PLANNING STATEMENT

Land to the east of Ithon Road (Phase 3, 4 & 5), Llandrindod Wells

April 2021

Summary

Proposal: Proposed residential development and associated works

Location: Land to the east of Ithon Road (Phase 3, 4 & 5), Llandrindod Wells, LD1 6DU

Date: April 2021

Project Reference: 20.248

Client: J G Hale Construction Ltd.

Product of: Asbri Planning Limited Unit 9 Oak Tree Court Mulberry Drive Cardiff Gate Business Park Cardiff CF23 8RS

Prepared by: Mared Jones | Graduate Planner

Approved by: Dylan Green | Senior Planner

Disclaimer: This report has been prepared for the sole and exclusive use of J G Hale Construction Ltd. for whom it was commissioned and has been prepared in response to their particular requirements and brief. This report may not be relied upon by any other party.

The Contracts (Rights of Third Parties) Act 1999 shall not apply to this report and the provisions of the said Act are expressly excluded from this report. This report may not be used for any purpose other than that for which it was commissioned. This report may not be reproduced and/or made public by print, photocopy, microfilm or any other means without the prior written permission of Asbri Planning Ltd. The conclusions resulting from this study and contained in this report are not necessarily indicative of future conditions or operating practices at or adjacent to the Site. Some of the information presented in this report is based on information provided by others. That information has neither been checked nor verified by Asbri Planning Ltd.

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 2

Contents

Section 1 Introduction 4

Section 2 Site Description 7

Section 3 Planning Context 10

Section 4 Proposed Development 15

Section 5 Summary of Accompanying Information 19

Section 6 Planning Policy Framework 25

Section 7 Appraisal 33

Section 8 Conclusion 37

Appendix 1 Planning Policy Wales Placemaking Table

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 3

Introduction

1.1 This Planning Statement is submitted to accompany the full planning application submitted on behalf of J G Hale Construction Ltd. for residential development and associated works on land off Ithon Road, Llandrindod Wells.

1.2 The site is located within the defined settlement boundary for Llandrindod Wells and is identified as a housing commitment site (P28 HA1) within the adopted Local Development Plan for Powys County Council. The development comprises phases 3, 4 and 5 which is a continuation of the residential development approved under planning permission 19/0021/FUL.

1.3 This Planning Statement acts as a supporting document for the accompanying planning application and should be read in conjunction with all other elements of the application which include the following plans prepared by Chamberlain Moss King;

