City of Cardiff Council Letting Boards Evidence Report

Submission to the Welsh Planning Minister for a Direction under Regulation 7 of the Town and County Planning (Control of Advertisements) Regulations 1992

October 2014 Contents

1. Introduction

2. Legislation & policy

3. Area of Proposed Control

4. Policy initiatives to address the impact of high student populations and HMOs

5. Adverse impact of letting boards

6. Action taken to minimise the effects of letting boards

7. Survey and consultation to support this submission

8. Character appraisal and visual amenity assessment

9. Future enforcement strategy

10. Impact of the proposed controls on existing businesses

11. Conclusions

Appendices

1. Proposed Direction Area

2. Cathays and Plasnewydd Ward Profiles ‐ 2011 Census

3. (to follow when approved) Cardiff Student Community Action Plan 2014 – 2017

4. City of Cardiff Council Cabinet Reports – Plasnewydd HMO Licensing (July 2014)

5. City of Cardiff Council Executive (March 2012) and Cabinet (March 2014) Reports

6. Public Consultation Report

7. Landlord and Letting Agent Consultation Report

8. Draft Policy Guidance ‐ Consultation Version ‐ July 2014

9. 2010 Letting Board Survey ‐ Cathays

10. 2014 Letting Board Survey – Cathays and Plasnewydd

11. Petition received by the Council – May 2014

12. Policy Guidance ‐ Final Draft Version – Oct 2014

13. OFT Report ‐ Home Buying and Selling Market Study – Feb 2010

14. UK Estate Agents and Solicitors/Conveyancers Survey 2011 ‐ Homesalone Report – April 2011 1.0 Introduction

1.1 The City of Cardiff Council requests that the Welsh Planning Minister grant a Direction under Regulation 7 of the Town and County Planning (Control of Advertisements) Regulations 1992 that deemed consent for the display of letting boards relating to residential property, which are advertisements within Schedule 3, Part 1, Class 3A of the regulations, should not apply to parts of the Cathays and Plasnewydd wards of Cardiff (the proposed ‘Direction Area’) as identified on the attached plan (Appendix 1).

1.2 The reason for seeking such a Direction is that the number of letting boards displayed has become so excessive that they have a significant adverse impact on the character and appearance of the area and the wellbeing of the resident communities.

2.0 Legislation & Policy

2.1 The display of outdoor advertisements is controlled by the Town and Country Planning (Control of Advertisements) Regulations 1992. This legislation permits adverts relating to the letting of residential property to be displayed without requiring the Council’s consent, provided they conform with a number of conditions and limitations. Whilst under the normal circumstances the Advertisement Regulations are adequate to keep the impact of outdoor signage within acceptable control, this submission intends to illustrate that the situation in the proposed Direction Area falls well outside of acceptable limits, meaning that special intervention is required.

2.2 Technical Advice Note (TAN) 7 – Outdoor Advertisement Control – November 1996, provides guidance on how applications for advertisements consent are to be assessed and details how requests for special powers are to be made:

Para 22. Before a direction is made, the local planning authority will have to show that it would improve visual amenity and that there is no other effective way of controlling the display of that particular Class of advertisement. As part of this process, local planning authorities will be asked to tsubmi a fully reasoned statement showing that the particular deemed consent provisions are environmentally unsatisfactory in the area or place for which the direction is proposed: dealing with the adverse effects on visual amenity; describing the remedial steps already taken to minimise these effects; giving details of prosecutions for any illegal displays; and assessing the likely consequences of making the direction. The comments of organisations and individuals, whose interests would be affected by the making of a direction, should be sought as part of the process of deciding whether a direction is appropriate.

2.3 This submission intends to address these issues in order to describe why a direction is considered appropriate. In considering the impact letting boards have on area, it is important to note that TAN 7 (para 3) only allows their display to be controlled in the interest of ‘amenity’ and/or ‘public safety’. With these in mind, the City of Cardiff Council considers the display of letting boards to adversely impact on both ‘amenity’ and ‘public safety’.

2.4 It should be recognised that both the Regulations and TAN 7 are over 20 and 15 years old respectively and that planning policy and planning considerations have changed substantially over this period. Of particular relevance is the issue of crime prevention, the initiative to create sustainable communities and the importance given to creating a high standard of public realm.

2.5 Linking into the above considerations, it is also recognised that some streets within the submission boundary lie within designated conservation areas. Accordingly, Section 72(1) of the planning (Listed Building and Conservation Areas) Act 1990 provides that where an area is designated as a conservation area ‘special attention shall be paid to the disability of preserving or enhancing the character of appearance of that area’. The Legislation includes the control of outdoor advertisements.

1 2.6 In conclusion, the conditions and limitations that apply to adverts falling within Schedule 3, Part 1, Class 3A of the 1992 Advertisement Regulations effectively mean the overwhelming majority of ‘to‐let’ boards on display benefit from ‘deemed consent’. As such, they do not require any form of advertisement consent from the Local Planning Authority. In the light of this the Council is seeking special powers under Regulation 7 to remove the benefit of ‘demand consent’ provisions for letting boards. In doing this, all letting boards within the defined area would require advertisement consent. Unauthorised boards (those that do not conform to specific guidance) could then be removed effectively through normal enforcement procedures.

3.0 Area of Proposed Control

3.1 The wards of Cathays and Plasnewydd together cover an area of 4.9 sq km, representing 3.4% of the total 145 sq km area within the City of Cardiff Council administrative boundary.

Figure 3.1 Cathays and Plasnewydd wards within Cardiff

3.2 Both Cathays and Plasnewydd are characterised by very high rates of private renting, accounting for the tenure of over 60% of all households in 2011 as shown in Table 3.1 below. This is up from 44% in 2001, with the absolute number of households also increasing by over 2,500 (22%) during the same period. Looking back further, private renting was at 31% across the two wards in 1991. Appendix 2 provides ward profiles from key 2011 Census statistics.

All households Privately rented properties Exclusively full time student households

Number Number % of all Number % of all households households Cathays 6,192 4,261 68.8% 1,841 29.7%

Plasnewydd 7,565 4,171 55.1% 827 10.9%

Combined 13,757 8,432 61.3% 2,668 19.4%

Cardiff 142,557 31,220 21.9% 3,298 2.3%

Wales 1,302,676 184,254 14.14% 8,067 0.6%

Table 3.1 Household characteristics, 2011

2 3.3 This predominance of private renting can be attributed primarily to the attractiveness of these wards to young people for shared student housing and to professionals living in flats, shared houses or HMOs, due in part to the ease of access to campuses and close proximity to the city centre by public transport, bicycle or on foot. It should be noted that many students stay in Cardiff after graduating and continue to live in the Cathays and Plasnewydd areas, often in shared accommodation. Figure 3.2 provides an indication of the number of subdivided and shared properties within this area.

Figure 3.2 HMOs and Flats

3 3.4 As may be expected, other wards surrounding the city centre, for example Gabalfa, Adamsdown, Riverside and Grangetown, also have relatively high ratios of private renting. However, at less than 40% this is at significantly lower rates to that of Cathays and Plasnewydd. This, together with the lower student numbers, means that the population is less transient in these other wards. The associated rental markets are therefore significantly less vigorous, with fewer properties advertised.

Further Education in Cardiff

3.5 Over 50% of those resident in these wards in 2011 were full time students (Cathays 74%, Plasnewydd 31%). Similarly, people aged between 22‐30 accounted for over 30% of those resident in these wards in 2011, compared to 17% for Cardiff as a whole and 11% for Wales. Those aged under 30 accounted for 70% of the population of these wards in 2011 (see Appendix 2 for more detail).

3.6 The last 10 to 15 year period has seen an unprecedented expansion in the number of people choosing to study in Cardiff, with Census figures showing that there were 43,027 full time students living in the city in 2011, equating to approximately 12% of the population. This is a significant increase of almost 44% since 2001 (29,786 students).

