contamination. A Phase 1 Geo-Environmental Assessment has been prepared and accompanies the application.
Highway Safety – A Transport Assessment (TA) should be provided which considers the transport hierarchy of PPW10 with the main emphasis on how this development will be served by sustainable forms of transport. In addition, within that TA should be a junction capacity assessment of the priority junction of Danygraig / Bridgend Road and Danygraig / Birch Walk to understand if this development will push those junctions over capacity. The development should seek to upgrade and improve walking and cycling routes from the boundary of the site to link with the existing walking and cycling provision. In addition, a Travel Plan will be required as part of the TA as well as a Transportation Implementation Strategy of how and when any measures highlighted in the Travel Plan will be implemented. Further to this, officers raised some detailed design-related commentary with regard to parking, access and the internal arrangement of the proposed highways.
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Drainage – A surface water drainage application will need to be submitted to the Sustainable Drainage Approval Body (SAB). This will be progressed separately and at the appropriate time.
Planning Obligations – In line with adopted planning policy and based on the current situation, the following sums/provision would be requested:
▪ 30% affordable housing (i.e. 6 units) ▪ £1,000 per dwelling towards outdoor recreation provision (we would seek to argue this should not apply to the affordable dwellings)
Ecology – The submitted Preliminary Ecological Assessment (PEA) has scoped out the main ecological issues and will allow for more detailed operational/mitigation measures to be set out in a Construction Environment Management Plan / Habitat Management Plan.
Landscaping – Officer requested a detailed landscaping scheme for the site including details of all proposed hard and soft landscaping.
3.9 Please note that the above points have been addressed in this Planning Statement or in supplementary documents accompanying the submission of the outline planning application.
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4. Planning Policy Context
Preface
4.1 Section 38 (6) of the Planning and Compulsory Purchase Act 2004 requires that an application for planning permission should be determined in accordance with the Development Plan, unless material considerations indicate otherwise.
4.2 The planning policy that supports the proposal exists at a number of levels and extends to a range of guiding documents. To highlight the site’s potential, the following sections record the main provisions of the principal statutory planning documents and strategies of relevance. It establishes the context within which the proposed development will need to be brought forward.
4.3 National guidance comprises Planning Policy Wales Edition 10 (PPW) (December 2018), as well as a range of supplementary Technical Advice Notes (TANs). At the local level, the Bridgend Local Development Plan (LDP), which was adopted in September 2013, comprises land allocations as well as specific ‘land use’ policies against which all planning applications are considered. Relevant Supplementary Planning Guidance (SPG) seek to supplement the policies of the LDP and also form material considerations.
4.4 According to the proposals map (Figure 2) accompanying the LDP, the site falls outside the settlement boundary for Newton (edged in purple). Whilst the site is located outside the settlement boundary, it is surrounded by it and the curtilages of existing dwellings to the north, south and west.
4.5 The site is located outside, but adjacent to, the Merthyr Mawr Warren Special Landscape Area (SLA) and the Merthyr Mawr, Kenfig & Margam Burrows (Cadw reference HLW(MGI)1), which is a Registered Historic Landscape.
Figure 2: Extract from LDP Proposals Map
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4.6 The site is located within a limestone resource safeguarding area.
4.7 Given the nearby presence of Newton Burrows and Merthyr Mawr Warren, the site may be archaeologically sensitive. Whilst there are no listed buildings in the vicinity of the site, Merthyr Mawr Warren is designated as a Scheduled Ancient Monument (SAM) (Cadw reference: GM432). This area consists of the multi-period remains of a large number of archaeological sites, which range from prehistoric funerary, ritual and domestic remains through to medieval/post-medieval deserted settlement.
4.8 The site is not subject to a statutory ecological designation. The coastal zone (Merthyr Mawr Warren) to the south and east is designated as a Site of Special Scientific Interest (SSSI), a Special Area of Conservation (SAC) and a Site of Importance for Nature Conservation (SINC), although the site does not form part of these designations, nor does it form part of the Glamorgan Heritage Coast.
4.9 A Public Right of Way (PROW) cuts across the site’s northern boundary and runs in an east to west direction.
4.10 According to the Development Advice Map, accompanying Technical Advice Note 15 (Development and Flood Risk), the site is not located within an area of known flood risk.
National Planning Policy
Planning Policy Wales (Edition 10)
4.11 PPW (Edition 10) sets out the land use planning policies of the Welsh Government (WG). This contains guidance for the preparation of Local Authority’s development plans, development management, and sets out the WG commitment to creating sustainable developments.
4.12 The primary objective of PPW is to ensure that the planning system contributes towards the delivery of sustainable development and improves the social, economic, environmental and cultural well-being of Wales, as required by the Planning (Wales) Act 2015 and the Well-being of Future Generations (Wales) Act 2015.
4.13 Chapter 2 of PPW relates to ‘People and Places’ and seeks to promote the concept of placemaking in both plan making and development management decisions in order to achieve the creation of sustainable places and improve the well-being of communities.
4.14 Planning policies, proposals and decisions must seek to promote sustainable development and support the well-being of people and communities across Wales. PPW suggests this can be achieved by maximising their contribution to the achievement of the seven well-being goals and by using the Five Ways of Working, as required by the Well-being of Future Generations Act.
4.15 The seven well-being goals within the Well-being of Future Generations Act provide a shared vision to work towards – emphasis is placed on the importance of achieving all the goals within a proposal.
4.16 PPW identifies 5 Key Principles that provide a guiding vision for all development plans, including the National Development Framework (NDF). These are as follows:
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1. Growing our economy in a sustainable manner;
2. Making best use of resources;
3. Facilitating accessible and healthy environments;
4. Creating & sustaining communities, and
5. Maximising environmental protection and limiting environmental impact.
4.17 In responding to the key principles for the planning system, PPW states that development proposals must seek to deliver development that addresses the following national sustainable placemaking outcomes.
▪ Creating and sustaining communities
▪ Making best use of resources
▪ Maximising environmental protection and limiting environmental impact
▪ Growing our economy in a sustainable manner
▪ Facilitating accessible and healthy environments
4.18 It is accepted that not every development will be able to demonstrate it can meet all of these outcomes.
4.19 PPW must be used to implement placemaking. To do so, proposals should be prepared within the context of the key planning principles of the planning system in order to meet the well-being goals.
4.20 PPW first requires development proposals to be assessed against the ‘Strategic and Spatial Choices’ (Chapter 3). Thereafter, an assessment must be made of the detailed impacts of the development proposals and its contribution to ‘Active & Social Places’ (Chapter 4), ‘Productive & Enterprising Places’ (Chapter 5) and ‘Distinctive & Natural Places’ (Chapter 6).
4.21 The results of the assessment should promote well-being goals and sustainable placemaking outcomes, by ensuring the proposals contribute to sustaining or creating sustainable places and delivering the national sustainable placemaking outcomes identified above.
Technical Advice Notes (TANs)
4.22 As set out above, PPW is supplemented by a series of Technical Advice Notes (TANs). A range of these apply to the proposed development, and their specific provisions are addressed through the information submitted in support of this planning application. Relevant TANs include:
▪ Technical Advice Note 2 (Planning & Affordable Housing) was published in 2006 and requires local planning authorities to include an affordable housing target in the development plan; indicate how the target will be achieved using identified policy approaches, and monitor the provision of affordable housing against the target.
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▪ Technical Advice Note 5 (Nature Conservation & Planning) was published in September 2009 and provides advice about how the land use planning system should contribute to protecting and enhancing biodiversity and geological conservation.
▪ Technical Advice Note 12 (Design) was updated in 2016 and provides detailed advice on how good design in development may be facilitated by the planning system. The guidance states that good design has the potential to assist in environmental sustainability, economic growth and social inclusion. The guidance places particular emphasis on the achievement of sustainable design solutions, sustaining or enhancing character, promoting innovative design solutions, ensuring access for all and promoting legible development.
▪ Technical Advice Note 18 (Transport) was published in 2007 and recognises the key role of the planning system to facilitate sustainable travel patterns. As in TAN 12, the guidance aims to influence the location of new development to reduce the need to travel and subsequently promote more sustainable forms of transport which contribute to environmental improvement in the longer term.
▪ Technical Advice Note 20 (Planning and the Welsh Language) was published in October 2013. This provides guidance on how the planning system considers implications of the Welsh language. A TAN 20 Practice Guidance Note was published in June 2014 which should be read in conjunction with TAN 20, but has been produced to assist local planning authorities in the preparation, monitoring and review of their Local Development Plans.
▪ Technical Advice Note 23 (Economic Development) was published in February 2014 and focuses on the need to encourage development in order to generate wealth, jobs and income. This TAN recognises the importance of all aspects of development and that planning decisions are made in a sustainable way which balance social, environmental and economic considerations.