Table 1: Application Drawings

Drawing title Drawing Prepared by no/ref

Site Location Plan N207 - A120 Chamberlain Moss King

Existing Site Layout N207 – A121 Chamberlain Moss King

Proposed Site Layout N207 - A122 Chamberlain Moss King

External Finishes Layout N207 - A123 Chamberlain Moss King

House Finishes Layout N207 - A124 Chamberlain Moss King

Street Elevations – N207 - A125 Chamberlain Moss Sheet 1 King

Street Elevations – N207 - A126 Chamberlain Moss Sheet 2 King

Street Elevations – N207 - A127 Chamberlain Moss Sheet 3 King

Street Elevations – N207 - A128 Chamberlain Moss Sheet 4 King

Context Elevation N207 - A129 Chamberlain Moss King

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 4

2 Bed 4 Person Type A - N207 - A130 Chamberlain Moss Floor Plans King

2 Bed 4 Person Type A - N207 - A131 Chamberlain Moss Elevations King

2 Bed 4 Person Type B - N207 – A132 Chamberlain Moss Floor Plans King

2 Bed 4 Person Type B – N207 – A133 Chamberlain Moss Elevations King

3 Bed 5 Person Type A - N207 – A134 Chamberlain Moss Plans King

3 Bed 5 Person Type A – N207 – A135 Chamberlain Moss Elevations King

3 Bed 5 Person Type B – N207 – A136 Chamberlain Moss Plans King

3 Bed 5 Person Type B – N207 – A137 Chamberlain Moss Elevations King

4 Bed 6 Person - Plans N207 – A138 Chamberlain Moss King

4 Bed 6 Person – N207 – A139 Chamberlain Moss Elevations King

1 Bed 2 Person Walk Up N207 – A140 Chamberlain Moss Flats - Plan King

1 Bed 2 Person Walk Up N207 – A141 Chamberlain Moss Flats – Elevations King

Adapted Bungalow - N207 – A142 Chamberlain Moss Plans King

Adapted Bungalow – N207 – A143 Chamberlain Moss Elevations King

2 Bed 3 Person N207 – A144 Chamberlain Moss Bungalow – Plans King

2 Bed 3 Person N207 – A145 Chamberlain Moss Bungalow – Elevations King

2 Bed 4 Person N207 – A146 Chamberlain Moss Bungalow – Plans King

2 Bed 4 Person N207 – A147 Chamberlain Moss Bungalow – Elevations King

1.4 In addition, the submission is accompanied by the following supporting documents:

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 5

Table 2: Application Documents

Document Title Prepared by Application Forms Asbri planning

Planning Statement Asbri Planning

Design and Access Asbri Planning Statement (DAS) Preliminary Ecological Ecological Services Wales Appraisal

Ecological Impact Ecological Services Wales Assessment

Arboricultural Report ArbTS

Geophysical Survey Report Sumo Survey

Phase One Desk Study Terra Firma (Wales) Investigation Report

Transport Statement Asbri Transport

1.5 The purpose of this Planning Statement is to summarise the proposals and to provide additional and complementary information to the planning submission. It provides a description of the application site at Section 2 and discusses the pre-application discussions at Section 3. Section 4 outlines the proposals, Section 5 provides a summary of the findings of the accompanying documents whilst Section 6 sets out the planning policy context. Thereafter, Section 7 appraises the development before Section 8 draws together the conclusion.

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 6

Site Description

Site Location 2.1 The site comprises a rectangular parcel of agricualtural land to the east of Ithon Road in Llandrindod Wells. It is located to the south of Phase 1 & 2 of the residential development which is currently being constructed by J G Hale Construction Ltd and managed by Newydd Housing.

2.2 The site lies immediately east of Ithon Road (A4081) which links the settlements of Llandrindod Wells and Llanyre within the centre of the administrative county of Powys. The all-weather pitch at Ysgol Calon Cymru is situated to the south of the site with the wider playing fields located along the eastern boundary.

Site Features 2.3 The field parcel comprises a linear stretch of agricultural land measuring approximately 2.6ha. The site’s boundaries are predominantly formed of post and wire fencing with mature hedgerows including a mix of bramble, hawthorn, blackthorn and existing trees, primarily along the northern and western boundaries. A large common oak sits half way along the site’s western boundary.

2.4 The site consists of greenfield land currently used for agricultural pasture. The majority of the land within the site boundary is semi- improved grassland and there are no structures located on the site, however, a drainage easement runs across the site in a north-east to south-west direction connecting with Llandrindod Wells’ Waste Water Treatment Works which lies approximately 200m to the south- west of the site.

2.5 The site’s topography slopes gradually from a high of 201m AOD along the eastern boundary adjacent to the playing fields of Ysgol Calon Cymru to a low of 187m AOD to the west along Ithon Road and thereafter, down to the river Ithon. There is also a gradual slope from a high of 196m in the north-eastern corner to a low of 191m AOD along the south-western corner of the site.

2.6 A review of TAN 15 Development Advice Maps shows the site to be within Flood Zone A. As such, there is no record of historic flooding on the site and it is considered to be of little or no risk of fluvial or coastal flooding.

Access 2.7 Access into the field parcel is currently achieved directly via an agricultural gate located along the north-western corner of the site, off Ithon Road (A4081). The road is straight at this location; therefore, visibility is adequate in both directions. The recently re-routed public right of way (CF22/1) runs along the site’s northern boundary,

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 7

connecting the site with Holcombe Drive to the north-west and the wider footpath network. Public Right of Way CF20/1 also runs parallel to the site’s eastern boundary.