3.7 Some 30,000 students attend one of the city’s three major universities: Cardiff University, Cardiff Metropolitan University or the University of South Wales. In addition there are a number of successful colleges and further education establishments, notably Cardiff & Vale College and the Royal Welsh College of Music and Drama, which have teaching facilities located close to the city centre. Further education facilities and primary halls of residence (university‐run and private) are shown on Figure 3.3.

Figure 3.3 Further education facilities and halls of residence

3.8 The main campus of Cardiff University is located within and adjacent to the Cathays and Plasnewydd wards to the immediate north and east of the city centre, focussed primarily around the Civic Centre, Park Place/Column Road/Newport Road and the University Hospital of Wales at Heath Park. Cardiff

4 Metropolitan University operates from campuses located at Llandaff and Cyncoed. As the name suggests, the University of South Wales is a regional institution, with its Cardiff Campus located to the east and south east of the city centre. All universities have a number of halls of residence on‐campus or nearby. As figure 3.3 illustrates, the proposed Direction Area falls within the centre of the higher education facilities, meaning that privately rented housing within it provides the most convenient accommodation for a huge number of students.

3.9 Purpose‐built student accommodation within the city in the last ten years has provided almost 7,000 additional bed spaces. By providing an alternative to students living in general housing, this makes an important contribution to the housing stock. Despite this, the shortfall has continued to be picked up by the private rented sector, the expansion of which within what is a relatively concentrated area is the primary reason for the proliferation of ‘to‐let’ boards. Accordingly, ‘to‐let’ boards are likely to remain in unacceptably high numbers in the Direction Area unless greater control is given to the Council by granting a Direction.

4.0 Policy initiatives to address the impact of high student populations and HMOs

4.1 In recognition that concentrations of high student populations can lead to negative impacts upon resident communities, the City of Cardiff Council has developed a number of initiatives seeking to mitigate the impact and improve environmental and social conditions in such areas.

4.2 The Council’s approach to the imbalance caused by over concentrations is twofold:

‐ Planning Policy: Diversion of students from the general housing market (in particular areas of over concentration) by permitting the provision of purpose built student accommodation in appropriate locations, primarily within the Central and Bay Business Areas. Policy KP10 within the emerging Draft Local Development Plan 2006‐2026 reinforces this position.

‐ Environmental Health: Improving the environmental conditions in areas dominated by students. (see section below on the Students Community Action Plan).

Cardiff Student Community Action Plan 2014‐17

4.3 The Student Community Action Plan has been in place since 2007. It summarises activities undertaken and planned through a strategic partnership between the Council and the three universities.

4.4 The Plan Action outlines the partnerships’ achievements since the inception of the plan, and aims to deliver an agreed set of actions that address issues under the themes of accommodation, neighbourliness and community respect, health & safety, environmental sustainability, and improved communications, with a view to improving the quality of life for students and residents alike.

4.5 Some of the activities within the plan are described below, however for full details of all the initiatives please refer to the full Action Plan which will be sent as Appendix 3 when approved, expected to be in November 2014.

Student Liaison Officer

4.1 This dedicated officer coordinates many of the activities within the Action Plan, meaning that lines of communication between partners, agencies, communities and students have improved greatly, with all bodies being aware of who to contact when problems arise. The main activities of the Student Liaison Officer include issues relating to waste management, health and safety, crime prevention, parking, community cohesion, anti‐social behaviour and accommodation.

5 Landlord Accreditation Wales

4.2 The Landlord Accreditation Wales (LAW) Scheme is a national joint initiative between the Private Sector Housing/Environmental Health Services from each of the 22 Local Authorities in Wales, and is supported by the Welsh Assembly Government.

4.3 It recognises good landlords and helps them differentiate themselves from less reputable landlords who give the rental market a bad name. It also allows tenants to seek out professional landlords who offer good, well managed accommodation.

4.4 The scheme is administered by Cardiff Council on behalf of the partnership and has trained and supported over 840 landlords with properties in Cardiff, raising standards of knowledge and professionalism in the private rented sector and improving the way landlords deal with their properties and tenants. Those accredited members rent out over 3,000 properties in Cardiff.

Additional HMO Licensing

4.6 In Cathays, Cardiff Council has introduced Additional Licensing for those Houses of Multiple Occupation (HMOs) that fall below the mandatory licensing arrangements, being those households of three or more unrelated adult occupants within 2+ storey buildings. These provisions will also apply within Plasnewydd (commencing November 2014, see Appendix 4).

4.7 The Cathays Additional Licensing Scheme became effective 1st July 2010 for a period of 5 years and has resulted in the licensing of 1,750 properties that would otherwise not have been covered by Mandatory HMO Licensing (properties that have 3 storeys or more and 5 or more occupants), thereby ensuring improved standards of living for tenants and raising the quality of private rented housing stock in Cathays generally.

4.8 The additional licensing schemes are linked to the Landlord Accreditation Wales, with discounted license rates available for accredited landlords. Where doubts remain regarding the evidence presented to demonstrate competency to hold a licence, the Council can require that landlords attend the training to become accredited.

Partnership and Communities Together (PACT)

4.9 Regular Partnership and Communities Together (PACT) meetings across the main student wards provide an opportunity for residents to highlight community issues having an impact on quality of life. Attended by a wide range of authorities and community members, these meetings have improved relations and seen increased representation from the community. Through participation, the Community now has a voice and leads the way in terms of consultation over key messages, information, education priorities and identification of key community priorities.

5.0 Adverse impact of letting boards

5.1 The Council has sought to mitigate the impact through a proposed voluntary code and through enforcement action where possible. However in recent years the issue of letting boards has risen in prominence. It is considered that a new proactive approach is required which will be underpinned by a statutory Direction to ensure compliance.

5.2 The traditional means of advertising the availability of property to rent is by placing a ‘to‐let’ advertisement boards on the building or in its curtilage. Although this method of advertisement is used through out the country and causes few problems, it has become a serious issue within Cardiff because of the huge number of properties involved.

6 5.3 Properties for rent on short term tenancies make up a large percentage of total available housing stock in parts of Cardiff and it is this concentration, particularly in the proposed Direction Area, which causes the problem. The situation is further compounded by the fact that a high percentage of properties in the proposed Direction Area are also rented by students; so tenancy agreements tend to run for a 12 month period (e.g. July to August) which creates an annual letting ground. The result of this annual letting ground is that whole streets become dominated by letting boards, particularly from November to February. Although this situation should only be for a relatively short period of time each year, the reality is somewhat different, as shown by the results of the survey undertaken in the Summer of 2014.

5.4 The principal concern of residents relates to the adverse visual impact of large numbers of letting boards have on the character and appearance of parts of Cardiff. The problem is so serious in some streets in the proposed Direction Area that it can virtually appear that every property is for rent. eTh visual impact resulting proliferation of letting boards can be particularly detrimental to the overall quality, character and appearance of the four conservation areas in the Direction Area.

5.5 From the perspective of landlords and letting agents, the use of letting boards is a convenient means of attracting new tenants. However, they are also increasingly used as a marketing and advertising tool where concentrations of boards show the extent of an agent’s portfolio. As more landlords enter the market, then competitio to secure tenants increases, leading to greater requirements to advertise. Accordingly, letting boards are now displayed early in the year and often stay in place for long period of times in order to gain advantage over other operators. There appears to be little incentive for agents to remove the boards but a lot to be gained from free advertising. The results of the public survey exercise show that the majority of people thought that the effectiveness of letting boards as a way of finding new accommodation was minimal, due to the properties often not actually being available, or that other means of searching such as websites or estate agent lists being more effective (see section 7 and Appendices 6, 13 and 14 for more information).

5.6 The overall consequence is that letting boards dominate the public realm to the detriment of the area’s character and appearance. This visual harm will be explained further in Section 8 of this report.