Local Planning Policy
4.23 The Planning and Compulsory Purchase Act 2004 introduced the requirement for all local planning authorities to produce a new form of development plan for their areas – a Local Development Plan (LDP). Accordingly, The Unitary Development Plan was superseded by the LDP following its adoption in September 2013.
4.24 Taking into account the site’s context and applicable designations, the following planning policies of the LDP and relevant Supplementary Planning Guidance (SPG) are considered relevant to the redevelopment proposals:
▪ Policy SP2: Design and Sustainable Place Making – states that all development should contribute to creating high quality, attractive, sustainable places which enhance the community in which they are located, whilst having full regard to the natural, historic and built environment.
▪ Policy SP4: Conservation and Enhancement of the Natural Environment – sets out criteria to be adhered to ensure development will conserve and, wherever possible, enhance the natural environment of the County Borough.
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▪ Policy SP5: Conservation of the Built and Historic Environment – seeks to conserve, preserve or enhance the built and historic environment and development will only be permitted where it can be demonstrated that they will not have a significant adverse impact upon the listed building and their settings, conservation area and their settings and historic landscapes, parks and gardens.
▪ Policy SP14: Infrastructure – requires that developments include material proposals which deal with the fair and reasonable infrastructure requirements of the development to mitigate negative impacts that may arise as a consequence of the development.
▪ Policy PLA11: Parking Standards – requires all developments to provide appropriate levels of parking. This should be in accordance with adopted parking standards.
▪ Policy ENV1: Development in the Countryside – seeks to control development within the countryside. Although the policy accepts development may be appropriate in certain circumstances and states that where development is acceptable in principle in the countryside it should where possible, utilise existing buildings and previously developed land and/or have an appropriate scale, form and detail for its context.
▪ Policy ENV3(9): Special Landscape Areas – states that the settings of SLA's will be protected with consideration of the views from those areas to the settlements of the County Borough.
▪ Policy ENV4: Local/Regional Nature Conservation Sites – seeks to ensure developments which would have an adverse impact on LNRs, SINCs or RIGS will not be permitted unless the benefits associated with the development can be demonstrated to outweigh the harm and/or the harm can be reduced or removed by appropriate mitigation and/or compensation measures.
▪ Policy ENV6: Nature Conservation – requires proposals for development (where possible) to retain, conserve, restore and enhance existing nature conservation features.
▪ Policy ENV9: Development in Mineral Safeguarding Areas – in the case of residential development, the policy requires development proposals to demonstrate the scale and location of the development would have no significant impact on the possible workings of the resource.
▪ Policy SP12: Housing – identifies the county’s housing land supply and states that provision will be made for the development of 9,690 new dwellings in Bridgend County Borough up to 2021.
▪ Policy COM4: Residential Density – requires that on sites exceeding 0.15 hectares in size new residential developments will be built at a density of at least 35 dwellings per hectare, although it is recognised that lower densities can be accepted.
▪ Policy COM5: Affordable Housing – seeks the provision of 30% affordable housing on sites capable of accommodating 5 or more dwellings or exceeding 0.15 hectares in size.
▪ Policy COM11: Provision of Outdoor Recreation Facilities – requires the provision, or the equivalent value, of a satisfactory standard of outdoor recreation space for all new housing developments.
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Supplementary Planning Guidance (SPG)
4.25 The Council provides a range of Supplementary Planning Guidance (SPG) which comprises detailed guidance on the way in which policies of the LDP will be applied in particular circumstances or areas. All necessary guidance has been taken account of when designing the scheme. The SPGs of relevance to the application are as follows:
▪ SPG 8 – Residential Development
▪ SPG 7 – Trees and Development
▪ SPG 13 – Affordable Housing
▪ SPG 16 – Education Facilities and Residential Development
▪ SPG 17 – Parking Standards
▪ SPG 19 – Biodiversity and Development
Emerging Planning Policy
Revised Local Development Plan (2018 – 2033)
4.26 BCBC is required to commence a full review of the LDP every four years, the process for which has recently commenced. This will assist in meeting the 2021 deadline for having an adopted revised LDP in place to avoid having a local policy vacuum that the new Regulations threaten to create. At present, the LDP period will cease on 31st December 2021; meaning a revised LDP will need to be in place by 1st January 2022.
4.27 A report was presented to BCBC’s Development Control Committee on 14th February 2019 outlining the draft vision and objectives for growth and spatial options as part of the revised Local Development Plan. The report estimates a population increase of 8.4% to 155,013 by 2033, with a dwelling requirement of 7,575 (505 dwellings per annum) and employment growth of 3,990 (266 pa) over the plan period. Progressing along this trajectory would induce similar levels of residential development to those witnessed in recent years, see more established working aged households remaining in the County Borough and provide significant scope to secure complementary infrastructure. The preferred spatial strategy option (4), proposes to continue to focus growth on Bridgend, Porthcawl, Maesteg and the Llynfi Valley recognising that some ‘greenfield’ sites may be required to deliver future housing requirements for the County Borough up to 2033.
4.28 The RLDP will identify specific sites to deliver housing and other major development needs, such as employment and retail, in Bridgend up to 2033. To inform these site allocations the council invited landowners, developers, and other interested parties to submit details of potential sites for development or reuse (known as ‘the call for candidate sites’). A representation for the residential development of the application site (RLDP Ref: 345.C1) was submitted to BCBC following the invitation to submit candidate site details (included at Appendix IV).
4.29 More recently, BCBC published its pre-deposit proposals (Preferred Strategy) in relation to the Replacement LDP, the consultation for which closed on 8th November 2019.
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4.30 The next stage in the LDP process is to prepare a Deposit Plan for consultation beginning in July/August 2020.
Supplementary Planning Guidance
4.31 On 16th January 2020, Bridgend County Borough Council’s Development Control Committee approved the ‘Recreation Facilities and New Housing Development’ and ‘Education Facilities and Residential Development’ draft SPGs. These documents were published for a period of public consultation which ended on Friday 3rd April 2020. They are yet to be adopted.
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5. Design and Access Proposals
Preface
5.1 This section of the statement takes forward the key findings of the appraisal of context, which are firstly interpreted into a set of guiding principles, before the evolution of the scheme’s design is described.
5.2 This section then goes on to draw upon the advice and design objectives contained within Chapter 3 of PPW 10 and TAN 12, and considers how the context to the site has informed the evolution of the proposed development. These matters are addressed under the following key topics:
5.3 Character (including considerations of placemaking, amount and density, streets, spaces and public realm, uses and tenure, scale, layout, heritage and detail design);
▪ Access and Inclusivity;
▪ Character (including consideration of use, amount, layout, scale, appearance and landscaping);
▪ Community Safety;
▪ Environmental sustainability; and
▪ Movement to, from, and within the development.
Interpretation of Context
5.4 The development proposals have been informed by the site’s context, which comprises its physical and socio-economic context, as well as the planning policy context, relevant planning constraints, the outcome of the pre-application enquiry and the statutory pre-application consultation exercise.
5.5 The key findings of the context analysis are as follows, which have been translated into subsequent guiding principles that have informed the design of the scheme.
Context Analysis Findings Guiding Principles
The site comprises a finger of vacant scrubland that The site forms a logical and proportionate extension punctuates the existing residential development in to this key settlement given that the land to the the area. south, north and west already fall within the settlement boundary and are developed. As such, the site is suited to a comprehensive residential development. The site is in a sustainable location with good The scheme should seek to promote sustainable access to sustainable transport modes. modes of travel. Parking provision should reflect the variety of sustainable transport modes available.
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The site is partially crossed by a public right of way The public right of way should be realigned to which extends from east-west. ensure the route is not comprised.
The surrounding area is predominantly residential in The scheme should seek to reflect the character of character and form, largely consisting of detached the surrounding area in terms of plot size, scale of dwellings benefitting from front and rear gardens, development (i.e. traditional two storey with respective driveways accessed from cul-de- development with pitched roofs) and the nature of sacs served by the main estate roads. the parking provision (i.e. off-street). The site is located on the edge of, but outside, the The built form in the eastern portion of the site Merthyr Mawr Warren Special Landscape Area should respect the adjacent landscape and (SLA), but falls outside the Merthyr Mawr, Kenfig & heritage assets. Margam Burrows (Cadw reference HLW(MGI)1), which is a Registered Historic Landscape. There is plentiful informal, formal and incidental The proposed layout should provide areas of open space located within the vicinity, much of incidental and usable open space where possible. which is located to the east of the site and south of Cypress Gardens, including a Council owned playing field.
The hammer-head that terminates Cypress Gardens The access should be taken off Cypress Gardens abuts the site’s boundary. and improved to current standards as part of the scheme’s design.
There is a belt of vegetation and tree cover that The layout proposals should take account of the screens the properties fronting Lime Tree Way. existing tree cover in the area, having regard to their amenity value.