2.8 Ithon Road is a local distributor road with an approximate carriageway width of 7.3m and footways along the eastern kerb (approximately 2m wide. The road is un-lit and is subject to a 30mph speed limit in the vicinity of the site which changes to 60mph approximately 700m to the north-west.

2.9 The site is served by public transport with several scheduled bus services connecting Llandrindod Wells with destinations such as Builth Wells, Newtown, Hereford, Brecon and Cardiff. There is an existing bus stop on Dyffryn Road within 600m walking distance to the site access and the X47 bus is routed along Holcombe Drive, to the north of the site connecting residents with the town centre and adjoining settlements. Llandrindod Wells Bus Interchange Station is located approximately 900m from the site. In addition, Llandrindod Wells railway station is located within the town centre, approximately 1km from the site.

2.10 The site benefits from being within walking distance to the centre of Llandrindod Wells, within which, there are a range of shops, school, community facilities, services and public transport routes.

Surroundings 2.11 The site is situated in a predominantly residential area. The residential context of Llandrindod Wells is characterised by several styles throughout the town. The residential development to the north of the site comprises of phases 1 and 2 of the development which are a mix of detached, and semi-detached houses and bungalows as well as walk-up apartments, the façades of which consist of a mix of buff and red/brown brick with matching brickwork and blue brick detailing. The roofs are blue/grey concrete tiles with black uPVC rainwater goods and white fascias and soffits. The windows are white uPVC with the front doors consisting of GRP doors of varying colours.

2.12 Further afield, the older residential development along Holcombe Drive is comprised of detached bungalows, the façades of which consist largely of red brick and stone cladding. The properties along Hillcrest Close and Penybryn are engineered to two storeys and are largely in terrace or semi-detached arrangements.

2.13 The site is situated in an inherently sustainable location by virtue of its position adjacent to Llandrindod Wells which forms the administrative centre of Powys County. The town offers an array of services and facilities including; a post office, library, museum, Tesco Superstore, hospital, sports centre and an array of restaurants. Ysgol

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 8

Calon Cymru lies adjacent to the site with access achieved via the aforementioned rights of way or along Ithon Road.

2.14 The River Ithon, a tributary of the River Wye, lies within close proximity to the site, albeit separated by additional field parcels. Both rivers are designated as Special Areas of Conservation (SAC) and Sites of Special Scientific Interest (SSSI).

Planning History 2.15 The site is identified as a housing allocation (P28 HA1) within the adopted Local Development Plan. The site is part of a wider allocation which is identified as being capable of accommodating a total of 122 dwellings over 3 phases (with a requirement for a minimum of 30% to be affordable). Phases 1 & 2 have recently been approved full planning for 55 units (19/0021/FUL) and is near completion.

2.16 A separate planning application for a development of temporary car park and associated works (20/0869/FUL) was approved on the 4th March 2021. This was in conjunction with the construction stage of the above planning permission and provided J G Hale Construction the use of the land on the opposite side of Ithon Road for car parking for a period of three years.

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 9

Pre-Application Discussions

Pre-Application Enquiry 3.1 A pre-application was submitted by Asbri Planning on behalf of J G Hale Construction Ltd on the 21st September 2020 (reference: 20/0132/PRE). The pre-application enquiry was accompanied by a layout plan which demonstrated how the site could be sympathetically developed to accommodate 77 no. residential dwellings along with the supporting documents referred to below.

3.2 The layout plan that accompanied the pre-app enquiry was largely similar to the plan submitted as part of this planning submission which is considered to be acceptable.