5.7 Another major concern for many permanent residents is not solely the visual impact of the boards but what the boards represent. The numbers of letting boards identify the area as one where there is a transitory population which can mark the decline in the attractiveness of the area for single family occupation. The balance of the community is changed by the influx of mainly young single people occupying shared rented properties. This has an impact on school rolls, as there are fewer families with children in the area, with census statistics showing that children of school age accounted for 9.5% of residents in 1991 (2,251), compared to just 5.6% (1,774) in 2011.

5.8 A further result of this shift in diversity is that the range and scope of other local services alter to meet the different demands of the dominant population e.g. more hot foot takeaways and convenience stores with extended opening hours, accompanied by the loss of more traditional shops. Although it is accepted the existence of letting boards is not responsible for these changes, the Council has identified that the transient nature of the population in the proposed Direction Area and their presence in large numbers does draw attention to these issues and can have the effect of re‐enforcing change.

5.9 In addition to the above, there are also community safety concerns allied to the display of letting boards as it is well known that many properties will be occupied by students. Rented properties tend to be more vulnerable to theft due to the potentially lower standard of maintenance, repair and security. Student houses in particular are targeted as they often have high value, easily disposable items such as mobiles, audio/visual equipment and laptops/tablets in large quantities. They can also be vacant during certain times of the year.

7 5.10 During background survey work in 2009/10, Police records were checked for recorded burglaries in the Cathays Ward which may have occurred as a result of the presence of ‘To‐let’ or ‘For Sale’ boards in the area. Between September 2009 and June 2010, there were 28 burglaries (3.50%) in properties with ‘To‐let’ signs (800 properties) as at April 2010, and 75 burglaries (1.56%) in properties without such signs (2,400 properties). Hence, this snapshot showed that those properties with ‘To‐let’ signs were burgled at over twice the rate of those without ‘To‐let’ boards.

5.11 In conclusion, the proliferation of letting boards effectively act as a constant reminder that an area has a lack of permanent residents and makes it easier to identify properties that may be at greater risk of burglary due to nature of their occupation. To have greater control over the display of letting boards would represent a positive move forward in terms of helping to address the issue of community safety and would at the very least make it more difficult to target individual property.

6.0 Action taken to minimise the effects of letting boards

6.1 As noted in section 2, the Advertisement Regulations are such that the vast majority of letting boards on display at any one time benefit from deemed consent. Of the minority of those who do not comply, enforcement action can be taken to have the boards removed, although the process is often very labour intensive and prosecution in the courts is difficult to secure.

6.2 In an attempt to establish if estate agents and letting agencies could be persuaded to voluntarily cease to place such signs on properties in the Cathays Ward, or place smaller standard signs instead, the Development Manager wrote to them on two occasions (see March 2012 Executive Report at Appendix 5), but had very little response or positive feedback about the proposal, primarily due to the perceived doubts about the level of participation and difficulties in ensuring compliance.

6.3 There were in excess of 100 letting board related enforcement investigations across the two wards between 2008 and 2014. These investigations related to ‘Let By’ signs or properties with multiple signs. Where breaches of the existing regulations for boards had been observed, action was taken by enforcement officers to seek their removal through negotiation without resorting to formal proceedings.

6.4 The limited enforcement action taken over the years clearly highlights how few boards are actually unauthorised and that the real problem lies with the total number on display throughout large parts of the year, rather than the relatively small number of unauthorised boards that can be removed through enforcement action.

6.5 Furthermore, as observed in the 2014 survey and through enforcement investigations, the regulations are being increasingly flouted by estate agents through multiple board displays, boards remaining in place far in excess of the 14 days following let completion, and boards being displayed at properties which are not actually to‐let. It is also noticeable that only a handful of landlords/agents make use of the ‘Let By’ attachment, with many preferring instead to have boards in situ for long period of time. In these circumstances it is difficult to have boards removed as establishing if a property is fully let or not can be problematic and time consuming.

8 7.0 Survey and consultation to support this submission

2009 / 10 Survey of Cathays

7.1 In order to establish evidence as to the scale of the specific problem within the Cathays Ward, two separate surveys of the area were undertaken in November 2009 and April 2010 with help from the Student Liaison Officer and volunteers. The results of these surveys showed that, in November 2009, 779 dwellings had letting boards displayed (plus 22 for sale boards) and, in April 2010, this figure had reduced to 751 (plus 44 for sale boards). Apart from a few small areas of concentration, the signs appeared to be well dispersed throughout the residential area of the Cathays Ward, as identified at Appendix 9.

7.2 At the time the surveys were undertaken, there were approximately 5,600 residential units in the Cathays Ward, as confirmed by Council Tax records. This means that, in November 2009, 14.3% of dwellings had such signs displayed and, in April 2010, this figure had reduced marginally to 14.2%. Between the two surveys, 513 boards (64%) showed no change (i.e. remained in situ); 288 had been removed and 281 new boards were placed.

7.3 The survey did not extend to Plasnewydd, because at this point in time, visual amenity was not felt to be as severely affected as in Cathays. This position has since changed, with the survey from 2014 demonstrating that the visual impact of Plasnewydd is also being adversely affected.

2013 Survey of Cathays

7.4 A further survey was undertaken in October 2013 to ascertain if the number of letting boards had changed since the 2010 survey and the associated 2012 Executive Report.

7.5 This survey only assessed the number of letting boards on a street‐total basis, rather than recording individual board details and locations. However, the results found that a total of 815 letting boards were present in Cathays, an increase of 8.5% on the 2010 survey total. As a result of this failure in lettings board control, a request was made by ward Councillors to progress the necessary work to seek mandatory removal of deemed consent to display advertisements in the Cathays and Plasnewydd Wards.

7.6 A report was presented to the Council’s Cabinet on 13th March 2014 (Appendix 5). This report stated that the further survey work carried out since 2012 showed that the problem has endured in parts of the Cathays and Plasnewydd wards and that there was evidence to support the case for seeking a Regulation 7 Direction. The Cabinet noted the continuation of the evidence gathering and policy drafting work necessary to justify, support and deliver a Direction under Regulation 7 and authorised the Director of Strategic Planning, Highways and Transportation to apply to the Planning Minister to request that the necessary Direction be served.

Policy Guidance for the Acceptable display of Letting Boards

7.7 The policy work noted within the Cabinet Decision was a reference to an approach taken by other university cities in England, notably Leeds and Nottingham, where Directions had been approved by the First Secretary of State. In those instances deemed consent was removed, however given the large number of properties affected and the need to avoid delay, those Councils do not ask for applications for, or take action against, those boards which meet a series of criteria regarding the design, number position and duration of display.

7.8 This approach was felt to be the most reasonable in order to address the visual impact whilst allowing landlords to continue to advertise properties with a board, albeit in a significantly more restricted manner. The Nottingham example was considered to offer the most robust guidance and discussions 9 with that authority confirmed that the scheme had been operating successfully since its implementation in October 2012, with letting boards no longer causing visual harm in their Direction area.

7.9 This approach was adapted and designed to be relevant to Cardiff, with clear criteria presented in both diagrammatic and numbered form. As in Nottingham, the guidance will form a key part of the enforcement strategy, as explained in section 9. A copy of the proposed guidance can be found at Appendix 12.

2014 Survey of Cathays and Plasnewydd

7.10 A comprehensive survey of both wards was undertaken in summer of 2014 (over the months of May to July). This survey recorded the presence and agent name for every board visible at that time, with further information recorded for properties with more than one board on display. Boards relating to properties for sale or commercial letting were not included in the survey. Given that it is at the end of the academic year and that students typically search for property within the winter/spring months, it could be argued that this is traditionally the quietest part of the year for student letting activity.

7.11 The survey revealed that a total of 937 letting boards were on display in Cathays, an increase of 15% on the October 2013 survey. This was an increase of 25% on the 2010 figure of 751.

7.12 A total of 551 letting boards were recorded in Plasnewydd, meaning that approximately 8% of the approx 7,000 households (2011 Census) were advertised as available for rent. This can be compared to a household vacancy rate of 5% at the time of the 2011 Census.