Design Development
5.6 Since the initial proposals for the residential development of the site were put forward at the pre-application meeting held with the Council on 20th May 2020, there have been several important changes made to the scheme. Key changes include:
▪ The dwellings proposed in the eastern portion of the site have been rearranged to improve the outlook within the site and the relationship with the Merthyr Mawr Warren Special Landscape Area.
▪ The layout of the proposals has been revised to exclude development within the portion of the site predicted to constitute either Grade 2 or Grade 3b agricultural land.
▪ The proposed swales have been fenced out of the rear gardens of the proposed dwellings that line the site’s southern boundary.
▪ The number of off-street parking spaces dedicated for the affordable dwellings has been increased.
▪ The realigned public right of way has been marked onto the site layout plan.
▪ The width of the footpath into the site has been increased to a ‘shared-use surface’.
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▪ Minor changes have been made to the access road into the site to ensure the road alignment achieves the required forward visibility.
Design and Access Principles
Character
5.7 As noted in the preceding sections of this statement, the application site is located within a predominantly residential area, characterised by detached dwellings benefitting from front and rear gardens, with respective driveways accessed from cul-de-sacs served by the main estate roads.
5.8 The properties in the area vary in size, style and form, but generally front the highway.
5.9 The application is submitted in outline form with matters of layout, scale, appearance and landscaping all reserved for future consideration. Nevertheless, an illustrative layout supports the application and demonstrates the acceptability of the site’s residential development for up to 20 no. dwellings.
(i) Use & Amount
5.10 The application site area extends to 0.68 hectares and the illustrative site layout demonstrates the site is capable of suitably accommodating up to 20 no. dwellings, comprising a mixture of detached and terraced units.
(ii) Layout
5.11 This is an outline planning application with details of layout reserved for future consideration. However, the application is supported by an illustrative site layout plan that demonstrates how the development of the site could be achieved for the number of dwellings proposed. The following points seek to outline the principles behind the site layout:
▪ The proposed development seeks to reflect the character of the surrounding area, which largely consists of two storey dwellings with front and rear gardens, respective driveways accessed from cul- de-sacs served by the main estate roads.
▪ The proposed layout has sought to incorporate areas of incidental and usable open space where possible.
▪ Private driveways for a small number of dwellings are accessed off the main spine road serving the development.
▪ The proposals account for the existing tree and vegetation cover to the north of the site and seek to retain this.
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(iii) Appearance
5.12 The detailed appearance of the proposed dwellings is not for consideration as part of this outline planning application. However, the guiding design principles for the scheme set out that the proposed dwellings will be of traditional design, being no more than two storeys and will have pitched roofs.
(iv) Scale
5.13 The scale of the proposed development has been reserved for future consideration by the council, although the principles of this have been carefully considered as part of the preparation of the illustrative site layout plan so that the scheme suits the existing character of the surrounding area.
5.14 The surrounding built-form largely consists of two storeys dwellings with pitched roofs. The proposed development scheme follows this pattern of development and will not appear at odds with the existing character of the area or scale of the adjacent buildings.
5.15 Overall, it is considered that the scale and massing of the proposed development will seek to preserve the character and appearance of the area and will not result in undue harm to the adjacent Special Landscape Area (SLA) or the Merthyr Mawr, Kenfig & Margam Burrows. This matter has been assessed and is detailed in the supporting Landscape Visual Impact Assessment.
(v) Landscaping
5.16 The landscaping detail for the scheme has been reserved for future consideration by the council. Nevertheless, an overarching Landscape Strategy has been prepared for the site and supports this planning application. This defines the broad landscaping principles that any future reserved matters application(s) will need to follow and will ensure the scheme is developed in an acceptable manner having regard to visual amenity and the adjacent SLA.
Access & Inclusivity
5.17 Vehicular access to the proposed development will be provided from the south of the site, via a continuation of the Cypress Gardens turning head providing a spine road into the site.
5.18 Pedestrian access for the site would be from Cypress Gardens and also the public footpath linking to both The Burrows and Lime Tree Way.
5.19 Servicing arrangements are discussed in detail as part of the Transport Statement. However, this would be via the proposed vehicular access to the site. Swept path analysis of the site access has been provided and demonstrates the acceptability of this for refuse vehicles and fire tenders.
5.20 Access for all users of the development will be carefully considered as an inherent part of detailed design of the scheme. Level access will need to be provided to ensure inclusivity for pedestrians and wheelchair / buggy users.
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5.21 The definitive line of the public right of way cuts across the northern portion of the site. However, in reality the informal line of the path skirts the site’s boundary and will remain unaffected. In any case, the definitive line of the PROW will need to be amended in due course.
Movement
5.22 Vehicular access to the site will be achieved from Cypress Gardens via an extension of the existing turning head. Pedestrian access is capable of being provided at various points across the site and to ensure permeability.
5.23 The provision of safe and convenient access for vehicles and pedestrians is of paramount importance and has, therefore, been contemplated in the layout of the scheme. Accordingly, connections have been shown to the public right of way that runs to the north of the site and onto Cypress Gardens to the south via a shared-use footpath.
5.24 The surrounding area is immediately accessible by walking, cycling, public transport and the private car; this is explored in more detail in the submitted Transport Statement.
5.25 The Transport Statement submitted confirms that the proposals are acceptable in terms of highway capacity, given the limited number of vehicle movements associated with the proposed development, the capacity of the local highway network and following a capacity analysis of key junctions.
5.26 The proposed spine road into the site will be constructed to adoptable standards and will therefore be capable of accommodating refuse vehicles.
Environmental Sustainability
5.27 The environmental and technical constraints have been fully assessed and accounted for in the design of the scheme.
▪ Landscape / habitat – Soft landscaping will be introduced across the site for visual enhancement; the focus will be on native planting. A Preliminary Ecological Assessment (PEA) has been undertaken and confirms that there is limited existing ecological value on the site itself.
▪ Energy and resource efficiency – It is the intention of the applicant that the proposed development is designed with sustainability as an important consideration. It is the applicant’s intention to encourage the creation of an energy efficient development through a variety of techniques, enhancing the fabric of the proposed dwellings and seeking to utilise energy efficient technologies. It is also the applicant’s intention to utilise a local labour force, where possible, and source building materials locally to avoid importation.
▪ Water and waste management – Refuse collection has been considered and the proposed road in capable of accommodating a refuse vehicle. In terms of foul water management, the existing combined public sewer is located within Cypress Gardens. Foul discharges will be into this diverted public sewer. In terms of surface water management, a combination of permeable paving, the provision of an on-site infiltration/attenuation basin an conveyance swales will be used to control land and surface water drainage. Under the new legislation, namely Schedule 3 of the Flood and
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Water Management Act (FWMA) 2010, a separate Sustainable Drainage System (SuDS) application will of course be submitted to the council as the Sustainable Drainage Approval Body (SAB).
Community Safety
5.28 The development has been designed and orientated to allow natural surveillance of car parking and other communal areas.
5.29 The development site will be simple to navigate given its obvious single vehicular access off Cypress Gardens, which will feed two private driveways, each serving less than the maximum requirement of 5 dwellings.
5.30 There is potential for pedestrian links to the surrounding area, which have been shown on the illustrative layout. Any such links are capable of offering natural surveillance from the proposed dwellings.
5.31 The proposed scheme has been carefully designed, taking into account Section 17 of the Crime and Disorder Act 1998, to provide a safe environment and aid crime prevention.
Response to Planning Policy
5.32 This is addressed in the following section of this statement that covers the key planning issues.
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6. Key Material Considerations
Preface
6.1 The application proposals are compliant with policy provisions at the national and local level and the way this can be achieved is demonstrated by the detail submitted in the application package. This identifies the key development influences that have been taken into account when designing the proposals for the site.
6.2 This assessment demonstrates that the proposals accord with the detailed LDP policy requirements identified in Section 4.0. These include matters of design, transportation, ecology, landscaping and residential and visual amenity.
6.3 As required by Section 38 (6) of the Planning and Compulsory Purchase Act 2004 the application proposals have been assessed against all relevant national and development plan policies and other material considerations, and have been found to be in compliance.
6.4 In this context, we believe the primary issues in this instance to be:
▪ The Principle of Development;
▪ Landscape / Visual / Heritage;
▪ Residential Amenity;
▪ Highway Safety;
▪ Drainage;
▪ Ecology;
▪ Trees;
▪ Site Investigation;
▪ Impact upon the Welsh Language, and
▪ Scio-Economic Impacts.
The Principle of Development
6.5 The application site falls outside the settlement boundary for Newton, but is surrounded by it and the curtilages of existing dwellings to the north, south and west.
