2 APPLICATION NUMBER: 12/07690/CAC APPLICANTS NAME(S): Mr Phil Collins SITE ADDRESS: Former Mid Hospital Road LD3 0EF GRID REF: E: 316190 N:233086 : Talgarth DATE VALIDATED: 28 March 2012 DECIS ION DUE DATE: 23 May 2012 CASE OFFICER: Mr Rhodri Davies

PROPOSAL Mixed use redevelopment of the site for housing, employment and community uses including 76 number residential units (C3), 5 live work units (B1/C3) and 18 number 1-2 bed retirement apartments (C3), Care/health facility (up to 70 bed apartments) (C2/D1), conversion of the front 'Admin Block' into 4 apartments (C3), conversion of retained chapel into multi-use community building (D2) and offices (B1), conversion of retained mortuary into office space (B1), internal roads and paths, new allotments, creation of new cricket pavilion, access road, car park and tennis courts, landscaping and public open space, sustainable drainage systems, de- construction (demolition) of the existing former ward buildings and associated works, services and utilities. ADDRESS Former Mid Wales Hospital, Hospital Road, Talgarth

CONSULTATIONS/COMMENTS Consultee Received Comments

Brecon Beacons Park The proposed development adversely affects Society the Talgarth Conservation area and is contrary to UDP Policies Q17 and 18, the policies relating to Conservation areas in the deposited LDP and the guidance given in PPW Chapter 6.5.16 – 6.5.23. These policies suggest that new buildings in Conservation Areas should only be permitted where they preserve or enhance the character of the area and that demolition should only be permitted where there is the strongest justification. The developer proposes to demolish the majority of the important buildings on the site. The proposed new buildings would not enhance the buildings to be retained. For instance those proposed to be closest to the Administration building would not give it sufficient prominence and would tend to diminish it, being mainly of three stories. The lay out of the buildings does not reflect the distinctive layout of the original Hospital site. The applicant stresses that the new houses are designed to reflect the local vernacular but has chosen to relate them to houses in Talgarth and not to the historic buildings on the site.

P.S. We note that the developer makes great play of the dangers posed by asbestos on the site if the buildings are left to deteriorate further. Since there has not been a proper structural survey one is unable to determine the truth of this suggestion and it leaves the possibility that the suggestion is scaremongering to encourage people to accept the current proposal. We suggest that a proper structural survey by a reputable firm should be insisted on. CADW Ancient 16th Jul 2012 Judith Alfrey, Cadw's Head of Regeneration and Monuments Conservation has commented as follows:

The buildings at the former Mid-Wales Hospital have been assessed on two occasions, but were felt to fall short of the high standard necessary for listing. They were assessed as part of a thematic survey of NHS hospital buildings which was undertaken to provide certainty about the listability of buildings on the NHS estate, and again when the community of Talgarth was surveyed. As part of the thematic exercise, some 230 structures on 35 sites were assessed for listing, and 42 structures on 11 sites met the listing criteria and were listed. These sites now set the bench-mark for listing.

Amongst the mental which have been listed, the earliest and most architecturally distinguished is the North Wales County Asylum at Denbigh (1846-8 by Thomas Fulljames), which is listed at grade II* in recognition of its importance as a pioneering example of early Victorian asylum architecture. Also, from first generation of asylum buildings, Penyfai Hospital Abergavenny is listed grade II as one of the best C19 hospital buildings in Wales. The surviving original sections of 1851 are also by Fulljames, though with some remodelling by Giles, Gough and Trollope in the 1880’s. By the early twentieth century, new thinking on hospital planning is best reflected in Wales at which is a close contemporary of the Mid Wales hospital, being built between 1902-1908. Like the Mid Wales hospital, Whitchurch uses the principle of echelon planning. It is considered to be the best example in Wales using this plan form, and is of exceptional architectural quality and character. When built, it was amongst the most modern of its period, offering provision for the latest treatment methods, and including facilities such as a large recreation hall.

Listing requires selectivity, particularly for buildings after about 1840, where it is necessary to identify the best example of particular building types, selecting only buildings of definite quality and character. For twentieth century buildings, key examples are identified. As far as hospitals are concerned, Whitchurch Hospital has been selected as defining the standard for early twentieth century buildings.

Although the Mid Wales hospital does not meet the exacting standard required for listing, this should not be taken as meaning that it is of no value or interest, and its inclusion within the Talgarth Conservation Area would seem to be an acknowledgement of its local importance. Although when compared with Whitchurch Hospital, the buildings at Talgarth are stylistically conservative, they constitute a near- complete group in a harmonious style with good quality detailing (particularly in the use of materials), and a coherent plan: retention of its original echelon plan-form is probably the principal historic interest of this complex of buildings and although we have judged Whitchurch to be the key exemplar of this significant plan type, the buildings at Talgarth represent a good demonstration of similar principles. The relatively complete survival of the complex at Talgarth also enabling the buildings to demonstrate approaches to mental health care in the early twentieth century.

NP Head Of Strategy 17th Aug 2012 The Adopted Local Plan forms part of the Policy And Heritage Development Plan for the National Park area, however the Authority has approved the UDP (March 2007) for development control purposes and affords it greater weight than the Local Plan, since it is more recent and relevant. It has been through all the stages necessary for greater weight to be attached to it save for adoption due to the single issue of safeguarding sand and gravel reserves.

The Local Plan allocated the site for redevelopment/refurbishment with a policy indicating the desirability of finding alternative appropriate employment uses for the site. In the UDP the site is allocated for mixed use/commercial. Neither Plan specifies the proportion of different uses that would be expected in terms of the mix of uses on the site.