7.13 Full survey results and frequency of letting board maps can be found at Appendix 10 and within Section 8, which also provides more detail as to the harm to visual amenity being caused within various smaller character areas of the Direction Area. Table 7.1 below shows how the number of letting boards has increased in recent years, with a small drop in April 2010 following requests for better ‘board‐discipline’ as described in Section 6.

Nov 2009 Apr 2010 Oct 2013 July 2014 Cathays 779 751 815 937 Plasnewydd n/a n/a n/a 551 Total n/a n/a n/a 1,488

Table 7.1 Total letting boards 2009‐2014

7.14 The distribution of letting boards recorded during the 2014 survey across both wards is indicated below at Figure 7.1.

7.15 While letting boards were present in high numbers throughout the Direction Area, the survey showed that the highest concentrations were visible in those areas closest to the city centre and in areas with particularly high levels of HMOs and buildings subdivided into flats (see Figure 3.2). Section 8 provides a more detailed breakdown of these results.

10

Figure 7.1 Letting Boards Survey, Summer 2014 11 7.16 The survey showed that almost 1,500 letting boards had been erected across the two wards by 78 different letting agents. However, the vast majority (80%) of boards could be attributed to fewer than 20 letting agents, with 50% (734) erected by just five agents, as shown at Figure 7.2.

Figure 7.2 Infographic showing the breakdown of total (1,488) letting boards in Cathays and Plasnewydd by agent, 2014 survey

Consultation

7.17 Following the Cabinet decision in March 2014 (Appendix 5), a programme of consultation was undertaken to seek comments from the public and landlords/letting agents regarding the intention to apply for a Regulation 7 Direction in the proposed Direction Area.

7.18 In advance of undertaking the consultation, a petition requesting supporting action on to‐let signs in Cathays and Plasnewydd was received by the council in May 2014. The petition requested the following:

“We support Labour Cardiff County Council’s steps to control the spread of "To‐let" signs in Cathays and Plasnewydd. We believe these signs blight Cathays and Plasnewydd due to their numbers and unsightliness. They become a form of constant advertising for Estate Agents rather than being used to advertise individual properties for let and raise the risk of burglaries. They also undermine the sense of community in Cathays and Plasnewydd." Why is this important? Cathays and Plasnewydd are blighted by "to‐let" signs ‐ they blight our area and help to make our streets look untidy. They can also be used by burglars to target student houses. All too often they remain up for months, even years, and become a form of advertising for Letting Agencies.”

7.19 At the time of this submission, the petition had 262 supporters: 116 physical and 146 electronic signatories (via a website www.bit.ly/bantheboards). The petition is copied at Appendix 11. This indicated that in addition to the ward councillor support for the controls, there was significant public support to take action.

12 7.20 Cardiff Research Centre, the Council’s consultation service, were commissioned to design a survey that could be completed both online and offline in order to obtain wider public views about the issue of letting boards and the proposed controls and guidance (which was available on the survey page as a PDF download) that would be put in place should the Direction be put in place. The survey stated at the outset that a dedicated landlord and letting agent survey would follow shortly after the closure of the public consultation.

7.21 The public consultation survey was hosted at a dedicated website (bilingual) from 7th August 2014 for a period of 21 days. A hard copy version was made available on request. It was promoted through various lines of communication, including:

- distribution to the 484 members of the ‘Ask Cardiff’ Citizens’ Panel that were resident in Cathays or Plasnewydd; - via Cardiff Council’s Twitter Feed (28,800 followers); - through the Council‐led Landlord Accreditation Wales programme; - within the Student Liaison Officer’s newsletter and email distribution list; - linked from the ‘Ask Cardiff’ website home page; and - by the ward councillors; through letter drops and at Ward Surgeries.

7.22 A total of 477 valid responses were received, which was considered to represent a good level of response and a statistically robust sample of the target wards. 81.7% of respondents reported that they were concerned about the number of residential letting boards in their neighbourhood, compared to 15.7% who were not. A full report summarising the results of the consultation exercise and the comments received is attached to the rear of this submission (Appendix 6).

7.23 The landlord and letting agent survey was hosted from 4th August 2014 for a period of 21 days at a dedicated website (bilingual). The survey was designed in order to seek views regarding the proposed criteria within the Guidance document referred to above and included as Appendix 8 (which was available on the survey page as a PDF download).

7.24 Letters were sent to 173 letting agents across the city, inviting them to participate in the survey. This included all agents that had boards on display in Cathays or Plasnewydd during the 2014 survey, together with all other known letting agents known by the Council’s Private Sector Housing team. A sample copy of the letter is attached within Appendix 7.

7.25 A total of 22 responses were received, with 77% stating that they were in support of the Council in taking action to control letting boards in Cathays and Plasnewydd. The response was very poor, with only 13 named letting agents responding, this represents just 10% of the agents displaying boards in Cathays or Plasnewydd in 2014, and just 7% of all those agents contacted. A report summarising the results of the consultation exercise and the comments received is attached to the rear of this submission (Appendix 7).

7.26 The named agents that responded collectively accounted for 127 (8.5%) of the letting boards on display in the 2014 survey (8 agents). No response was received by any of the agents within the top nine in terms of numbers of boards (totalling 918 boards, or 62% of all boards – see figure 7.2).

7.27 Given the limited numbers of boards displayed by those agents that did respond, both the positive level of support for action against the more prolific agents and the negative comments regarding the limiting nature of the criteria proposed are considered to be understandable. The respondents generally stated that they undertook theirg lettin business with respect for the regulations in place in terms of timely and relevant erection and removal of boards, and that some other agents used the boards as general advertising.

13 7.28 Some respondents requested that the boards be banned altogether as the other means of advertising properties were more than sufficient to attract prospective tenants, as demonstrated by their own businesses not using letting boards at all. This approach has recently been taken in Newcastle, however it is felt that the Guidancee Code rout would allow enforcement to be carried out to ensure whilst significant improvement to visual amenity, whilst allowing letting agents, particularly smaller businesses, to advertise properties on‐street.

14 8.0 CHARACTER APPRAISAL AND VISUAL IMPACT ASSESSMENT

This section intends to describe the character and appearance of the residential areas of each ward and to assess how the proliferation of letting boards is considered to harm visual amenity.

8.1 Cathays Ward

Cathays became a suburb of Cardiff in 1875, following the development of the docks, and the resultant number of new workers flocking to Cardiff. At that time, a few streets led off Woodville Road and Cathays Terrace, but by 1900, the urbanisation of Cathays was virtually complete, as shown below.

Well over 100 years on, the residential area of Cathays remains predominantly characterised by the same high density late‐Victorian residential terraces, accounting for 70% of housing in the ward in 2011 (Census). The extent of the area is well‐defined by railway lines to east and west, Cathays Cemetery and Maindy Barracks to the north and the city centre and civic centre to the south.

1886

1900

th Image 8.1 Early Edition OS Maps showing the rapid construction of Cathays at the end of the C19 15 Character Areas

In order to describe the impact of letting boards upon visual amenity on a local scale, the residential area of Cathays has been divided into ten ‘character areas’, as shown below and described within the following pages. These boundaries have been determined based on street and layout characteristics, land uses and housing styles. The full 2014 letting board survey results can be found at Appendix 10.

Image 8.2 Cathays Character Areas

16 8.2 Area A – Senghennydd Road to Miskin Street

Character Appraisal

The area lies directly to the rear of Cardiff Students’ Union and offers some of the closest private rented accommodation to the Cardiff University main campus buildings. Many properties are HMOs or divided into flats, occupied predominantly by students (CC Council Tax exemptions data). Two streets benefit from fronting onto landscaped public gardens.

Key Characteristics

- Long/channelled street views - Uniformity of two and two ½ storey terraced housing, built predominantly c.1890‐1900. - Relatively narrow building plots of 5‐6m with small forecourts bounded by walls/railings/hedges. - Consistent use of limited materials: distinctive local pennant stone facing, stone dressings, brick, render and slate. - Rhythms and visual tinteres created by bay windows, gables, chimneys and brick/stone detailing. - Some larger subdivided properties in Llanbleddian Gardens and Glynrhondda Street. - Character enhanced by mature trees and the presence of landscaped public gardens.