6.6 Whilst Policy PLA1 of the LDP directs development of housing to areas within defined settlement limits, Policy ENV1 comprises a criteria-based policy and governs development in countryside locations and states that where development is acceptable in principle in the countryside it should where possible, utilise existing
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buildings and previously developed land and / or have an appropriate scale, form and detail for its context. PPW states that “development in the countryside should be located within and adjoining those settlements where it can best be accommodated in terms of infrastructure, access, habitat and landscape conservation. Infilling or minor extensions to existing settlements may be acceptable, in particular where they meet a local need for affordable housing or it can be demonstrated that the proposal will increase local economic activity.1”
6.7 The application site is located on the edge of the settlement boundary of Newton (surrounded by development on three sides) and would form a logical and proportionate ‘minor’ extension to this key settlement, particularly given that the land to the south, north and west already fall within the settlement boundary and are developed. In addition, the site has excellent accessibility to a variety of transport modes and there are plentiful key services in the immediate vicinity.
6.8 The housing requirement, strategy and settlement boundaries set out in the LDP are based on evidence of housing need which is long out of date. Indeed, the LDP is fast approaching its end date. The Council’s emerging Revised LDP is yet to be placed on deposit and is not expected to be adopted until September 2021. This projected adoption date doesn’t factor-in any potential delay in delivery due to the Covid-19 pandemic.
6.9 The weight to be attached to an emerging LDP does not necessarily increase as it progresses to adoption. The housing requirement, housing trajectory and LDP strategy are yet to be tested at examination. Consequently, there is no certainty that they are sound so have limited weight.
6.10 The changes to PPW and revocation of TAN1 have not reduced the importance of delivering new housing, just the way delivery is planned, measured and monitored. This is a clear indication that the government is committed to ensuring that the planning system delivers the housing Wales needs and that under delivery is a material consideration.
6.11 The Annual Monitor Reports prepared by BCBC to assess the performance of the adopted LDP against the Plan’s objectives clearly demonstrate there is a significant shortfall of housing provision within the County Borough. It is evident that key housing sites are not being delivered as anticipated, which suggests the need for additional site allocations and windfall sites or, indeed, a change to planning strategy to assist with housing delivery.
6.12 Porthcawl is defined as a Strategic Regeneration Growth Area (SRGA) in the adopted LDP. As such, it has a clear strategic role to play within Bridgend and the wider region. One of the area’s key roles is residential provision. Accordingly, the application site represents a suitable and realistic windfall housing site. It is on this basis the residential development of the site is considered to be acceptable.
Landscape / Visual / Heritage
6.13 There are no listed buildings in the vicinity of the site, although Merthyr Mawr Warren is designated as a Scheduled Ancient Monument (SAM) (Cadw reference: GM432). This area consists of the multi-period remains of a large number of archaeological sites, which range from prehistoric funerary, ritual and domestic
1 Paragraph 3.56 of PPW (Edition 10)
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remains through to medieval/post-medieval deserted settlement. As a result, Newton Burrows and Merthyr Mawr Warren are considered to be archaeologically sensitive.
6.14 The site is located on the edge of, but outside, the Merthyr Mawr Warren Special Landscape Area (SLA) and Merthyr Mawr, Kenfig & Margam Burrows (Cadw reference HLW(MGI)1), which is a Registered Historic Landscape.
6.15 In terms of the historic landscape, LANDMAP classifies the area as being important for its rural environment and system of sand dunes (Level 4); the recommendation being to maintain the integrity of the buried historical and archaeological landscape.
6.16 From a visual and sensory perspective, LANDMAP designates the area as lowland coastal dunes (Level 3), including broad views out to the wider landscape. The description of the landscape aspect area notes the recent housing development to the western edge has somewhat reduced the aspect area.
6.17 The application site was designated in the historic Ogwr Borough Local Plan and Unitary Development Plan as green wedge, although this designation has since been omitted and the site’s protection downgraded.
6.18 Adopted LDP Policy ENV3 supports development proposals that enhance or improve the Special Landscape Areas through their design, appearance and landscape schemes. Whilst this policy does not intend to necessarily preclude development, it is intended to reflect the emphasis placed upon the term ‘special’ in their definition. As such, the design of developments should be sensitive enough to ensure that the scheme makes a positive contribution to the landscape and that the development of the site will not harm the special features of the SLA.
6.19 A Landscape Character and Visual Impact Assessment (LCVIA) has been prepared by TDA to assess the general visual and landscape character impacts the proposed development will have upon the surrounding landscape. The LCVIA is submitted in support of this application and concludes that the site can accommodate the proposed residential development without unacceptable landscape character or visual amenity impacts upon its immediate setting or the wider landscape.
6.20 Having regard to the LANDMAP classifications, the site forms a logical extension to the existing settlement given that it shares three boundaries with existing development (formerly allocated for housing purposes) that represents a rounding off exercise. The proposed development will create a defined barrier to avoid erosion into the Merthyr Mawr Warren and would be viewed in the context of existing development in the area.
6.21 The illustrative scheme has been designed to avoid undue harm to the visual amenity of the area to ensure the transition between the settlement’s edge and the nearby features of acknowledged heritage and landscape importance is softened. Moreover, the scale and form of the proposed dwellings reflect the character of the neighbouring dwellings, whilst respecting the site’s “edge of settlement” location.
6.22 Overall, the residential development of the site would not have an unacceptable impact upon the character and appearance of the area or upon the setting of the neighbouring Registered Historic Landscape or the Merthyr Mawr Warren Special Landscape Area.
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Residential Amenity
6.23 In terms of residential amenity, the proposed illustrative layout would not result in harm to the amenity of neighbouring occupiers or the occupiers of the proposed units given the separation distances and the levels on the site.
6.24 Amenity areas for the future occupants of the dwellings would be provided within the confines of the site by way of private gardens.
6.25 In any case, the site is screened by vegetation and mature trees along its northern and eastern boundaries, which will act to soften the development proposals. Significant vegetation and tree cover is being retained as part of the proposals, with only a small number of minor trees being removed and additional landscaping proposed to screen the development from neighbouring properties. A Pre-Development Tree Survey and Assessment has been undertaken and is submitted in support of the application to demonstrate the acceptability of this.
Highway Safety
6.26 In terms of sustainability, the site occupies a sustainable location with good connectivity to a number and range of local facilities. There are good cycling links to nearby settlements and an extensive footpath network, including footway links to the shops in Newton. The site is also within a short walk of bus stops on Lime Tree Way (circa 300m), with further services located on Bridgend Road. In general terms, the site has good access links to Porthcawl and the wider region.
6.27 In terms of access to the site, this is achievable from Cypress Gardens, which benefits from an existing turning head that abuts the site’s southern boundary. The access road is designed as a continuation of Cypress Gardens, which becomes the main access spine road for the proposed site. The access road widths vary from 4.5m at the initial access upon entering the site, in keeping with the existing widths on Cypress Gardens, to 4.8m as it routes northeast into the site. This ensures a smooth transition from the existing road whilst offering some additional space within the site.
6.28 A drawing of the Proposed Site Access General Arrangement & Vertical Design has been prepared by Hydrock, which demonstrates how access can be suitably achieved. This involves some land take from the existing dwelling adjacent to the Cypress Gardens turning head (No. 8) – this property falls within the ownership of the applicant.
6.29 Car parking and cycle parking for the development will be provided on-site in line with the requirements of the council’s Parking Standards SPG.
6.30 In terms of vehicular trip generation and associated impact upon the local highway network, the Transport Statement that supports the application demonstrates that the existing highway network would satisfactorily accommodate the additional traffic arising from the proposed residential development without resulting in any significant impacts. The traffic impact of the scheme is therefore acceptable and in accordance with requirements set out in TAN 18.
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Drainage
6.31 The drainage, water resources and utilities required by the proposed development have been considered as part of the preparation of this planning application.
6.32 A Concept Drainage Strategy has been prepared by Hydrock. This provides an overview of the potential surface water drainage strategy for the site and demonstrates how foul water can be discharged.
6.33 Under the new legislation, namely Schedule 3 of the Flood and Water Management Act (FWMA) 2010, a separate Sustainable Drainage System (SuDS) application will of course be submitted to the Council as the Sustainable Drainage Approval Body (SAB).
6.34 In terms of foul water, there is an existing public foul sewer located adjacent to the turning head of Cypress Gardens. It is proposed that the development could connect at this point.
6.35 Initial investigative work has been undertaken to determine how the surface water run-off from the proposed development could be managed. A concept strategy has been prepared based on the use of Sustainable Drainage Systems (SuDS) integrated with the landscape strategy, to comply with the principles of Schedule 3 of Flood and Water Management Act 2010 and to secure SAB approval. The SuDS strategy comprises a mixture of permeable paving, rain gardens and shallow infiltration, with swales provided behind the rear gardens of the properties to channel surface water into a dedicated infiltration and attenuation basin. This basin would be sized for all storm events up to peak duration of 1:100 year + 30% climate change and could include an overflow into the public sewerage system, although this is unlikely to be required due to the potentially favourable infiltration conditions.