The Mid Wales Hospital Planning Brief produced by Knight Frank in 1997 and adopted as Supplementary Planning Guidance to the Local Plan in 1999 while referencing the Local Plan suggests that a mix of uses would be more appropriate given, in their opinion, the unlikely prospect of one single employment use being found for a site of that scale. It does not specify the type or proportion of mixed uses to be considered on the site. The Planning Brief was carried through to the Authority Approved UDP in March 2007.

The Talgarth Planning Brief was approved as guidance to supplement the UDP in December 2008. It sets out broad land use and design principles to act as a framework for future development and investment in Talgarth and the Former Mid Wales Hospital. The brief indicated that,

"The Mid -Wales Hospital site has huge potential. The site has the benefit of new owners and is allocated in the UDP as a mixed use site. It is imperative that the potential is realised and any development is linked to and provides benefits for the wider community. - It is an important site for roosting and hibernating lesser horseshoe bats (and some other bat species). - There is also the opportunity in any development proposals to explore the site's capacity to supply combined heat and power to itself and to the town through wood burning boiler systems. - The National Park Authority (NPA) will negotiate with the new owners of the site to produce an updated development brief and these issues can be explored in more detail. "

In 2010 the Authority undertook a Conservation Area Appraisal of Talgarth Conservation Area and confirmed an extension of the boundary to include the Former Mid Wales Hospital in 2011. As a result it is considered that the level of detail that will need to be submitted in order for the planning application and conservation area consent to be validated and determined means, an updated development brief is unnecessary.

The main (though not exclusive) National policy considerations in determining the application are as follows;

The Town and Country Planning Actc1990 Section 54 A specifies that planning applications should be determined in line with the development plan unless material considerations indicate otherwise. Chapter 4, Planning for Sustainability of Planning Policy Wales (Welsh Government, Edition 4, February 2011) emphasises that planning polices and proposals should, in promoting sustainable development here should be a "preference for the re-use of suitable previously developed land and buildings, wherever possible avoiding development on greenfield sites" (4.4.2). The former Mid Wales hospital site is a ‘previously developed land' and is allocated accordingly for redevelopment for mixed use in the UDP. The current proposal is therefore acceptable in principal.

In terms of the details of the proposal I have the following policy observations to make; Neither the UDP, the 1997 Planning Brief nor the later Talgarth Planning Brief, specify the mix of uses. The Authority, through these documents however is concerned to enable development that benefits and is well related to the local area and should provide some level of employment generating uses particularly given the history and importance of the site to Talgarth in this regard. The Authority recognises that an element of housing will be needed to ensure any scheme is viable and likewise that a wholly employment led scheme is unlikely. The UDP Inspector in her report accepted the mixed use allocation on the site "but a significant amount of residential development, unrelated to the primary commercial uses on the site, would be contrary to the strategy and aims of the UDP" (March 2006). To ensure the delivery of the employment generating uses specifically the Rehabilitation and Enablement Centre (TREC), the proposals for the Chapel and the mortuary building, I would want to see the delivery of those elements of the scheme tied, at appropriate stages, to the delivery of the housing via a S106 agreement.

In terms of the detail, the main polices that the application will need to be considered against (amongst others) are Policy G3, Policy ES29, Policy Q17 (which will be considered by the Senior Heritage Officer) and Policy Q5 (which will be considered by the Conservation Officer)

In terms of Policy ES29, the UDP requires a minimum of 20% affordable housing where there is an identified need. It is accepted that there is a general need for affordable housing across Powys. The proposal for 6 dwellings out of the 103 to be affordable housing does not accord with this Policy. Furthermore the proposed provision is 6 units offered at 60% market value. Discounted market housing is not considered to be affordable housing for the purposes of the UDP. The proposal therefore is contrary to Policy. I understand the matter is currently with the District Valuer to consider the viability of this element of the scheme. For the purposes of the UDP live/work units are considered to be those units where at least 51% of the floorspace of the property is given over to the ‘work' element. This would then be tied via a S106 Agreement to any permission. The proposal for 5 live/work units where approximately 1/3 of the floorspace of each is for the ‘work' element does not align with this policy position. Despite consistent advice from the Welsh Government that emerging LDP's should be given little if any weight in determining planning applications until such time as the Inspector Report is produced, we need to have due regard to the Inspectors recommendation on the Cwrt Y Gollen appeal. In coming to his view he stated that irrespective of the status of the site in the UDP:

"The situation now is very different. The LDP spatial strategy and housing provision proposals which do not carry forward the UDP SS5 allocation at Cwrt y Gollen are based on newer population projections for the National Park over the Plan period, coupled with a settlement assessment process directed at supporting the vitality of communities whilst ensuring that the special qualities of the Park are maintained and enhanced. Whilst the robustness of the LDP strategy has yet to be examined, this is due to take place shortly. I consider that it would be unduly prejudicial to the LDP and the strategy it embodies to permit such a large quantity of housing in this location in advance of the comprehensive and detailed consideration of the Plan that the forthcoming examination will provide." (PINS Report APP/P9502/A/10/2132455, July 2011).

I consider we would have to take a similar view in relation to the proposals for this site. Whilst the proposals here are not for the same number of houses as at Cwrt Y Gollen, there are parallels. Namely that a significant number of dwellings are being proposed on a single site and that the site itself is not being carried forward into the LDP. To permit the proposals could therefore, in my view, be prejudicial to the strategy of the LDP.

NP Senior Heritage 3rd July 2012 This site is of a specific special character within the Officer Building conservation area made of the former hospital Conservation buildings.

These buildings are formed into separate courtyards so that control of various types of patients was easier but created a more open feeling than the previous design of asylums.

This building shows a distinctive change and development in how people considered to be have a mental illness was treated. The whole setting reflects this with the wide open parkland feel, entertainment and rehabilitation facilities for patients came into its own during and after the WWI.