3.3 The comments received as part of the pre-application enquiry have been fully considered, as is evident in the Design Evolution which is discussed in more detail in the accompanying Design and Access Statement. In summary, the following comments were provided during the meeting with the officer and subsequently within the written response:

Principle of Development • As the proposed development complies with both policies H1 and H2 of the adopted Powys Local Development Plan, it is considered that the principle of development is accepted. • A development brief should be produced to accompany any planning submission

Scale and Nature of Development • The current proposal is in accordance with the requirements set out in policy H4 for towns and large villages, however, it is noted that Future Wales sets a requirement for 50 dwellings per hectare for towns and discussion with Welsh Government has advised that this should be the start point for development in any settlement. As such, whilst the density provided is in excess of that required by the LDP, it is substantially lower than that required by Future Wales. Any future submission would need to provide robust justification over the reduction in density

Design • The submission details matching materials with the adjacent development, red and buff brick facades with blue/grey concrete roof tiles. No elevations have been provided but the artist impressions details dwellings of a similar style and design to the adjacent scheme. The design is therefore generally in keeping with development in Llandrindod Wells, with the adjoining site under developments, and with Holcombe Drive being predominantly of buff and red brick construction

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 10

• The use of materials that are common within the area will ensure that the development will be in keeping with its surroundings. • With regards to boundary treatment, careful consideration regarding the northern boundary treatments is necessary to ensure that active travel route is not negatively impacted upon. • In light of the use of matching materials and the likely design of the dwellings, it is considered that the proposed development is in keeping with the character and appearance of the area and is therefore in accordance with policy DM13 of the Powys Local Development Plan.

Residential Amenity • The Powys Residential Design Guide Provides guidance on ensuring that developments do not have a detrimental impact on the amenity and privacy of neighbouring properties. The guidance states that 21 metres should be maintained between rear habitable windows of the existing and proposed dwelling and 10 metres should be provided between the proposed dwelling and the boundary with the neighbouring property. Consideration will need to be given to maintaining these distances between the proposed development and the dwellings of the site under development and those existing dwellings on Holcombe Drive. It is noted that the active travel route separates the existing dwellings from the proposal however ensuring these distances are complied with ensures that the development remains compliant with policy. • In light of the above, it is considered that the proposed development is in accordance with policy DM13 of the Powys Local Development Plan and the Powys Residential Design Guide.

Landscaping • The site lies wholly within the development boundary of Llandrindod Wells, however will be a highly visible development on your approach into the settlement from the west. However, the application site is allocated for housing and will be seen against the backdrop of the existing housing in Llandrindod Wells. • Therefore, having taken into account the nature and scale of development together with the information contained within LANDMAP, it is considered that the development will satisfactorily integrate into the landscape in accordance with policy DM4 of the Powys Local Development Plan.

Highway Safety • Whilst the Highway Authority would have no fundamental objection to the provision of a residential development at this

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 11

location, the following matters will need to be addressed as part of any future formal planning submission. o The access would need to provide visibility of 2.4m x 160m in each direction, which is the recommended standard for roads with speeds of 50mph, as detailed within Manual for Streets & Table A/B of TAN 18. o Such an access will need to conform to PCC standards in terms of: ▪ Gradient - Max 1:30 for first 10m ▪ Construction - 450mm standard construction for first 10m o Off street parking provision shall be provided in accordance with CSS Wales Parking Standards. (1 space per bedroom up to max. of 3 spaces excluding garage space.) o Parking areas and private drives shall include a suitably sized turning head (see PCC Design Guide) and be surfaced in a suitably bound material such as block paving or tarmac. o The width of the internal carriageway shall be not less than 5.5 metres with 2 metre footways.

Contaminated Land • The Council’s Contaminated Land Officer has offered no objection to the pre-application.

Ecology and Biodiversity • Given the proximity of the proposed development to the River Wye SAC, the potential for the proposed development to impact the River Wye SAC during the construction and operation phases of the development and the potential for a Likely Significant Effect on the River Wye SAC and/or its associated features will need to be considered. • Submission of a planning application should be accompanied by both initial and updated PEA and AIA surveys. • It is noted that the provided PEA refers to the closest pond being some 1.2km away. A pond is known to be located approximately 125m from the proposed development site alongside public footpath 15 which extends in a loop from Dyffryn Court to Dyffryn Road. The pond was created approximately ten ago to benefit wildlife. The current status of the pond is uncertain but up to date information regarding its potential to support great crested newts will be required for consideration of a planning application. • A Tree and/or Hedgerow Compensation Planting Scheme or Hedgerow Translocation Plan could be secured through a planning condition. • Careful consideration will need to be given to any external lighting of the proposed development. Measures will need to be