6.36 Based on the initial investigative work undertaken, it is considered that suitable foul and surface drainage solutions are available to serve the proposed development.
Ecology
6.37 The site has no statutory ecological designation and comprises a small part of a coastal dune system that is regularly managed by annual cutting, as acknowledged by the Preliminary Ecological Assessment (PEA) undertaken by Pryce Consultant Ecologists in February 2020. This follows prior ecological survey work carried out in October 2010 (issued in February 2011) and 2004.
6.38 The 2020 PEA has an extended survey area which covers the application site and the land to the north, on the opposite side of the public right of way. The 2020 PEA describes the site as being clothed in rank grassland, bracken and scrub, divided by an existing footpath. The assessment also states that the results of the 2004 and 2010 surveys indicate there have been no gross changes in the habitats and vegetation types located within the site.
6.39 Whilst the site is said to be largely scrub and grassland, it is acknowledged there will be a need to remove or manage some vegetation to facilitate the site’s future development. It is also noted that the coastal zone (Merthyr Mawr Warren) to the south and east is designated as a Site of Special Scientific Interest (SSSI), a
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Special Area of Conservation (SAC) and a Site of Importance for Nature Conservation (SINC), although the site does not form part of these designations, nor does it form part of the Glamorgan Heritage Coast.
6.40 The appraisal concludes that the development of the site is not likely to pose a direct impact on the adjacent statutory ecological designations and is either not suitable to support or there was no evidence of European or UK protected species. Whilst there will be a loss of a vegetation buffer with the SSSI, this will be marginal. Provided the corridor of semi-mature trees and scrub is maintained along the northern boundary as a habitat corridor then potential features of acknowledged ecological importance will be suitably safeguarded.
6.41 To protect UK Biodiversity Action Plan (BAP) habitats and the coastal sand dunes, the PEA recommends that a habitat corridor is maintained along the northern margin of the site, requiring retention and enhancement of vegetation and tree cover. This application site boundary has been drawn to the south of this area to maintain a suitable habitat corridor.
6.42 In terms of protected species, there was no evidence of badgers, reptiles or birds. The site was also considered unsuitable to support dormice, water vole, otter, marsh fritillary butterfly, or other protected fauna. There are no water bodies on the site to support amphibians and the habitat is unsuitable for such species. There was also limited potential for bats. The PEA found that Hedgehogs may be present, but the development of the site to include gardens will diversify their habitat and be of benefit.
6.43 In terms of ecological mitigation, in addition to the retention of a habitat corridor along the site’s northern margin, the PEA recommends the development scheme should include bird nesting boxes and suitably sized apertures at the base of fences and walls to allow free movement of Hedgehogs. It is also recommended the measures are taken to protect existing plants (particularly Bluebells) adjacent to the site’s boundaries. Finally, Japanese Knotweed has been identified in the northern portion of the site (outside the development area – TN06). This will need to be treated and managed accordingly.
Trees
6.44 There is minimal tree cover on the site and there are no Tree Preservation Orders (TPOs) in the immediate vicinity. Nevertheless, a Pre-Development Tree Survey & Assessment and a Tree Constraints Plan for the site and its immediate surroundings have been prepared by TDA.
6.45 TDA surveyed 8 no. individual trees (T6 – T13), 1 no. tree group (containing 5 no. trees) (G1) and 1 no. woodland (W1). The outcome of this survey is as follows:
▪ Category A – 1 no. tree (T9) and 1 no. tree group (G1)
▪ Category B – 1 no. trees (T10) and 1 no. woodland (W1)
▪ Category C – 6 no. trees (T6, T7, T8, T11, T12 & T13)
6.46 The Tree Survey concludes there are no trees of particular note on the site, although G1, W1 and T8-10 (all located to the north of the application site) provide screening to views from the north, so are recommended
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to be retained. Accordingly, the proposed development has been designed to ensure these trees can be retained.
6.47 On the site there are 5 no. individual trees (T6, T7, T11, T12 & T13) and a group of young Hawthorn, Blackthorn and Bramble. These trees are deemed to fall within Category C (i.e. low quality and value) and are proposed to be removed. There is plentiful space for the provision of replacement tree planting within the common areas or in frontage locations. Further details of this are providing in the Landscape Strategy that supports this application.
Site Investigation
6.48 The site comprises vacant and undeveloped scrubland. Nevertheless, a Phase 1 Ground Conditions Desk Study has been prepared by Hydrock to identify key geo-environmental and geo-technical risks to the proposed development.
6.49 The report identifies that there was a landfill site operational between 1956 and 1975 20m south of the site, with the boundary of the landfill shown to potentially partially encroach on the southeast corner of the site. Despite this, the report concludes that it is unlikely the site would be classified as contaminated land and the risk of contamination is low. Overall, the risk of developing houses on the site is moderate, but this would need to be confirmed by appropriate intrusive investigation, testing and assessment of the results of the investigation. As such, matters related to ground contamination are not insurmountable.
Impact upon the Welsh Language
6.50 TAN 20 (Planning and the Welsh Language) seeks to safeguard and promote the interests of the Welsh language through development proposals and states that:
“In determining individual planning applications and appeals where the needs and interests of the Welsh language may be a material consideration decisions must, as with all other planning applications, be based on planning grounds only and be reasonable.” (Paragraph 4.1.2, Page 14, TAN 20).
6.51 In accordance with this policy context, the impact of the proposal on linguistic character of the surrounding area is a material consideration. The development proposal will provide up to 20 no. new open market and general needs affordable homes in an area where there is a substantial undersupply of housing to meet local needs. The provision of new homes will, therefore, enable Welsh speakers to remain in the area. As such, the proposal will not have a detrimental impact upon the needs and intensity of the Welsh language.
Scio-Economic Impacts
6.52 The proposed development will deliver significant benefits to Bridgend, not just in terms of housing numbers, but in terms of economic development and community benefits. Obstructing developments such as these is clearly not the intention of the Welsh Government or the Council through PPW or the LDP.
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6.53 It is also important to consider the economic benefits that the residential development of the site will have at the construction stage and upon the occupation of the proposed dwellings. Such matters are supported by Technical Advice Note 23 (Economic Development). The construction phase will generate jobs and inject expenditure into the local economy, also providing subsidiary income for other businesses (i.e. suppliers, professional services, retailers etc.). Upon occupation of the proposed dwellings there will be continued income generation for the local economy from resident expenditure on commodities, and in local amenities and services.
Date: August 2020 Page: 33 Client: C.H Knight & Partners Report Title: Planning, Design & Access Statement
7. Summary
7.1 This Planning, Design and Access Statement has been prepared to accompany and support an outline planning application for the residential development of the vacant scrubland located to the north and east of Cypress Gardens in Newton.
7.2 The proposals to develop the site for residential purposes constitute an efficient use of this vacant scrubland and will deliver a sustainable form of development, representing a logical extension of (or rounding off of) an established and well served key settlement and will deliver economic, social and a range of community benefits.
7.3 The supply of land for housing and the delivery of new homes is a serious challenge in the County Borough. The opportunity the proposals provide to contribute to the supply of land for housing simply has to be taken since it has been demonstrated the scheme will not result in harm to the character of the area, will provide a host of economic benefits and complies with national policies and the local policies of the adopted Development Plan.
7.4 The proposals will provide a suitable level of residential amenity for future occupiers, will not result in any detrimental harm to the residential amenity of neighbouring occupiers or visual amenity of the area, and neither would they harm matters of highway safety, heritage or ecology.
7.5 In the lead up to this submission, engagement has been undertaken with site stakeholders, the local community and the council to explain the merits of the proposal. This demonstrates the on-going commitment to respond to the economic, social, environmental and cultural necessities of the area. This is to, ultimately, deliver a sustainable development which is in-keeping with the local context and in line with the Well-being of Future Generations goals, the placemaking outcomes of PPW10 and the local requirements set out by the Local Development Plan.
7.6 Overall, we conclude that the principle of developing the site for residential purposes, with access from Cypress Gardens, is acceptable and no harmful impact will arise. As such, we respectfully request that outline planning permission is granted.