The distinctive style of architecture, although somewhat foreboding now, was of a high quality and using superior materials.

Much of the layout and architectural qualities survive and provide the main character of this part of the conservation area.

The design of the proposal does nothing to preserve or enhance the character of the conservation area in anyway. No attempt has been made to include the layout plan even in the street plan let only recognise the importance of the buildings as they are now.

Although the designs of individual buildings proposed have some merit it is the layout and lack of cogent justification for wholesale demolition that lets this applications down.

The lack of an historical analysis of the site and the importance of the buildings to the town and to the character of this part of the conservation area undermines the proposals.

Although it is recognised that the buildings are difficult to assess at the present time the condition survey shows that there is a problem with dry rot within the building. However with the amount of ventilation there is in the building this may be of a localised nature. The stone wall show no signs of movement which one would expect if the timber floors and roof structure had lost their structural integrity due to dry or wet rot.

There is no attempt to cost the works required to bring the building back into a good state of repair and to convert it into a suitable new use. The cost of demolition will be significant as well as the removal of the debris from site. This should be factored in when considering the cost of redevelopment. It is always more sustainable from an energy perspective to retain buildings and convert them than start again from new. This should also be factored in as a cost implication.

I had expected that the design and access statement would at least give some indication of the process regarding deciding to demolish and not retain the buildings. This argument must be clearly made to justify the wholesale clearance of the site.

These are not exhaustive comments as it would run to pages but gives reason for the recommendation of refusal on Conservation grounds. Talgarth Town 26th Apr 2012 The above Planning Application is dated 18 th April Council 2012 and received by me at 6pm on 24 th April 2012.

However, we note that the Public Consultation has an advertisement in the & Radnor Express would set the consultation from today.

We would also ask you to note that our next Town Council meeting is not scheduled until Wednesday 9th May and in view of the complexity of this Planning Application it will take a few days beyond the meeting in which to compile a response.

Can you please confirm the current Consultation dates and by when you are expecting responses.

Talgarth Town 28 th May, 2012 Talgarth Town Council broadly welcomes and Council supports the proposal to redevelop the site of the old Mid Wales Hospital. Currently the site is dangerous, neglected and hardly befitting a conservation area in the national park. The redevelopment of the site is long overdue.

Buildings that define the character of the site should be retained where ever possible though it acknowledged that may not always be possible. The main administration building is one of only three current building that is going to be retained. To maintain the character of the site it would greatly enhance the site if the building stood more out as prominent architecture.

Deconstruction/ Demolition B1 The Town Council would prefer to retain as many buildings of character as is possible. We do however understand that there are restraints as some building may be damaged beyond repair due to vandalism and neglect. Talgarth Town 3rd May 2012 The proposal is of great signi ficance to the residents Council of Talgarth therefore it is essential that the Council give the plans due consideration and allow enough time to discuss all the relevant aspects.

Unfortunately this planning submission has arrived at a time where the Council’s normal operation is somewhat disrupted. On the 3 rd May the local elections take place and although Talgarth Town Council will not undergo elections four of the twelve current council members will change.

The first meeting after the elections, on the 9 th May, is the AGM of the council where the new chair and deputy chair are elected together with the formation of the various sub committees, including planning. With an already packed agenda it is felt that insufficient time will be allocated to discuss the application and give it the full deliberation that it deserves.

Following this meeting the four new council members would have to understand the plans to be able to deliberate and then the council would have to formulate a response. The Town Council would therefore request a possible extension of the closing date for responses for up to two weeks from the current closing date of 18 th May 2012. CONTRIBUTORS P H Pugh, House, Talgarth Roger And Angela Cowlin, Sunnybank, Penbont Road, Talgarth Francis Morris, Grovelly Cottage, Penbont Road, Talgarth Craig Robinson, 166 St Davids Street, Brecon Antonia Spowers, Genffordd Isaf Bach, Talgarth Tracy Richard Sharman And Gillick, Hilton House, Penbont Road Marcus Binney, SAVE Britain's Heritage, 70 Crowcross Street David Walker, 22 Inverleith Row, Edinburgh Jeremy Taylor, 14 Friars Quay, Norwich Simon Bradley, 47 Bedford Square, William Powell Virginia Brown J M Rule, Merlin House, Church Street, Talgarth Mrs L Lewis, Glan Usk , Llanfrynach Susan Barrett, 18 Kenilworth Close, Belmont Penny Hallas, Glasfryn, Llangattock John Tushingham, Penbryn, Hospital Road, Talgarth Mrs M Mullan, 2 Hospital Villas, Hospital Road, Talgarth John Dunne, Tegfan, Hospital Road, Talgarth Mrs K E Tanner, Groverly House, Penpont Road, Talgarth Mr Paul Hanson, Ty Craig, Church Street, Talgarth Niel Bally, Taflod, Wernfawr Mr Nicholas Jackson Lydia Kiernan, The Old Court House, Bell Street, Talgarth Dylan Jones, Lower Pen Y Bryn, Hospital Road, Talgarth Christopher Twigg, Church House, Church Street, Talgarth Peter Evans , Constituency Office, 4 Watergate, Brecon Elaine And Peter Starling, The Elms, Bronllys Road, Talgarth Cook Mr P Murphy, 137A Crouch Hill, London Mr A J Morrell, Apartment 9, Ivy House Rachel Murphy, 137A Crouch Hill , London Bob Martin, Sunnybank, Trefecca Susan Morrell, Chancefiield House, Talgarth Mr Niel Bally, Taflod Wernfawr Talgarth Brecon Powys, Mr Mark Young, 3 Upper Hospital Villas, hospital road, Talgarth D G Parry, Swyn Yr Enfys, Upper Brechfa Vanessa Pugh, 17 Woodlands Avenue, Talgarth Niel Bally, Taflod, Wernfawr Niel Bally, Taflod, Wernfawr Mr Roger Williams, 4 Watergate, Brecon J Ashford, Forest Mill, Pengenffordd Mrs D Tame, 3 Parc Y Berllan, Bronllys Mr L Dodds, 8 Queens Avenue, Talgarth Mrs P A Banford, 8 Queens Avenue, Talgarth Mrs Mary Davies, 8 Kings Drive, Talgarth B Gwynne, Coronation House, The Square B Summerfield, Firtref Cottage, Penbont Road, Talgarth I Gwynne, 1 Powells Terrace, High Street, Talgarth D Boukett, Pentre Jock, Llandewi Fach J Cathryn Alae, Tyr Bryn, Church Street, Talgarth Mrs V M Clarke, Court Cottage, Penbont Road, Talgarth Stefan Fec, Primrose Pharmacy, Garth House Stefan Fec, 25 Orchard Street, Llanfaes Stuart Cardell, 9 Llanwenarth Road, Govilon M Castle, Coleg House, Trefecca Nathan Lewis, 34 West Fields, Talgarth Terrence G Lewis, 33 Woodlans Avenue, Talgarth Pauline Lewis, 33 Woodland Avenue, Talgarth Carl Lewis, 33 Woodland Avenue, Talgarth Mr David Cooke, 65 Wyeside Gardens, Hay-on-Wye