Visual Impact Assessment

Within Area A, a total of 135 letting boards were in position in May 2014. This represents the third highest concentration of any area at 12.4 boards per ha, with several streets showing greater than one board every 10m, equating to more than one board every other property (see Appendix 10 – Frequency of letting boards map). The most significant concentrations could be seen at Llanbleddian Gardens (below), Glynrhondda Street, Llandough Street and the northern end of Miskin Street.

The relatively narrow plot widths, continuous terraces and small front forecourts mean that the adverse visual impact of such numerous letting boards is particularly acute in this area. The number of boards on display makes it seem that almost every property is perpetually available for rent.

Image 8.3 Llanbleddian Gardens 17 8.3 Area B – Rhymney Street to Woodville Road

Character Appraisal

This area is densely populated by regimented rows of tightly‐packed residential terraces and limited vegetation. Properties within this area are predominantly occupied by groups of students sharing private rented accommodation, with a high proportion of HMOs and student households. The area includes (primarily ground floor) retail premises within the Salisbury Road Local Centre.

Key Characteristics

- Long/channelled street views - Uniformity of two storey terraced housing, built predominantly c.1870‐1900. - Narrow building plots, mostly under 5m, fronting straight onto the back edge of pavements. - Narrow streets, no green spaces and limited roadside vegetation. - Consistent use of limited materials: distinctive local pennant stone facing, stone dressings, brick, render and slate. - Limited decorative detailing, but rhythms and visual interest created by bay windows, gables, chimneys and brick/stone detailing. - Salisbury Road local shopping centre, many units with residential accommodation above.

Visual Impact Assessment

Within Area B, a total of 318 letting boards were in position in May 2014. This represents the highest concentration of any area at 16.7 boards per ha, with several streets showing greater than one board every 10m in 2014, equating to more than one board every other property.

The very narrow plot widths and roads, continuous terraces and lack of forecourts mean that the adverse visual impact of such numerous letting boards is particularly acute in this area. As an example, 67 boards were on display in Rhymney Street (below), which has plot widths of around 4.5m and a street width of under 12m, intensifying the visual impact of the multiple signs on display to the point that it seems almost every property is for rent.

Image 8.4 Rhymney Street 18 8.4 Area C – Letty Street to May Street

Character Appraisal

This area is densely populated by regimented rows of tightly‐packed residential terraces and limited roadside vegetation. Properties within this area are predominantly occupied by groups of students sharing private rented accommodation, with a high proportion of HMOs and/or student households.

Key Characteristics

- Long/channelled street views - Uniformity of two storey terraced housing, built predominantly c.1870‐1900. - Narrow building plots, mostly under 5m, fronting straight onto the back edge of pavements. - Narrow streets, no green spaces and limited roadside vegetation. - Consistent use of limited materials: distinctive local pennant stone facing, stone dressings, brick, render and slate. - Limited decorative detailing, but rhythms and visual interest created by bay windows, gables, chimneys and brick/stone detailing.

Visual Impact Assessment

Within Area C, a total of 119 letting boards were in position in May 2014. This represents the second highest concentration of any area at 15.7 boards per ha.

The very narrow plot widths and roads, continuous terraces and lack of forecourts mean that the adverse visual impact of such numerous letting boards is particularly acute in this area. As an example, 36 boards were on display in May Street (see below), which has plot widths of around 4.5m and is around 300m long. This represents a board being on display every 10m on average, or approximately one board for every three addresses on the street.

Images 8.5 and 8.6 May Street

19 8.5 Area D – Cathays Terrace to Maindy Road

Character Appraisal

Similar in character to areas B and C, this area is also primarily characterised by tightly‐packed residential terraces fronting straight onto the pavement, with limited roadside vegetation. It borders the new Maindy Park Campus of Cardiff University. With the exception of Maindy Road which has a higher percentage of owner‐ occupiers, properties within this area are predominantly occupied by groups of students sharing private rented accommodation, with many buildings being HMOs and/or student households.

Key Characteristics

- Long/channelled street views - Uniformity of two storey terraced housing, built predominantly c.1890‐1900, with some inter‐war housing on Maindy Road and 1960s flats fronting Cathays Terrace/Catherine Street. - Narrow building plots, mostly under 5m, mostly fronting straight onto the back edge of pavements. - Narrow streets, no green spaces and limited roadside vegetation. - Distinctive local pennant stone facing with brick window surrounds, use of render and slate roofing. - Limited decorative detailing, but rhythms and visual interest created by proportions of windows, gables, chimneys and brick/stone detailing. - Some larger 3 storey (inc basements) properties on Cathays Terrace.

Visual Impact Assessment

Within Area D, a total of 105 letting boards were in position in May 2014, equating to 9.4 boards per ha. Cathays Terrace and Treherbert Street showed the highest number of boards per property in this area, with just under one every three addresses. The visual clutter created by numerous forecourt and frontage‐applied signage is also notable in this area (see below).

Image 8.7 Treherbert Street Image 8.8 Cathays Terrace

20 8.6 Area E – Column Road and North Road

Character Appraisal

The terraced housing to west of the railway line in built along North Road and Colum Road, key routes into the city centre from the north. The area is more mixed in land uses than others within the core of Cathays, but offers some very convenient private rented accommodation close to Cardiff University Business School and Cathays Park. Properties within this area are predominantly occupied by groups of students sharing private rented accommodation, with a high proportion of HMOs and/or student households.

Key Characteristics

- Long/channelled street views - Two storey terraced housing, built predominantly c.1890‐1900, surrounded by larger modern student halls of residence, university buildings and the Nazareth House care home. - Relatively narrow building plots of 5‐6m with small forecourts bounded by walls/railings/hedges. - Consistent use of limited materials: distinctive local pennant stone facing, stone dressings, brick, render and slate. - No green spaces and limited roadside vegetation. - Rhythms and visual interest created by bay windows, gables, chimneys and brick/stone detailing.

Visual Impact Assessment

Within Area E, a total of 51 letting boards were in position in May 2014, equating to 7.2 boards per ha. Colum Road (see below) featured 41 boards on display, just under one every three addresses. The visual clutter created by numerous forecourt and frontage‐applied signage is a particular problem within such a prominent key route into the city centre.

Image 8.9 Colum Road Images 8.10 Blackweir Terrace 21 8.7 Area F – Rhigos and Gelligaer Gardens

Character Appraisal

This area of inter‐war housing is characterised by red brick built two storey terraces fronting onto landscaped public gardens and tree‐lined streets. Historically the area has been characterised by high percentage of owner occupier family properties, with 71% in 2001. However the attractiveness of the area to the private rental sector continues to increase, as demand for accommodation close to the new facilities at the Maindy Park Campus grows. The proportion of owner occupation in this area fell to 52% in 2011 (Census), with private renting accounting for 27% of all tenure in 2001 rising to 45% in 2011.

Key Characteristics

- Long/channelled street views - Uniformity of two storey terraced housing, built c.1925‐1935. - Relatively narrow building plots of 5‐6m with small forecourts bounded by red brick walls and railings. - Consistent use of limited materials: pressed red brick, stone dressings, render and slate roofs. - Rhythms and visual interest created by bay windows, gables, chimneys and brick/stone detailing. - Character enhanced by mature trees and the presence of landscaped public gardens.

Visual Impact Assessment

Area F had the lowest concentration of letting boards during the May 2014 survey of the Cathays residential area, with just four boards in place for some 114 addresses. This low number can be attributed to the very low level of private renting, however this is envisaged to change in response to the continued northerly expansion of Cardiff University at the Maindy Campus. For this reason it is considered necessary to include these streets within the proposed area of special advertisement control.

22 8.8 Area G – Llantrisant Street to Gelligaer Street

Character Appraisal

The Edwardian terraces within area G are located at the northern extent of Cathays, separated from the Gabalfa ward by Maindy Barracks. The overall layout here is slightly more generous in terms of road widths and plot sizes that in the heart of Cathays.