Date: August 2020 Page: 34
Site Location Plan
Detail drawings and large scale Figured dimensions and levels to be used. take precedence over smaller drawings. architect. Any inaccuracies must be notified to the This drawing must not be scaled. Registered Office: Powell Dobson, Suite 1F, Building One, Eastern Business Park, Wern Fawr Lane, Old St. Mellons, Cardiff CF3 5EA. Dobson is a trading name of Ltd company registered in England and Wales No 3873802. THIS DRAWING IS COPYRIGHT ©
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Indicative Site Layout Plan
Detail drawings and large scale Figured dimensions and levels to be used. take precedence over smaller drawings. architect. Any inaccuracies must be notified to the This drawing must not be scaled. Registered Office: Powell Dobson, Suite 1F, Building One, Eastern Business Park, Wern Fawr Lane, Old St. Mellons, Cardiff CF3 5EA. Dobson is a trading name of Ltd company registered in England and Wales No 3873802. THIS DRAWING IS COPYRIGHT © 6 2
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KEY PLAN NOTES NOTES (CONTINUED) REVISIONS (CONTINUED) REVISIONS FIRST FLOOR,CASTLEBRIDGE 5 TITLE 5-19 COWBRIDGE ROAD EAST CARDIFF PROPOSED SITE ACCESS AND VISIBILITY CF11 9AB t: +44 (0) 2920 023665 SPLAY PLAN e: [email protected]
CLIENT CYPRESS GARDENS LOCKE PROPERTY HYDROCK PROJECT NO. SCALE @ A3 C-11884 1:250 PROJECT STATUS DESCRIPTION STATUS P01 31/07/2020 First Issue. GP NB NB LAND TO THE NORTH & EAST OF CYPRESS FOR STAGE APPROVAL S4 GARDENS, BRIDGEND DRAWING NO. (PROJECT CODE-ORGINATOR-ZONE-LEVEL-TYPE-ROLE-NUMBER) REVISION Rev Date Description By Ckd App 11884-HYD-XX-XX-DR-TP-0201 P01 F:\01 Contracts\C-0000-C\C-11884 - Land to the North & East of Cypress Gardens, Bridgend\01_WIP\DR_Drawing\TP\0200 General Arrangement Design\11884-HYD-XX-XX-DR-TP-0201-P01.01-S2.dwg, 31/07/2020 15:30:46, DWG To PDF.pc3
Candidate Site Representation to BCBC’s Revised Local Development Plan (2018-2033)
Bridgend County Borough Council Revised Local Development Plan – Invitation to Submit Candidate Sites Land to the North & East of Cypress Gardens, Newton, Porthcawl, Bridgend, CF36 5BZ
November 2018
GVA Client: Tythegston Millennium Trust Report Title: LDP Representation – Candidate Sites
Contents
1. Preface ...... 3 2. Site Context ...... 4 3. Background ...... 6 4. Site Assessment ...... 10 5. Conclusion ...... 15
Appendices
Appendix I Site Location Plan Appendix II Indicative Site Layout Plan Appendix III Ecological Assessment
Figures
Figure 1 Site Location Plan
Figure 2 Extract from Adopted LDP Proposals Map
Status: Final Draft Date: 08 November 2018
For and on behalf of GVA Grimley Limited
Date: November 2018 Page: 2 Client: Tythegston Millennium Trust Report Title: LDP Representation – Candidate Sites
1. Preface
1.1 This representation has been prepared by GVA, on behalf of Tythegston Millennium Trust, as part of the consultation exercise being carried out by Bridgend County Borough Council (BCBC) in respect of the invitation to submit candidate site details to inform the preparation of the Revised Bridgend Local Development Plan (RLDP) (2018 – 2033).
1.2 This representation is made in respect of land to the north and east of Cypress Gardens in Newton, Porthcawl, Bridgend.
1.3 The land subject to this representation falls within the ownership of Tythegston Millennium Trust.
1.4 We understand that the RLDP will identify specific sites to deliver housing and other major development needs, such as employment and retail, in Bridgend up to 2033. This stage in the preparation of the RLDP invites developers, landowners, and other interested parties to submit details of potential sites for development or reuse.
1.5 The site presents a significant opportunity to deliver sustainable, high quality residential development on an area of infill land surrounded on three sides by an existing well-established residential settlement.
1.6 Further details of the proposed candidate site are clearly set out in the completed Candidate Site Assessment Questionnaire that accompanies this statement, together with a plan indicating the extent and make-up of the site itself.
1.7 This statement has been prepared having regard to the Candidate Site Assessment Questionnaire Guidance Note, which provides support to promoters of land and other interested parties on the information required as part of the candidate site process.
Date: November 2018 Page: 3 Client: Tythegston Millennium Trust Report Title: LDP Representation – Candidate Sites
2. Site Context
2.1 The subject site (as shown in Figure 1 below and at Appendix I) extends to 1.36 hectares (3.3 acres) and is situated to the north and east of Cypress Gardens, which is located in Newton, on the eastern side of Porthcawl.
2.2 The site comprises unused land that is well suited for residential development, immediately bounding Cypress Gardens to the south and the rear gardens of those properties that front Lime Tree Way to the north. To the east is open land that extends along the coastline towards Candleston Castle.
2.3 The surrounding area is predominantly residential in character and form, largely consisting of detached dwellings benefitting from front and rear gardens, with respective driveways accessed from cul-de-sacs served by the main estate roads.
Figure 1: Site Location Plan
Date: November 2018 Page: 4 Client: Tythegston Millennium Trust Report Title: LDP Representation – Candidate Sites
2.4 There is plentiful informal, formal and incidental open space located within the vicinity, much of which is located to the east of the site and south of Cypress Gardens (including a Council owned playing field for which the Council’s Estates Department submitted a representation to the emerging LDP for its inclusion in the settlement boundary).
2.5 Newton benefits from a range of existing facilities including plentiful open space, a children’s equipped play area, a day school, football pitches, tennis courts, churches and numerous public houses.
2.6 The subject site is positioned on the eastern edge of Newton in close proximity to the route of the Wales Coast Path, overlooking Merthyr Mawr Warren and Newton Burrows. The village of Newton dates from the 12th Century, although there has been significant residential development in more recent years taking advantage of the good access links offered by the A4106 (Bridgend Road).
2.7 Beyond Newton, to the west, lies Porthcawl ((identified in the adopted LDP as one of the four strategic growth areas in the County Borough). The proposed candidate site is about 1.5 miles from Porthcawl town centre and the retail, employment and community facilities offered there. The town also benefits from a significant historic and natural amenity resource.
2.8 Access to the site can be achieved from Cypress Gardens, which benefits from an existing turning head that abuts the site’s southern boundary. It is envisaged that a private drive could extend north from this turning head, providing an extension to the cul-de-sac. The site has good access links to Porthcawl and the wider region.
Date: November 2018 Page: 5 Client: Tythegston Millennium Trust Report Title: LDP Representation – Candidate Sites
3. Background
Existing Planning Policy Context
3.1 Figure 2 (below) shows the extent of the settlement boundary for Newton, edged in purple, as defined by the proposals map that accompanies the adopted LDP. Whilst the site is located outside the settlement boundary, it is surrounded by it and the curtilages of existing dwellings to the north, south and west.
Figure 2: Extract From Adopted LDP Proposals Map
3.2 The site is located on the edge of, but within, the Merthyr Mawr Warren Special Landscape Area (SLA) and falls partly within the Merthyr Mawr, Kenfig & Margam Burrows (Cadw reference HLW(MGI)1), which is a Registered Historic Landscape.
3.3 The site is also located within a limestone resource safeguarding area.
3.4 Given the nearby presence of Newton Burrows and Merthyr Mawr Warren, the site is considered to be archaeologically sensitive. Whilst there are no listed buildings in the vicinity of the site, Merthyr Mawr Warren is designated as a Scheduled Ancient Monument (SAM) (Cadw reference: GM432). This area consists of the multi-period remains of a large number of archaeological sites, which range from prehistoric funerary, ritual and domestic remains through to medieval/post-medieval deserted settlement.
3.5 The site is not subject to a statutory ecological designation. The coastal zone (Merthyr Mawr Warren) to the south and east is designated as a Site of Special Scientific Interest (SSSI), a Special Area of Conservation (SAC) and a Site of Importance for Nature Conservation (SINC), although the site does not form part of these designations, nor does it form part of the Glamorgan Heritage Coast.
Date: November 2018 Page: 6 Client: Tythegston Millennium Trust Report Title: LDP Representation – Candidate Sites
3.6 A Public Right of Way (PROW) runs across the site in an east to west direction. This can be accounted for as part of any future development of the site.
3.7 According to the Development Advice Map, accompanying Technical Advice Note 15 (Development and Flood Risk), the site is not located within an area of known flood risk.
Planning History
3.8 The most pertinent planning history applicable to the site relates to the submission of two previous planning applications for the residential development of the site, as follows:
Ref: Applicant Proposal Decision
Full planning application for residential Tythegston development – 12 no. detached dwellings, new P/04/1726/FUL Millennium Refused 29/03/2005 access onto Cypress Gardens and associated Trust landscaping.