NEIGHBOUR/THIRD PARTY RESPONSE SUMMARY The majority of the objections to the redevelopment of the site are included in the report for the corresponding full application for the redevelopment of the site.

However, the following comments have been received in relation to the proposed demolition of the existing buildings on the site:

- The Building Condition Survey highlights the fact that there is no real justification for the planned demolition. - Demolition of the buildings should be kept to a minimum as they are an important part of the heritage of Talgarth. - The former Exe Vale Hospital outside Exeter fell into a very serious state of decay and was nonetheless successful rescued ad converted as a mixture of flats and houses. - The Ballroom should be retained as it was very much a part of the community. - An independent structural engineer’s assessment should be commissioned by the BBNPA before any demolition works are approved. - Non-compliance with policies Q17 and Q18. - The scheme goes against the reasons for including the site in the Talgarth Conservation Area and Appraisal. - The buildings should be listed. - The Design and Access Statement states that the building condition survey has confirmed that the buildings are no longer structurally or financially viable for retention but the building condition survey states that a structural survey has not been undertaken.

SAVE Britain’s Heritage has provided a letter dated 25 th May, 2012 as follows: “We have been carrying out a considerable amount of research on Talgarth Hospital contacting a series of experts in the history of architecture and hospital design. In our view, this has produced new information of a substantial kind which we feel merits a new application for the buildings to be listed. I am attached various letters supporting this case. The first is from Professor David Walker, who for many years was in charge of the compilation of all the lists of listed buildings in Scotland. Subsequently, he was an architectural advisor to the Heritage Lottery Fund and the National Memorial Heritage Fund and he has also been the principal compiler of the remarkable online Dictionary of Scottish Architects which has numerous cross references to buildings and architects elsewhere in the .

Professor Walker draws a series of important comparisons with hospitals in Scotland which are listed and concludes that in Scotland a building of Talgarth’s quality would certainly be listed.

A second letter comes from Dr Jeremy Taylor who has written the most important history of the architecture of mental hospitals and he again points to important innovative features in the layout of the hospital buildings. Both he and Professor Walker emphasise that the architects, Giles, Gough and Trollope were one of the leading practices designing these hospitals, and therefore their work is of special interest.

We have also heard from Simon Bradley, the general editor of Pevnser series of county volumes covering England and Wales. Rob Scourfield, who is revising the Powys volume has described the hospital as ‘an incredibly complete site’. Simon Bradley has written the Westminster volume of the Buildings of England which covers some of Giles, Gough and Trollope’s most important works. Their work in London, for which substantial budgets were available, is of exceptional quality, both in terms of design and materials and imaginative detailing. Talgarth is equally built to a very high standard with very good use of materials and excellent masonry detail.

The letters mentioned are attached. Quite apart from the architectural merits of the design, the buildings we submit also merit listing on group value. Clearly this is a very extensive composition of linked buildings designed and built to harmonise with each other and remaining remarkably complete. Its fine situation on the edge of the National Park looking out over fields and hills allows the whole group of buildings to stand well and be appreciated from many different points of view.

In our view, the submissions we have provided make it irrefutably clear that Talgarth Hospital is of both special architectural interest and special historical interest. It would certainly be listed in Scotland.

All these submissions underline the fact that your council took the right decision in extending the conservation area to include the Talgarth Hospital buildings. As the hospital buildings comprise the totality of the extension it would clearly make a nonsense if all the buildings which give character to the conservation area (as well set out in your appraisal) to be demolished.

In our view it is of the utmost importance that the buildings are retained and the means are found to refurbish them, as this is incontestably the best way of conserving and enhancing the character of this part of the conservation area. The excellent conversion of the formal mental hospital at Abergavenny into residential use is a good local example of what can be achieved.”

William Powell, County Councillor for Talgarth/Assembly Member for Mid and West Wales has commented as follows:

While I am currently involved in considering a live petition on Built Heritage & Conservation on the site, in my role as Chair of the Assembly's Petitions Committee, it would not be appropriate to comment in detail on that aspect.

However, in determining this application, I would ask that BBNPA pay due regard to submissions from Save and other authorities on conservation matters. Similarly, the Brecon Beacons Park Society points out the need for a full structural survey, which I assume would be a requirement for extensive demolition in a recently declared Conservation Area.