Similar to Area F, until recently this area had been characterised by a high proportion of households in owner occupation, 71% in 2001. However the private rental sector has grown from 27% in 2001 to 45% in 2011. This trend is considered likely to continue with the expansion of nearby university facilities off Maindy Road.

Key Characteristics

- Long/channelled street views - Two storey terraced housing, built predominantly c.1900‐1910 - Relatively narrow building plots of 5‐6m with small forecourts bounded by walls/railings/hedges. - Consistent use of limited materials: terraces of either distinctive local pennant stone or red brick facing, stone or brick dressings, render and slate. - No green spaces and limited roadside vegetation. - Rhythms and visual interest created by bay windows, gables, chimneys and brick/stone detailing.

Visual Impact Assessment

Within Area G, a total of 73 letting boards were in position in May 2014, equating to 6.4 boards per ha. Concentrations of letting boards causing particular harm to visual amenity were evident in Brithdir Street, Gelligaer Street and Llantrisant Street, each with around one board per 4 or 5 addresses.

Image 8.12 Brithdir Street Images 8.13 Llantrisant Street 23 8.9 Area H – Monthermer Road to Fairoak Road

Character Appraisal

This area is also located at the northern extent of Cathays, separated from Gabalfa by Cathays Cemetery and from Plasnewydd by the Valleys & Cardiff Local Routes railway to the east. The area is popular for private renting, accounting for around 60% of all household tenure in 2011, up from 42% in 2011. The housing here is the closest area in Cathays to Cardiff University’s Heath Park (hospital) Campus.

Key Characteristics

- Long/channelled street views - Two storey terraced housing, built predominantly c.1890‐1900. - Relatively narrow building plots of 5‐6m with small forecourts bounded by walls/railings/hedges. - Consistent use of limited materials: distinctive local pennant stone facing, stone dressings, brick, render and slate. - No green spaces (although bordered by Cathays Cemetery) and limited roadside vegetation. - Rhythms and visual interest created by bay windows, gables, chimneys and brick/stone detailing.

Visual Impact Assessment

Within Area H, a total of 126 letting boards were in position in May 2014, equating to 10.3 boards per ha. Concentrations of letting boards causing particular harm to visual amenity were evident in Clun Terrace, Malefont Street, Monthermer Road and Tewkesbury Street, each with around one board per 4 or 5 addresses.

Images 8.14 Clun Terrace Images 8.15 Malefont Street 24 8.10 Area I – Daniel Street to Gwennyth Street

Character Appraisal

This area is densely populated by regimented rows of tightly‐packed residential terraces and limited vegetation. Private rentals accounted for around 64% of all households in this area in 2011, up from 42% in 2001.

Key Characteristics

- Long/channelled street views - Uniformity of two storey terraced housing, built predominantly c.1870‐1900. - Narrow building plots, mostly under 5m, either with very small forecourts or fronting straight onto the back edge of pavements. - Narrow streets, no green spaces and limited roadside vegetation. - Consistent use of limited materials: mainly red brick facing, with some stone facing or render - Limited decorative detailing, but rhythms and visual interest created by bay windows, gables, chimneys and brick/stone detailing.

Visual Impact Assessment

Within Area I, a total of 41 letting boards were in position in June 2014, equating to 5.7 boards per ha. Several streets had an equivalent of one board for every 5‐10 properties. This is a relatively low number compared with the rest of Cathays, however it is still significant enough to be considered a problem as the very narrow plot widths and roads, continuous terraces and absence of forecourts in several streets exacerbates the adverse visual impact of those boards present in this area.

Image 8.16 Florentia Street

25 8.11 Area J – Crwys Road and Woodville Road (commercial areas)

Character Appraisal

This area covers a similar boundary to the designated District Shopping Centre, relating to commercial facilities at Crwys Road and an eastern section of Woodville Road. A number of residential properties remain interspersed between stretches of shops (see image below).

Key Characteristics

- Predominately relatively narrow (5‐6m) plots of two storey residential buildings converted to commercial uses and forming the Crwys Road/Woodville Road District Centre. - Ground floor shop front build‐outs within former forecourts. - Many units with residential accommodation above. - No green spaces and limited roadside vegetation. - Some larger purposet‐buil commercial units and places of worship. - Includes Roy Jenkins Hall, Cardiff University halls of residence.

Visual Impact Assessment

Within Area J, a total of 25 letting boards were in position in June 2014, equating to 3.8 boards per ha. Clusters of boards were visible on both Crwys Road and Woodville Road, with some relating to flats above commercial units, with around one board per 10 addresses on Crwys Road and one per five on Woodville Road.

The number of boards was relatively low when compared with the rest of Cathays, however to ensure that a consistent approach is applied throughout the residential area of the ward, it is considered necessary to include these streets within the Direction Area.

Image 8.17 Crwys Road

26 8.12 Plasnewydd Ward

Plasnewydd (commonly known as Roath) is also one of the earliest suburbs of Cardiff. Eastern suburban development was initiated in the 1850’s by Charles Morgan of the Tredegar Estate, laying out a grid of four streets to the north of Newport Road, West Grove, East Grove, The Walk and The Parade.

Completion of this residential area was rapid as by 1900 the area was virtually complete as shown below. The large grand houses fronting and leading off the newly established Roath Park followed shortly after.

As with Cathays, Plasnewydd also remains predominantly characterised by high density late‐Victorian residential terraces (accounting for 55% of households in the ward in 2011, with a further 25% being flats within converted buildings), with several grander, more spacious streets, the best‐preserved of which are now protected by conservation area designations. The extent of the area is defined by a railway line to the west, Roath Park to the east and north and Newport Road to the south.

Image 8.18 Early Edition OS Map showing Plasnewydd in 1900 27 8.13 Character Areas

To help describe the impact that letting boards are considered to have upon visual amenity across the Plasnewydd ward, eight character areas have been identified, as identified below.

Image 8.19 Plasnewydd Character Areas

28 8.14 Area K – Roath Park

Character Appraisal

This area of Plasnewydd forms a large part of the Roath Park Conservation Area, originally designated in 1973 and reviewed in 2008 within a Conservation Area Appraisal, which provides full information about the area’s special character. The key arterial street of Ninian Road fronts the recreation ground and pleasure gardens of Roath Park, with further side streets emanating from it in a south westerly direction. As with all conservation areas, the distinctive character of this area is created by a combination of a distinctive quality of place; the presence of landmark buildings; high quality local or unusual materials; high quality architectural detailing; and high quality hard and soft landscaping. Private renting accounts for around 55% of the tenure of households in this area (Census, 2011). This area has a relatively high proportion of HMOs and properties subdivided into flats, particularly on Ninian Road.

Key Characteristics

- Long/channelled street views - Uniformity of two and two ½ storey blocks of terraced housing, built predominantly c.1890‐1910. - Some commercial uses focussed near the roundabout on Pen y Wain Road. - Relatively narrow building plots of 5‐6m with small forecourts bounded by walls/railings/hedges. - Consistent use of limited materials: distinctive local pennant stone facing, stone dressings, brick and slate. - Rhythms and visual interest created by bay windows (many original decorative timber sliding sashes), gables, chimneys and brick/stone detailing. - Some larger subdivided properties on Ninian Road, with larger front gardens. - Character enhanced by mature trees and the presence of Roath Park.

Visual Impact Assessment

Within Area K, a total of 50 letting boards were in position in June 2014. Although this is a relatively low number when analysed per hectare (2.7), however concentrations of letting boards causing particular harm to visual amenity were evident in the southern half of Ninian Road and within Shirley Road.

Image 8.20 Shirley Road Image 8.21 Ninian Road

29 8.15 Area L – Mackintosh Place to Angus Street

Character Appraisal

This area is densely populated by regimented rows of tightly‐packed residential terraces and limited roadside vegetation. Private renting accounts for around 50% of the tenure of households in this area (Census, 2011). Council tax student exemption records show that there is a high number of student properties within the area.