Outline planning application for residential C.H. Knight & P/99/426/OUT development - 4 no. detached dwellings Refused 06/07/1999 Partners
(N.B. the above is based on a desktop inspection of available information on Bridgend County Borough Council’s website)
3.9 We understand the 2004 planning application (LPA reference P/04/1726/FUL) was partly refused on the basis of highway safety in connection with the limited carriageway width. The Council’s Highway Engineers suggested that a reduced form of development may be given sympathetic considerations as the associated traffic movements are unlikely to generate significant adverse effects on the local highway network.
3.10 In addition, we note that a representation was made for the site’s development for residential purposes (LDP Candidate Site reference 792.B1) to the candidate site consultation stage of the emerging LDP.
3.11 A representation was also submitted to the Deposit LDP objecting to the Plan Strategy, the Proposal Map and Strategic Policies SP1, PLA1, ENV3 and COM2. This representation objected to the Plan on the basis the site should not be excluded from the proposed settlement boundary, should not be included in the SLA and that it was not identified as a residential land allocation.
3.12 We note the Inspector of the Unitary Development Plan (UDP) accepted the site would represent a logical rounding off of development, that the protective designations should be removed and the site included in the settlement boundary. However, the ‘Alternative Sites Consultation Report’ for the LDP failed to support the allocation of the site (LDP Alternative Site reference AS007) or the extension of the settlement boundary, regardless of acknowledging the site being located within a Strategic Regeneration Growth Area (SRGA) and adjoining settlement limits.
3.13 For ease of reference, we have included the UDP Inspector’s comments below:
“… An illustrative plan was submitted with the objection showing how four dwellings might be accommodated on the site. A proposal for development on these lines could,
Date: November 2018 Page: 7 Client: Tythegston Millennium Trust Report Title: LDP Representation – Candidate Sites
in my opinion, be considered on its merits under Policy H3, which permits small scale infilling and rounding off in main settlements including Porthcawl. However, I conclude that there is no reason to allocate it under Policy H1 of the UDP.”
3.14 The Inspector further stated that:
“The objectors (CE Knight & Partners) argue that the objection site, which is located within the coastal zone, is surrounded on three sides by housing development and is inappropriately included within the coastal zone. I accept that it is important to protect the unspoilt beauty and character of the coastline, but I consider this site to be almost enclosed by residential development and different in character from the open land immediately to the east. The site is outside the Heritage Coast, Merthyr Mawr SSSI and the proposed Newton Burrows Local Nature Reserve….”
3.15 These comments clearly remain pertinent to the consideration of this site and support the allocation of the site or, indeed, the extension of the settlement boundary to include it.
Rationale for Housing Allocation
3.16 The 2018 Joint Housing Land Availability Study (JHLAS) for Bridgend is the fifth assessment of the County Borough’s housing land supply since the adoption of the LDP in September 2013. It is also the second successive assessment demonstrating that Bridgend has a housing land supply for the Plan area below the 5 year requirement identified within Technical Advice Note (TAN) 1 (the 2017 JHLAS identified a 4.0 year supply, whilst the 2018 JHLAS identified a 3.4 year supply). This is reflected in Annual Monitor Reports (AMRs) which have been published to date.
3.17 BCBC is required to commence a full review of the LDP every four years, the process for which has recently commenced. This will assist in meeting the 2021 deadline for having an adopted revised LDP in place to avoid having a local policy vacuum that the new Regulations threaten to create. At present, the LDP period will cease on 31st December 2021; meaning a revised LDP will need to be in place by 1st January 2022.
3.18 TAN 1 states that where a shortfall in the housing land supply is identified, the LPA, in its AMR, should consider the reasons for the shortfall and whether the LDP should be reviewed either in whole, or in part. The LDP has been monitored on an annual basis with the publication of 3 AMRs. The AMR assesses the extent to which the LDP’s strategy, policies and allocations are being delivered and how effective it has been in delivering the Plan’s overall vision and objectives.
3.19 In terms of housing delivery to-date, a total of 324 new dwelling completions (general market and affordable) were recorded between 1st April 2017 and 31st March 2018. Cumulatively, there has been a total of 1,730 dwelling completions recorded since the Plan’s adoption (i.e. 18th September 2013). This is significantly below the annual need of 1,123 dwellings and the total housing requirement of 9,690 dwellings over the Plan period (2011 – 2021), as identified by the LDP. Put simply, there is a shortfall of 4,322 dwellings. It is evident that key housing sites are not being delivered as anticipated, which suggests the need for additional site allocations or, indeed, a change to planning strategy to assist with housing delivery.
Date: November 2018 Page: 8 Client: Tythegston Millennium Trust Report Title: LDP Representation – Candidate Sites
3.20 The LPA has identified a clear issue needing to be addressed in respect of the lack of a five year housing land supply and the need for new sites to come forward to allow for the Plan to better reflect and deliver the required housing requirements through to 2033.
3.21 The LDP Review Report was published in June 2018, with a recommendation agreed by Members that a ‘full’ review of the LDP should be undertaken. The Review identified that consideration would be given to adopted spatial strategy to determine whether it remains ‘fit for purpose’ and it will be necessary to allocate additional sites.
3.22 The need for a full revision of the LDP is, therefore, essential given the necessity to review housing supply to ensure that it is sufficient and reflective of the amended growth requirements evidence.
3.23 The proposed candidate site is surrounded on three sides by the settlement boundary and forms part of the SRGA. It is not within open countryside and is close to an established settlement; being on the urban fringe, opposite existing and proposed dwellings, served by existing infrastructure associated with the surrounding housing development and can be integrated easily into the neighbouring built up area. The site, therefore, presents a sustainable, realistic and deliverable opportunity to provide much-needed new homes in Bridgend. It is on this basis this representation has been prepared.
3.24 An indicative site layout plan has been included at Appendix II.
Date: November 2018 Page: 9 Client: Tythegston Millennium Trust Report Title: LDP Representation – Candidate Sites
4. Site Assessment
Principle of Residential Development
4.1 Porthcawl is defined as a Strategic Regeneration Growth Area in the adopted LDP. As such, it has a clear strategic role to play within Bridgend and the wider region. One of the area’s key roles is residential provision.
4.2 The site is located on the edge of the settlement boundary of Newton (surrounded by development on three sides) and would form a logical and proportionate extension to this key settlement. The minor alteration of the settlement boundary, to include the subject site, or indeed the allocation of the site, would represent a logical rounding off of the develop limits, particularly given that the land to the immediate south, north and west already fall within the settlement boundary.
4.3 The site also has excellent accessibility to a variety of transport modes and there are plentiful key services in the immediate vicinity. It is on this basis the site is being promoted for inclusion as a housing allocation in the RLDP.
4.4 These key material planning considerations associated with the residential development of the subject site are discussed below.
Highway Safety & Rights of Way
4.5 In terms of sustainability, the site occupies a sustainable location with good connectivity to a number and range of local facilities. There are good cycling links to nearby settlements and an extensive footpath network, including footway links to the shops in Newton. The site is also within a short walk of bus stops on Clevis Hill (circa 550m), with further services located on Bridgend Road.
4.6 In terms of access to the site, this is achievable from Cypress Gardens, which benefits from an existing turning head that abuts the site’s southern boundary. It is envisaged that a private drive could extend north from this turning head, providing an extension to the cul-de-sac. In general terms, the site has good access links to Porthcawl and the wider region.
4.7 The site is divided by a Public Right of Way (PROW) that runs in an east to west direction. It is envisaged any future development proposals can be suitably designed to accommodate this existing PROW.
Ecology
4.8 The site has no statutory ecological designation and comprises a small unmanaged area of coastal dune- land, as acknowledged by the Ecological Assessment undertaken in October 2010 (issued in February 2011) by Pryce Consultant Ecologists (included at Appendix III). This follows prior ecological survey work carried out in 2004.
4.9 The 2010 Ecological Assessment describes the site as being clothed in scrub to the north and bracken and rank grassland to the south, divided by an existing footpath. The assessment also states that the results of the 2004 and 2010 surveys indicate there have been no gross changes in the habitats and vegetation types
Date: November 2018 Page: 10 Client: Tythegston Millennium Trust Report Title: LDP Representation – Candidate Sites
located within the site. The view is therefore taken that these are unlikely to have altered significantly since the 2010 survey.
4.10 Whilst the site is said to be largely scrub and grassland, it is acknowledged there will be a need to remove or manage some vegetation to facilitate future development. We also note the coastal zone (Merthyr Mawr Warren) to the south and east is designated as a Site of Special Scientific Interest (SSSI), a Special Area of Conservation (SAC) and a Site of Importance for Nature Conservation (SINC), although the site does not form part of these designations, nor does it form part of the Glamorgan Heritage Coast.