Kirsty Willams AM has commented as follows:

As I understand it, the application must be tested against policy as it relates to conservation areas. Whilst I acknowledge that some existing buildings are to be kept, the plans do represent a significant demolition of existing structures. Again I would question the compatibility of the proposals against BBNP policy and indeed Welsh Government guidance that would I believe place a much stronger emphasis on conserving existing buildings and ensuring that any new development was sympathetic to the vernacular of the site.

Roger Williams MP has commented as follows:

The site still retains many fine vernacular buildings that are in the conservation area, the proposals to demolish many of these buildings (I am pleased that the mortuary is to be retained) will need much consideration before being agreed to either in part or as a whole. I understand the Petition Committee of the National Assembly for Wales has made comments on this matter.

RELEVANT POLICIES G3 Q17 Q18 LPG3 LPCB5 LPCB6

PLANNING HISTORY App Ref Description Decision Date

12/07922/FUL Mixed use redevelopment of the site for housing, employment and community uses including 76 number residential units (C3), 5 live work units (B1/C3) and 18 number 1-2 bed retirement apartments (C3), Care/health facility (up to 70 bed apartments) (C2/D1), conversion of the front 'Admin Block' into 4 apartments (C3), conversion of retained chapel into multi-use community building (D2) and offices (B1), conversion of retained mortuary into office space (B1), internal roads and paths, new allotments, creation of new cricket pavilion, access road, car park and tennis courts, landscaping and public open space, sustainable drainage systems, de-construction (demolition) of the existing former ward buildings and associated works, services and utilities.

OFFICER’S REPORT

INTRODUCTION

This application seeks Conservation Area Consent to demolish all of the buildings within the former Mid Wales Hospital complex apart from the Administration Building, the Chapel and the Mortuary to allow for the Mixed use redevelopment of the site for housing, employment and community uses including 76 number residential units (C3), 5 live work units (B1/C3) and 18 number 1-2 bed retirement apartments (C3), Care/health facility (up to 70 bed apartments) (C2/D1), conversion of the front 'Admin Block' into 4 apartments (C3), conversion of retained chapel into multi-use community building (D2) and offices (B1), conversion of retained mortuary into office space (B1), internal roads and paths, new allotments, creation of new cricket pavilion, access road, car park and tennis courts, landscaping and public open space, sustainable drainage systems, de-construction (demolition) of the existing former ward buildings and associated works, services and utilities.

Section 74 of the Planning (Listed Buildings and Conservation Areas) Act 1990 states that “A building in a conservation area shall not be demolished without the consent of the appropriate authority (in this Act referred to as “conservation area consent”).”

The scheme for the redevelopment of the site is the subject of the corresponding full planning application (12/07922/FUL).

RELEVANT HISTORY

Although there are a large number of historical planning applications relating to the site and surroundings, only the ones outlined above relate closely to the application proposals for the comprehensive redevelopment of the site that is currently before the BBNPA.

The site was acquired in the 1890’s as a County Asylum for Brecon and and opened in 1903. Further additions were made to the complex including a new treatment block in 1965 and an Occupational Therapy Department in 1971.

The site operated as a mental healthcare facility for the County of Powys until changes in mental healthcare such as the Government’s ‘Care in the Community” programme meant that facilities such as these were no longer appropriate. The Secretary of State for Wales announced that the Hospital would close in 1999/2000. Since the closure of the hospital the site has accommodated some small scale business ventures including a pie-making business within the former Mortuary building and other businesses within the Black Mountain Business Park to the north-west of the site.

In 2010 the Authority undertook an appraisal of the Talgarth Conservation Area which recommended an extension of the boundary to include the Former Mid Wales Hospital site. The relevant paragraph in the Talgarth Conservation Area Appraisal (December, 2010) states:

“The financial realities of mixed use development, access considerations and the requirements of the planning system will undoubtedly determine the future of the site but there is a need to secure the remaining buildings and to ensure that any development is of the highest standard, respecting the handsome buildings and their setting in an attractive landscape. It is conceivable that some or all of the original hospital buildings should be listed, on the basis of the quality of buildings like the main entrance block and the chapel and as a recognition of the historic building use and layout. This kind of mental/isolation hospital complex is a very characteristic late C19-early C20 development, providing a reasonably humane environment and facilities for sport and rehabilitation. In the last twenty years, many similar sites have been demolished or altered beyond recognition as the NHS has disposed of much of its estate. Whilst listing may be reconsidered, it is desirable to provide some sort of increased protection of the buildings and landscape and to inform future planning decisions. It is recommended that a conservation area is designated around the hospital complex, the ancillary buildings, Chance Field, the Waun Fawr group and a reasonable portion of the grounds.”

The recommendations were confirmed in 2011. The applicant purchased the hospital site in 2010.

SITE DESCRIPTION

The application site is located approximately 800m to the south east of the settlement of Talgarth which is a historic market town at the north western foothills of the Black Mountains with a population of approximately 2000.

The site can be accessed via two unclassified county roads – Hospital Road to the south and Church Street to the north. A public highway passes through the site and to the north of the main complex of buildings which links the two unclassified roads.

The application site is located within the Talgarth community but lies outside the settlement development boundary of Talgarth as defined by the Brecon Beacons National Park Unitary Development Plan 2007 (‘the UDP’) and Local Plan 1999 (‘the Local Plan’). However, the site is defined as ‘Previously Developed Land Allocated for Mixed Use’ in the UDP under Policy SS5 of the UDP.

The former Mid Wales Hospital and surrounding parkland comprises 13.62 Ha of land and is located in the Middle Wye Valley Landscape of Outstanding Historic Interest (under Part 2 of the Register of Landscapes, Parks and Gardens) and is in close proximity to the Pwll y Wrach Site of Special Scientific Interest and local nature reserve.