Key Characteristics

- Long/channelled street views, relatively narrow streets, no green spaces and limited roadside vegetation. - Uniformity of two storey terraced housing, built predominantly c.1890‐1900. - Narrow building plots, mostly under 5m with small forecourts bounded by walls/railings/hedges. - Consistent use of limited materials: distinctive local pennant stone facing, stone dressings, brick, drender an slate. - Rhythms and visual interest created by bay windows, gables, chimneys and brick/stone detailing.

Visual Impact Assessment

Within Area L, a total of 169 letting boards were in position in June 2014, equating to 6.5 boards per ha. Concentrations of letting boards causing particular harm to visual amenity were evident in most streets in the area, but particularly at Mackintosh Place, where one board per four addresses was recorded, or one board per 10‐15m.

Image 8.22 Mackintosh Place

30 8.16 Area M – Strathnairn Street to Cyfarthfa Street

Character Appraisal

This area is densely populated by regimented rows of tightly‐packed residential terraces and limited roadside vegetation. Private renting accounts for as much as 62% of the tenure of households in this area (Census, 2011). Council tax student exemption records show that there is a high number of student properties within the area.

Key Characteristics

- Long/channelled street views, relatively narrow streets, no green spaces and limited roadside vegetation. - Uniformity of two storey terraced housing, built predominantly c.1890‐1900. - Narrow building plots, mostly under 5m, some streets with small forecourts bounded by walls/railings/hedges, others fronting straight onto the pavement edge. - Consistent use of limited materials: distinctive local pennant stone facing, stone dressings, brick, render and slate. - Rhythms and visual interest created by bay windows, gables, chimneys and brick/stone detailing.

Visual Impact Assessment

Within Area M, a total of 97 letting boards were in position in July 2014, equating to 5.6 boards per ha. Concentrations of letting boards causing particular harm to visual amenity were evident in most streets in the area, but particularly at Glenroy Street, where one board per six addresses was recorded.

Image 8.23 Glenroy Street

31 8.17 Area N – Richmond Road

Character Appraisal

This area is also located at the western extent of Plasnewydd, separated from Cathays by the Valleys & Cardiff Local Routes railway which can be crossed in two locations at Lowther Road and pedestrian footbridge at Fitzroy Street. The housing here is the closest area in Plasnewydd to the civic centre and the city centre. Perhaps unsurprisingly, the area is therefore very popular for private renting, accounting for the vast majority (80%) of all household tenure in 2011. Council tax student exemption records show that there is a high number of student properties within the area.

Key Characteristics

- Long/channelled street views - Predominantly uniform two storey terraced housing blocks, built predominantly c.1870‐1900, with narrow building plots of 4‐6m with small forecourts bounded by walls/railings/hedges. - Larger two ½ storey semi‐detached properties fronting Richmond Road, mostly subdivided into flats or HMOs, with wider building plots of 7‐m10 and more generous front gardens. - Consistent use of limited materials: distinctive local pennant stone facing, stone dressings, brick, render and slate. - Rhythms and visual interest created by bay windows, gables, chimneys and brick/stone detailing. - The character of several streets is enhanced by mature trees.

Visual Impact Assessment

Within Area N, a total of 117 letting boards were in position in July 2014, equating to 7.5 boards per ha. This area had the highest frequency of boards within Plasnewydd, with concentrations of letting boards causing particular harm to visual amenity evident in were evident in most streets in the area, but particularly on Richmond Road (62 boards), Bedford Street and Northcote Street, each with one board per 10‐15m of street length.

Image 8.24 Richmond Road Image 8.25 Bedford Street

32 8.18 Area O ‐ Tredegarville

Character Appraisal

The is a conservation area, designated in 1981 and reviewed in 2008 within a Conservation Area Appraisal, which provides full information about the area’s special character. As with all conservation areas, the distinctive character of this area is created by a combination of a distinctive quality of place; the presence of landmark buildings; high quality local or unusual materials; high quality architectural detailing; and high quality hard and soft landscaping. The streets were some of the earliest to be developed in the suburban extension of Cardiff in the 1850s. Properties in this street are of a distinctly grander character and more decorative in appearance than those which followed to the north into central Plasnewydd. The housing here is the closest in Plasnewydd to the city centre, the Newport Road campus of Cardiff University and the many offices lining Newport Road.

The area contains a mix of commercial, educational and residential buildings. Private renting accounts for around 60% of the tenure of households in this area (Census, 2011). This area has a relatively high proportion of HMOs and properties subdivided into flats. Council tax student exemption records show that there is a relatively high number of student properties within the area.

Key Characteristics

- Long/channelled street views - Predominantly substantial two and three storey terraces or pairs of semi detached villas, built predominantly c.1850‐70. - Mix of commercial, educational and residential uses, with the latter concentrated in The Walk, East Grove and West Grove. - Relatively wide building plots of 5‐10m with more generous front gardens bounded by walls/ railings/ hedges. - Consistent use of limited materials: distinctive local pennant stone facing, stone dressings, brick, render and slate. - Rhythms and visual interest created by bay windows, gables, chimneys and brick/stone detailing. - The character is enhanced by mature trees.

Visual Impact Assessment

Within Area O, a total of 13 letting boards were in position in July 2014. Due to the mix of uses in the area, this is a relatively low number when assessed by the number per hectare, however, the visual impact of clusters of boards within The Walk and East Grove was considered to be harmful to the special character of the conservation area.

Image 8.26 The Walk

33 8.19 Area P – Wordsworth Avenue to Oakfield Street

Character Appraisal

The area contains the two conservation areas of Wordsworth Avenue and Oakfield Street, together with other late Victorian / Edwardian residential streets of varying plot widths. As with all conservation areas, the distinctive character of these sections of Area P is created by a combination of a distinctive quality of place; the presence of landmark buildings; high quality local or unusual materials; high quality architectural detailing; and high quality hard and soft landscaping. The area also contains a small area redeveloped in the 1960s (around Shelley Gardens and Oxford Street), where the historic terraced street pattern has been lost. Council taxt studen exemption records show that there is a low number of student properties within Area P. The area has a higher proportion of social rented households, 25% compared to the Ward average of 11% (Census, 2011).

Key Characteristics

- Long/channelled street views - Predominantly uniform two storey terraced housing blocks, built predominantly c.1860‐1900, with narrow building plots of 4‐6m with small forecourts bounded by walls/railings/hedges. - Larger two ½ and three storey semi‐detached/terraced properties at Wordsworth Avenue, Oakfield Street and Partridge Road, many of which are subdivided into flats or HMOs, with wider building plots of 7‐10m and more generous front gardens. - Consistent use of limited materials: stucco rendered walling with ashlar scoring in some streets, distinctive local pennant stone facing, stone dressings, brick and slate. - Rhythms and visual interest created by bay windows, gables, chimneys and brick/stone detailing. - The character of several streets is enhanced by mature trees.

Visual Impact Assessment

Within Area P, a total of 30 letting boards were in position in July 2014. This is a relatively low number when assessed by the number per hectare, however, the visual impact of boards within Wordsworth Avenue or Oakfield Street conservation areas is considered to be harmful to their special character. To ensure that a consistent approach is applied throughout the residential area of the ward, it is considered necessary to include these streets within the Direction Area.

Image 8.27 Wordsworth Avenue Image 8.28 Oakfield Street

34 8.20 Area Q – Claude Road to Timbers Square

Character Appraisal

The overall layout in the western part of this area is slightly more generous in terms of road widths and plot sizes that in the heart of Plasnewydd. Until recently this area had been characterised by a relatively high proportion of households in owner occupation, 42% in 2001. However the private rental sector in this area has grown from 30% in 2001 to 42% in 2011 (Census).