4.11 The 2010 Ecological Assessment concluded the development of the site would not be likely to pose any direct impacts to the SSSI, with the loss of the habitat within the site resulting in limited erosion of margin features; the impact to neighbouring statutory sites being classified as ‘minor adverse (minimal magnitude at national level’.
4.12 To protect UK Biodiversity Action Plan (BAP) habitats, the 2010 assessment concluded a habitat corridor should be maintained along the northern margin of the site, requiring retention and enhancement of vegetation and tree cover. This is achievable.
4.13 No evidence of badgers, reptiles or amphibians was found. The site was also considered unsuitable to support dormice, water vole, marsh fritillary butterfly, or other protected fauna. There was also limited potential for bats, although some bird species were present in small numbers and could be suitably mitigated.
4.14 A Preliminary Ecological Appraisal is likely to be required to inform any such works, which can be undertaken at the appropriate time, together with any Phase II work, to inform the proposals and provide details of any necessary mitigation (if required).
Residential Amenity
4.15 The immediate site context is wholly residential in nature and form. As such, the introduction of further residential dwellings will be sympathetic to the character of the area.
4.16 The closest residential dwellings to the site are those located opposite the site fronting onto Cypress Gardens, The Burrows and Lime Tree Way.
4.17 The adequate siting, design and scale of future development on the site can be achieved without having an unacceptable impact on existing or future residential amenity.
Visual Amenity & Heritage
4.18 There are no listed buildings in the vicinity of the site, although Merthyr Mawr Warren is designated as a Scheduled Ancient Monument (SAM) (Cadw reference: GM432). This area consists of the multi-period remains of a large number of archaeological sites, which range from prehistoric funerary, ritual and domestic remains through to medieval/post-medieval deserted settlement. As a result, Newton Burrows and Merthyr Mawr Warren are considered to be archaeologically sensitive.
Date: November 2018 Page: 11 Client: Tythegston Millennium Trust Report Title: LDP Representation – Candidate Sites
4.19 The site is located on the edge of, but within, the Merthyr Mawr Warren Special Landscape Area (SLA) and falls partly within the Merthyr Mawr, Kenfig & Margam Burrows (Cadw reference HLW(MGI)1), which is a Registered Historic Landscape.
4.20 In terms of the historic landscape, LANDMAP classifies the area as being important for its rural environment and system of sand dunes (Level 4); the recommendation being to maintain the integrity of the buried historical and archaeological landscape.
4.21 From a visual and sensory perspective, LANDMAP designates the area as lowland coastal dunes (Level 3), including broad views out to the wider landscape. The description of the landscape aspect area notes the recent housing development to the western edge has somewhat reduced the aspect area.
4.22 The subject site was designated in the historic Ogwr Borough Local Plan and Unitary Development Plan as green wedge, although this designation has since been omitted and the site’s protection downgraded.
4.23 Adopted LDP Policy ENV3 supports development proposals that enhance or improve the Special Landscape Areas through their design, appearance and landscape schemes. Whilst this policy does not intend to necessarily preclude development, it is intended to reflect the emphasis placed upon the term ‘special’ in their definition. As such, the design of developments should be sensitive enough to ensure that the scheme makes a positive contribution to the landscape and that the development of the site will not harm the special features of the SLA.
4.24 Having regard to the LANDMAP classifications, the site would be viewed as an extension to the existing settlement given that it shares three boundaries with existing development (formerly allocated for housing purposes). As such, the inclusion of the subject site as a residential allocation, or simply via an extension to the settlement boundary in the RLDP, would represent a logical rounding off exercise. This would create a defined barrier to avoid erosion into the Merthyr Mawr Warren and would be viewed in the context of existing development in the area.
4.25 The site’s residential development is capable of being designed to avoid undue harm to the visual amenity of the area to ensure the transition between the settlement’s edge and the nearby features of acknowledged heritage and landscape importance is softened. Moreover, the future residential plots could be designed to reflect the character of the neighbouring dwellings, whilst respecting the site’s “edge of settlement” location. An indicative site layout plan is included at Appendix II for illustrative purposes.
4.26 Overall, the residential development of the site would not have an unacceptable impact upon the character and appearance of the area or upon the setting of the Registered Historic Landscape or the Merthyr Mawr Warren Special Landscape Area.
Drainage
4.27 The drainage, water resources and utilities required by the future development of the site have been considered as part of this representation.
4.28 In terms of foul water effluent, this will be able to connect to the public system located in the adjacent highway (Cypress Gardens). Dwr Cymru Welsh Water issued its consultation response as part of the site’s
Date: November 2018 Page: 12 Client: Tythegston Millennium Trust Report Title: LDP Representation – Candidate Sites
consideration for residential purposes in the adopted LDP. This response stated that… “no problems are envisaged with the provision of water supply and discharge of foul drainage from this site.”As such, capacity will be available to serve the future development of the site.
4.29 In terms of surface water, a selection of discharge methods are available for the site. These follow the criteria set out by the Environment Agency / Natural Resources Wales and Building Regulations. Approved Document Part H of the Building Regulations establishes a hierarchy for surface water disposal. The most sustainable method is by infiltration, which most closely mimics the pre-development characteristics of a greenfield site. If that is not feasible, then discharge to a watercourse will be employed as the means of disposal.
Welsh Language
4.30 Technical Advice Note 20 (Planning and the Welsh Language) seeks to safeguard and promote the interests of the Welsh language through development proposals.
4.31 In accordance with this policy context, the impact of the proposal on linguistic character of the surrounding area is a material consideration. A residential use of the site will provide further residential dwellings that will contribute to the prosperity of the area as a whole. The provision of housing on the site will provide further opportunities for young Welsh speakers to remain in the area. As such, the proposal will contribute to the maintenance or enhancement of the Welsh language.
Socio-Economic Benefits
4.32 The site’s development for housing has the potential to deliver significant benefits to Bridgend, not just in terms of housing numbers, but in terms of economic development and community benefits.
4.33 The importance of the provision of housing to meet local needs and to encourage regeneration and economic growth is key to prosperity and has been reinforced as an overarching objective of the WG.
Deliverability
4.34 One of the key objectives of the LDP preparation process is to ensure that sites allocated for development represent viable and deliverable development opportunities. This is particularly the case for residential development to ensure that the housing requirements of the RLDP can be met.
4.35 The Candidate Site Assessment Questionnaire Guidance Note states that for residential candidate sites, the minimum threshold is 10 dwellings or a minimum site size of 0.25 hectares. Notwithstanding this, smaller residential candidate sites will be accepted where a revision of the settlement boundary will be required.
4.36 Whilst larger sites are generally subject to housing allocations, planning policy allows for a proportion of the housing land requirement to be met from windfall sites. These are sites which are not allocated in the LDP, perhaps because of their smaller size, or because they become available for development unexpectedly during the life of the Plan. Windfall sites have historically made a significant contribution to the supply of housing in Bridgend.
Date: November 2018 Page: 13 Client: Tythegston Millennium Trust Report Title: LDP Representation – Candidate Sites
4.37 Whether this site is subject to a housing allocation or simply included within the settlement boundary by making a minor ‘rounding off’ alteration to the development limits, it would assist with offering additional flexibility in the supply, which would help to increase range and choice. Such sites make a regular and reliable source of housing land supply and one which would make an essential contribution to the supply of housing in the area.
4.38 Following the anticipated adoption of the RLDP in 2021, it is expected the development would commence in 2022 and be fully built-out by 2023. This is subject to the preparation, submission and timely determination of a planning application for the subject site’s development. Therefore, it is anticipated the subject site could deliver the housing provision earmarked for this site in the first part of the Plan period.
Date: November 2018 Page: 14 Client: Tythegston Millennium Trust Report Title: LDP Representation – Candidate Sites
5. Conclusion
5.1 The evidence prepared and submitted as part of this representation for the residential development of land north of Cypress Gardens demonstrates the site has the potential to deliver a viable housing scheme in an established settlement.
5.2 The development of the site forms a logical extension of the settlement and is considered to be suitable for housing development given that it is not subject to physical constraints and is capable of being delivered within the Plan period. In fact, the Unitary Development Plan Inspector accepted the site should be included in the settlement boundary, which followed the submission of a candidate site representation to that historic plan. Moreover, there is clearly an impetus by the LPA to develop further housing in this location; demonstrated by the area’s location in a SRGA as identified by the adopted LDP.
5.3 In light of the above, the development of the site for wholly residential purposes will make best and most effective use of vacant scrub land, in a sustainable edge of settlement location, that will constitute a logical extension to (or rounding off of) an established and well served key settlement and will deliver economic, social and a range of community benefits.
5.4 These considerations provide clear and material justification for the site’s allocation in the RLDP for housing development, which will contribute to the performance of the emerging RLDP by providing a genuinely sustainable residential development opportunity.
Date: November 2018 Page: 15
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