The site also sustains a lesser horseshoe bat colony and several maternity roosts.

The site does not include any Listed Buildings but is within the recently extended Talgarth Conservation Area and is the subject of a number of Tree Preservation Orders.

The application site lies entirely within Zone A, as defined by the Development Advice Map (DAM) referred to in Technical Advice Note 15: Development and Flood Risk and is therefore outside the 0.1% (1 in 1000 year) annual probability fluvial flood outlines.

The site is surrounded by clusters of semi-detached and detached residential properties and open countryside/farmland beyond. It includes a number of buildings that were associated with the original hospital use of the site (such as an Administration Block, a Chapel, a Mortuary, Ward Buildings, Boiler Room and Chimney and the Grand Hall), the Victorian parkland setting, a cricket pitch and pavilion and derelict tennis courts.

In topographical terms, the site is located on a narrow plateau sloping gently from approximately 189m AOD in the southern corner to approximately 165m AOD in the northern corner of the site.

PROPOSAL

The application relates to the demolition of the majority of the former hospital buildings to allow the comprehensive mixed use redevelopment of the site with construction limited existing built footprint of the complex.

The majority of the existing buildings on the site are to be demolished apart from the Chapel, Administration Building and the Mortuary.

Residential Development

The redevelopment proposals includes residential development for 103 No. residential units made up of:

• 76 dwellings • 5 live/work units • 4 apartments within the former Administration Building • 18 retirement apartments

Based on the nett residential developable area of the site (3 Ha) the residential density of the scheme equates to an average density of 34 dwellings per hectare. A lower density rural farmstead approach is adopted along the periphery of the site to the south and south- east where the site interfaces with the open space/parkland and the surrounding countryside beyond. A village core/back lane development is proposed for the centre of the site and a high street with a more formal character is proposed to the northern section of the built development fronting the internal access road and the Chapel beyond.

The dwellings include a mixture of agricultural style buildings, rural dwellings, terraced houses and detached town houses. It is proposed to re-use the natural red sandstone from the demolished buildings and incorporate elements of render, stone quoins, brick chimneys for the woodburning stove flues, reconstituted slate roofs, timber frames and timber car ports with stone topped rendered walls for the less prominent boundaries.

Commercial Development/Community Buildings

It is proposed to convert the existing single storey Mortuary building to B1 office use and convert the existing Chapel to 110 sq. m. of B1 office use floorspace for small scale/start up businesses with the remainder of the floorspace being used as a multi-use community building for community based uses.

To the north-east corner of the site it is proposed to erect a two storey, 70 bed care/health facility (potentially a Talgarth Rehabilitation & Enablement Centre) which will provide specialist care for the management of pain for people injured in accidents, armed forces personnel and chronically ill patients and the rehabilitation of patients providing approximately 40 medical and care related employment opportunities.

Leisure/Recreational Facilities and Open Space

The existing but disused Cricket pitch and pavilion to the north-western corner of the site will be retained and enhanced through the provision of a new pavilion and an improved pitch and outfield and the facility will be handed over to the community to re-establish Talgarth Cricket Club who have not been able to find an alternative site in Talgarth.

The dilapidated tennis courts to the east of the cricket pitch will be refurbished and a new court will be added together with an allocated parking area. The cricket and tennis facilities are due to be provided by the beneficial occupation of the 25 th dwelling.

The graveyard surrounding the Chapel will be retained and reinstated as a formal Memorial Garden. An area of 0.12 Ha is designated for use as allotments by residents of the scheme with space for further plots if the scheme proves to be successful. A private communal amenity space will be provided to the east and south of plots 29-39 to offer additional communal space which can be used and managed by the relevant residents as an extension of their gardens. The grounds will be retained as informal public open space, a paddock and an arable field and will be enhanced through new landscaping, a pond, hedges, trees and planting of suitable species.

Powys County Council does not wish to adopt the public open space areas and leisure facilities so the applicant proposes to set up a management company to oversee the maintenance and management of these areas.

Access

The existing access and existing through road off Hospital Road will be retained and utilised as the main access into the site.

Phasing of the Development

The development has been broken down into five major elements:

• Deconstruction and remediation • Renovation and conversion of retained buildings • Laying of internal access roads • Provision of Infrastructure/foundations • Construction of the property superstructure

The overall programme of construction of the proposed development will last approximately 8 years. The development will generally proceed in a south-easterly direction with the buildings to the west of the site (excluding the ones that house the bat roosts) being deconstructed and redeveloped first.

APPRAISAL

This Conservation Area Consent application is considered against detailed policies G3 ‘Development in the National Park’, Q17 ‘Development affecting Conservation Areas’ and Q18 ‘Demolition in Conservation Areas’ of the UDP and detailed policies G3, CB5 and CB6 of the Local Plan.

The consideration in this case specifically relates to the justification for demolition and the suitability of the mixed use redevelopment scheme in the Talgarth Conservation Area. The impact of the demolition works on protected species in the vicinity has been addressed in the corresponding full planning application.

CONSIDERATION

The site was included within the Talgarth Conservation Area in 2011. None of the buildings within this site are Listed as CADW has confirmed that “the buildings at the former Mid- Wales Hospital have been assessed on two occasions, but were felt to fall short of the high standard necessary for listing.”

Policy Q17 of the UDP advises that new development and alterations to existing buildings within or affecting the setting of a Conservation Area will only be permitted where it will preserve or enhance the character of the area and where the design, all building materials, proportions and detailing are appropriate to the Conservation Area.