Key Characteristics

- Long/channelled street views - Predominantly two storey terraced housing blocks, built predominantly c.1870‐1900, with narrow building plots of 4‐6m with small forecourts bounded by walls/railings/hedges. - Some semi‐detached properties with wider building plots of 7‐10m and more generous front gardens on Princes Street, Roath Court Road, Timbers Square, Newport Road and Albany Road. - Consistent use of limited materials: distinctive local pennant stone facing, stone dressings, brick, render and slate. - Rhythms and visual interest created by bay windows, gables, decorative open porches, chimneys and brick/stone detailing. - The character of several streets is enhanced by mature trees.

Visual Impact Assessment

Within Area Q, a total of 57 letting boards were in position in July 2014. Although much of this area was unaffected by letting boards, concentrations causing particular harm to visual amenity were evident in Claude Road, Claude Place and Connaught Road: each with around one board every 10‐15m. The changes in tenure profile in the rest of the area considered likely to continue towards higher proportions of private renting, which is likely to increase the number of letting boards. To ensure that a consistent approach is applied throughout the residential area of the ward, it is considered necessary to include these streets within the Direction Area.

Image 8.29 Claude Road

35 8.21 Area R – City Road and Albany Road

Character Appraisal

This area covers a similar boundary to the designated City Road and Albany Road/Wellfield Road District Shopping Centres. Properties within this area are almost exclusively commercial at ground floor either in converted residential terraces or in several larger purpose‐built units. Many of the converted buildings have privately rented residential accommodation above.

Key Characteristics

- Predominately relatively narrow (5‐6m) plots of two storey residential buildings converted to commercial uses and forming the City Road, Albany Road/Wellfield Road District Shopping Centres. - Ground floor shop front build‐outs within former forecourts.. - Many units with residential accommodation above. - Some larger purpose‐built commercial units and places of worship. - No green spaces and limited roadside vegetation.

Visual Impact Assessment

Within Area R, a total of 17 letting boards were in position in July 2014. These boards primarily related to flats above commercial units.

The number of boards was relatively low when compared with the rest of Plasnewydd, however to ensure that a consistent approach is applied throughout the ward, it is considered necessary to include these streets within the Direction Area.

Image 8.30 Albany Road

36 9.0 Future Enforcement Strategy

9.1 By re‐investing power in the Local Planning Authority, a Regulation 7 Direction would allow the City of Cardiff Council to control the display of residential letting boards effectively in order to improve local visual amenity.

9.2 It is not the intention to have an absolute ban on letting boards in the Direction Area, but to limit their impact through new guidance for their acceptable display, with the backing of a statutory Direction to ensure compliance and allow for effective enforcement. Whilst the main stakeholders recognise the need for control, most also accept the need to allow landlords to advertise their properties. A copy of the proposed draft guidance is attached at Appendix 12. Following consultation on the version at Appendix 8, the revised guidance has taken account of concerns regarding poster‐type displays in windows and includes a gazetteer of the streets proposed for control.

9.3 A Regulation 7 Direction would need to be supported by robust monitoring and enforcement. No additional expenditure is proposed in order to expand the capacity of the Council’s enforcement team. Any increase in work demands will therefore need to be met by existing resources. In order to ensure that these proposed arrangements are delivered effectively from the implementation ‘start date’, it will be necessary to develop a new enforcement approach which will need to incorporate the use of the Council’s wider resources.

9.4 Any such boards displayed after the Direction is made, which are considered contrary to the proposals contained in the guidance note, would be unauthorised and therefore constitute an offence against which action could be taken. The success of the statutory controls supported by guidance approach taken by other LPA’s, for example Leeds, Charnwood and Nottingham, leads the Council to anticipate that as a result of concerted and significant enforcement action and monitoring, in the short term, the behaviour of Letting Agents will change in line with the approach presented by the guidance note – resulting in reduced enforcement demands in the medium term. However, in order to support the proposal and to address the considerable harm identified in this report, the City of Cardiff Council will be committed to seek prosecutions via the courts for boards that are contrary to the new guidance.

10.0 Impact of the proposed Regulation 7 controls on economic development and existing businesses

10.1 Planning Policy Wales (Edition 7 ‐ July 2014) sets out that the planning system should support economic and employment growth alongside social and environmental considerations within the context of sustainable development (paragraph 7.1.3). The key businesses which will be affected by the proposed direction are landlords and estate agents, whose views were sought during the development and consultation process. In addition to the responses supporting controls the City of Cardiff Council have considered the impact that the proposed restrictions will have on the business operation of landlords/agents and on tenants seeking accommodation.

10.2 The Office of Fair Trading report “Home Buying and Selling Market Study, Survey of Estate Agents, February 2010” (Appendix 13) asked estate agents what was the most important method for attracting sellers to their agency. The top three were local reputation, quality of service and access to property portals such as Rightmove. Fewer than 20% rated boards as very important for attracting customers. When asked about the proportion of eventual sales that originated from property portals, 37% of agents thought that over 50% originated from property portals.

10.3 The HomesAlone.co.uk website conducted a UK Estate Agent and Solicitors/Conveyance survey in April 2011. (Appendix 14) They asked a range of questions including whether their business model changed in the past five years. 86% said that it had and this was due to changes in the market and the internet. 34% said that main sources of new clients were the internet and online portal sites with referrals

37 generated form through a local presences the next largest at 31%. Only 8% of respondents thought that local press advertising was good value for money.

10.4 Respondents to the public consultation who completed the free text sections stated that many people now use the internet and that boards are not relevant when seeking a property. Only 10% of the comments received stated that the boards helped with finding properties. The majority of the remaining comments related to the boards being ineffective (29.6%), that online searching was more effective (29.1%), that going direct to letting agents was more effective (11.5%), that the boards were merely advertising for agents (10.3%) or that the boards were often out of date (7%).

38 11.0 Conclusions

11.1 The proposed Regulation 7 Direction to require express consent for letting boards that do not meet the criteria in the proposed guidance would be efficient, effective and simple in conception and operation. Residents, landlords and agents would have a clear understanding of the new regulation. As a result breaches would be easier for residents to report and enforcement would be quicker and simpler to progress. The removal of non compliant advertisements would build confidence in the community resulting in an increase in reporting of offences and landlords/agents compliance would rise as offences are dealt with efficiently and effectively.

11.2 The evidence from the boards survey shows that there are high numbers of letting boards in the proposed area with over 50% of properties in some streets with boards on display. The high number of boards combined with unique property and street characteristics, located in long straight streets, with many fronting directly onto the footpath and with little greenery to break up sightlines, results in the boards being a prominent feature of the streets. The removal of conventional letting boards would clearly improve the visual amenity of the area.

11.3 The Council has contacted landlords/agents to try and tackle the impact of the boards with a proposed Voluntary Code, however due to the lack of positive response the proposal was not put in place. Enforcement action has also been undertaken, but the Council’s ability to reduce the number of boards is limited. The action taken by the Council over the last five years has by these methods had little impact on the numbers of boards. The introduction of a Regulation 7 Direction is considered to be the only viable option available to the Council to control the impact To Let boards are having on the area identified.

11.4 Consultation was undertaken on the proposal to restrict letting boards, with overwhelming positive support for action (88%). Almost nine in ten (87%) respondents to the public consultation considered that letting boards harmed the appearance of the area.

11.5 The impact and views of the landlords and agents whose business could be affected by the proposed control have been considered, however it should be noted that the overall response rate (7%) from the targeted consultation was very poor, with just 13 letting agents responding from the 173 consulted. Of those responding to the landlords and agents’ survey, 77% were in support of the Council taking action to control letting boards.

11.6 Taking all of the above into account, the Welsh Planning Minister is respectfully requested to issue a direction under Regulation 7 of the Town and Country Planning (Control of Advertisements) Regulations 1992 to restrict deemed consent for the display of advertisements under Schedule 3 Part 1 Class 3A relating to the letting for residential uses for streets in the area shown at Appendix 1 and Appendix 12 of this document.

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Strategic Planning, Highways, Traffic and Transportation City of Cardiff Council Room 223 County Hall Cardiff CF10 4UW