Policy Q18 of the UDP relates to demolition in Conservation Areas and states that the substantial demolition of any unlisted building or structure within a Conservation Area that is subject to Conservation Area consent will only be permitted where there is the strongest justification. Where such a building is to be replaced, a contract of redevelopment will be required to be finalised and entered into prior to the granting of conservation area consent.

The Talgarth Conservation Area Appraisal (2010) recommended that the site be included within the Talgarth Conservation Area on the basis that “there is a need to secure the remaining buildings and to ensure that any development is of the highest standard, respecting the handsome buildings and their setting in an attractive landscape” and “it is desirable to provide some sort of increased protection of the buildings and landscape and to inform future planning decisions.”

Other relevant paragraphs from the TCAA (2010) are as follows:

3.3 The former Mid Wales Hospital lies about 500m to the SE of the town centre, a purpose-built complex set in parkland and agricultural land. It is now partially a business park and partly derelict and awaiting suitable new uses.

10.3 As part of the brief for this report, consideration has been given to the inclusion of the former Mid Wales Hospital site into an extension of the conservation area. The site has an older farmhouse, Wern Fawr to the north of (the later named) Hospital Road. The farm became the home farm of the hospital and there are other uses linked to it, notably staff houses or „villas ‟ along the southern access road to Talgarth and to Pwll-y- Wrach and a large, detached house, Chance Field, to the north of the main complex. The complex of hospital buildings, main entrance block, great hall, separate chapel, mortuary, boiler house and laundry and other specialised treatment facilities was originally designed by Giles, Gough and Trollope in 1900. The hospital buildings are laid out in a symmetrical „butterfly ‟ plan, with a series of pavilions positioned either side of the central entrance and hall blocks, linked by corridors. There are various modern extensions and buildings but, in the main, the site retains a strong early C20 character.

10.4 Wern Fawr appears to be a five bay house, possibly incorporating an attached barn. It is roughcast and has had its first floor windows heightened into partial dormer windows. The nearby home farm buildings have a very distinctive architectural vocabulary, with local purple-brown sandstone rubble, laid to courses and with a yellow brick trim of quoins and window and door heads. Windows and doors have cambered arch heads. The original hospital buildings are two and single storey, with the main entrance block having a real architectural presence, with an E-plan, ten bays, a projecting two bay centre with porch, topped by a decorative clock turret and ground floor canted bays in the outer bays. The style is a typical late C19-early C20 modified classical, with sash windows, and vernacular C17 elements in the central gable. The materials are coursed sandstone rubble, a pink sandstone used for dressings and slate roofs.

10.5 There are also single storey ancillary buildings, in similar materials, with hipped roofs and distinctive multi-paned iron windows with the glazing bar joints expressed by small rosettes. The mortuary is also single storey, but with wooden sash windows. The boiler room chimney is prominent, of tapering square section and with iron reinforcement banding. The chapel is a seven bay rectangle, of sandstone and slate, in a simple lancet style and topped by a louvred cupola. There is a group of rendered buildings to the east of the main block, with sash windows. The large detached house, Chance Field, to the NW of the chapel, has many attractive Arts and Crafts/Queen Anne-style details – roughcast, multi- pane sashes, a large casement marking the staircase, canted bays and a central porch complete with segmentally arched head.

10.6 The complex is set in a very attractive landscape, with mature coniferous and deciduous trees, in the area around the chapel and Chance Field, by the southern entrance and along the two approach roads. There is a tennis court and a cricket field, complete with a pavilion, to the west of Chance Field.

10.7 The hospital buildings have been unused since the late 1990s, apart from some commercial use of a few units to the east of the main complex. There has been systematic stripping of slates and lead, resulting in damage to the former main hall. There have been attempts to list some or all of the group, but these have been, to date, unsuccessful. A range of uses for the site has been discussed with the private owners but, apart from the limited commercial use and the successful conversion of the Waun Fawr buildings for residential and tourism accommodation uses, the main complex is in obvious danger of further damage and, potentially, loss.

10.8 The financial realities of mixed use development, access considerations and the requirements of the planning system will undoubtedly determine the future of the site but there is a need to secure the remaining buildings and to ensure that any development is of the highest standard, respecting the handsome buildings and their setting in an attractive landscape. It is conceivable that some or all of the original hospital buildings should be listed, on the basis of the quality of buildings like the main entrance block and the chapel and as a recognition of the historic building use and layout. This kind of mental/isolation hospital complex is a very characteristic late C19-early C20 development, providing a reasonably humane environment and facilities for sport and rehabilitation. In the last twenty years, many similar sites have been demolished or altered beyond recognition as the NHS has disposed of much of its estate. Whilst listing may be reconsidered, it is desirable to provide some sort of increased protection of the buildings and landscape and to inform future planning decisions. It is recommended that a conservation area is designated around the hospital complex, the ancillary buildings, Chance Field, the Waun Fawr group and a reasonable portion of the grounds.

10.9 It would be possible to either extend the existing Talgarth Conservation Area boundary or to designate a separate, new conservation area that is physically separate from the existing one. It is recommended that the first course is adopted, running an extension from the current eastern extremity about 50m south to the edge of the cricket field and to the southern access road, Hospital Road, along to the major field boundary south of New Hospital Villas, thence, following field boundaries south and east of the main hospital group. The boundary should then run north to the northern access road and include Wern Fawr and its former buildings. It should then return west along the northern access road, including the woodland by the sharp bend to the existing designated area.

The following paragraphs within Planning Policy Wales (4 th Edition – February 2011) are relevant to this application:

6.5.17 Should any proposed development conflict with the objective of preserving or enhancing the character or appearance of a conservation area, or its setting, there will be a strong presumption against the grant of planning permission.

6.5.18 Conservation area designation introduces control over the total or substantial demolition of unlisted buildings within conservation areas. In exercising controls, account should be taken of the part played in the architectural or historic interest of the area by the building for which demolition is proposed, in particular of the wider effects of demolition on the building’s surroundings and on the conservation area as a whole. Consideration should also be given to replacement structures. The general presumption should be in favour of retaining buildings which make a positive contribution to the character or appearance of a conservation area.

6.5.23 It is generally preferable, for both the applicant and the planning authority, for related applications for planning permission and conservation area consent to be considered concurrently. Consideration of proposals for development in a conservation area should be made on the basis of a full, rather than an outline, consent.

Welsh Office Circular 61/96: Planning and the Historic Environment: Historic Buildings and Conservation Areas at paragraph 33 states that:

“The general presumption should be in favour of retaining buildings which make a positive contribution to the character or appearance of a conservation area. Proposals to demolish such buildings should be assessed against the same broad criteria as proposals to demolish listed buildings. In cases where a building makes little or no such contribution the authority will normally need to have full information about what is proposed for the site after demolition. Consent for demolition should not be given unless there are acceptable and detailed plans for redevelopment. It has been held that the decision maker is entitled to consider the merits of any proposed development in determining whether consent should be given for the demolition of an unlisted building in a conservation area.”

The NP Building Conservation Officer considers that the layout and architectural quality of the buildings provide the main character of this part of the extended conservation area. The BCO has confirmed that the design of the proposal does nothing to preserve or enhance the character of the conservation area in anyway.

With regard to the proposed demolition of the buildings, the BCO considers that insufficient justification for the wholesale demolition of the ward buildings has been provided.

To this extent, although it is recognised that the buildings are difficult to assess at the present time, it is noted that the Building Condition Survey is not a full Structural Survey of the buildings (as is generally required with applications of this type) and only “serves to provide an overview of the general condition of the buildings.”

The survey report goes on to state that a “general visual survey” was carried out and the report “constitutes a visual assessment of accessible parts of the exterior of the buildings.” It also states that the survey was “of a general nature” and “would not be suitable to formulate a detailed programme of repairs.”

This advice is contrary to assertions made within the submitted Design and Access Statement that “the Building Condition Surveys confirmed that the majority of the existing hospital buildings as not viable for retention or renovation” and “a Building Conditions Survey of the derelict buildings has confirmed that the majority of these buildings are no longer structurally or financially viable for retention.”

The BCO also notes that no attempt has been made to cost the works required to bring the buildings back into a good state of repair and to convert it into a suitable new use and suggests that the cost of demolition will be just as significant as the refurbishment of the buildings. She expected that the design and access statement would at give some indication of the process regarding the decision to demolish and not retain the buildings and this argument must be clearly made to justify the wholesale clearance of the ward buildings.

The Brecon Beacons Park Society also note that Planning Policy Wales suggests that demolition in Conservation Areas should only be permitted where there is the strongest justification. The Countryside Council for Wales has commented that whether or not the buildings are beyond repair is a key consideration to the future use of this site and if they are not then demolition, re-use of materials and the “greening-up” of the site may be a preferable option.

Although a Building Condition Survey was included as part of the application package and the Planning Statement considers alternative proposals for the redevelopment of the site (including a Scenario 2 – Piecemeal and Incremental Development), it is considered that the potential for the re-use of other buildings within the complex has been disregarded on the basis of an insufficient assessment of their structural integrity and the reports accentuate the negative consequences of taking this approach rather than giving full consideration to the opportunities and constraints of refurbishing and converting more of the existing buildings.

In summary, Officers consider that the removal of the buildings (apart from the Administration Block, Chapel and Mortuary) that form an integral part of the recently extended Talgarth Conservation Area without sufficient justification for their removal is unacceptable.

Consequently, the proposal does not accord with policies ES17 and ES18 of the UDP and guidance contained within PPW and Welsh Office Circular 61/96: Planning and the Historic Environment: Historic Buildings and Conservation Areas.

CONCLUSION

As indicated in paragraph 6.5.16 of Planning Policy Wales (4 th Edition, February, 2011), there is no statutory requirement to have regard to the provisions of the development plan when considering applications for conservation area consent, since in these cases the Courts have accepted that Section 54A of the Town and Country Planning Act 1990 (superseded by section 38(6) of the Planning and Compulsory Purchase Act 2004) does not apply. However, Development Plans should include relevant policies which can be taken into consideration in the determination of such applications.

Having regard to the above, it is considered that insufficient information has been submitted to justify the demolition of the buildings and the demolition of the buildings will have a detrimental impact on the character and appearance of the Talgarth Conservation Area. Therefore, the proposal is considered to be contrary to policies G3 i), Q17 and Q18 of the Brecon Beacons National Park Authority Approved Unitary Development Plan is thus recommended for refusal.

It should also be noted that the corresponding planning application for the redevelopment of the site is also recommended for refusal and is to be determined concurrently with this application, in line with paragraph 6.5.23 of PPW. Therefore, there are no firm plans for the site after demolition and Welsh Office Circular 61/96 advises that consent for demolition should not be given unless there are acceptable and detailed plans for redevelopment.

RECOMMENDATION: Refuse

Reasons:

1 Insufficient information has been submitted to justify the proposals to demolish buildings that are an integral part of the Talgarth Conservation Area, contrary to policies G3 i), ES17 and ES18 of the Brecon Beacons National Park Unitary Development Plan, policies G3 ii), CB5 and CB6 of the Brecon Beacons National Park Local Plan (1999) and guidance contained within Planning Policy Wales (4 th Edition – February, 2011) and advice contained within Welsh Office Circular 61/96: Planning and the Historic Environment: Historic Buildings and Conservation Areas.