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 12

identified to minimise impacts to nocturnal wildlife commuting or foraging in the local area. • It is recommended that details of any landscaping proposed are submitted in a detailed Landscape Planting Scheme to include proposed species mixes, planting and aftercare schedules. • it is recommended that consideration is given to opportunities to incorporate features to enhance biodiversity at an early stage and ensure the development provides a net benefit for biodiversity. Examples of suitable features could include: o Provision of bird and bat boxes. The proposal should include details of the number, type and location of boxes, o Creation and management of a wildlife buffer strip. Hedgerows should be retained within buffer strips and left unlit, or with lighting directed away to create dark corridors for nocturnal wildlife moving through the site, o Provision of wildlife-friendly landscape planting.

Phosphate Levels • The proposed development is located within the catchment of the River Wye Special Area for Conservation (SAC). • In accordance with NRW’s interim planning advice first issued on 17th December 2020, it will be necessary to demonstrate that all proposed developments within the River Wye SAC catchment will not result in an adverse effect on the integrity of the River Wye SAC through further addition of phosphate to the SAC, either directly or indirectly. With regard to the current proposal, consideration has been given to the potential for additional phosphate associated with foul drainage to enter the River Wye SAC catchment. • NRW’s interim planning advice states ‘Any development connecting to a public wastewater treatment works where the permit has phosphate conditions in place and the sewerage undertaker has confirmed that there is capacity to treat the additional wastewater and the additional phosphate from the proposed development’ is considered unlikely to increase phosphate inputs. NRW advise that where connection to a public wastewater treatment plant is proposed that specific confirmation is required from DCWW to enable a HRA to be undertaken: ‘(a) that there is treatment capacity to treat the additional wastewater and any additional phosphate from the proposed development (in combination with other planned development) within the existing discharge permit limits, or (b) that the necessary treatment capacity to remain within existing discharge permit limits will be implemented within the current Asset Management Plan (AMP) period.’ • Concerns are raised regarding the correspondence received from DCWW as whilst this confirms that there is capacity within the WWTW and that they have phosphate conditions in place,

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 13

this does not confirm that the WWTW has phosphate stripping in place nor does it conform that it has capacity to treat the additional phosphate. DCWW need to advise that they have both the capacity and phosphate stripping in place for a development to be considered acceptable in terms of the Habitats Regulations.

Open Space • It is noted that from reviewing the Powys Open Space assessment that the settlement of Llandrindod Wells has sufficient informal open space and outdoor sports pitches. The benchmark for the settlement for designated equipped space has not been met and only 60% of the population is within the accessibility buffer to such play spaces. It is noted that the site at Ithon Road is not within any accessibility buffers for either Local Areas of Play or Local Equipped Areas of Play. However it is noted that the adjoining site is providing a Local Area of Play which will be within the accessibility buffer for the proposed site. As such, it is considered that the open space provided as part of this scheme should be an equipped area of play.

3.4 Ultimately, the pre-application response concludes that “having carefully considered the details submitted together with all statutory consultee responses and third party representations, Officers are satisfied that the proposed development complies with the relevant policies within the Powys Local Development Plan, Technical Advice Notes and Planning Policy Wales.”

Pre-Application Consultation 3.5 In accordance with Part 1A of ‘The Town and Country Planning (Development Management Procedures) (Wales) (Amended) Order 2016” (DMPO 2016), all major developments are required to be subject to pre-application consultation, prior to the Planning Application being validated by the Local Planning Authority.

3.6 Accordingly, a Pre-Application Consultation is to be held between the 12th April and the 10th May 2021 where all statutory, community and ‘other’ consultees are invited to view the submission package and provide their comments. Further details on the PAC process and the comments received are to be provided within the PAC Report and any alterations to the scheme, as a result of this consultation, is to be included within the Design and Access Statement.

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 14

The proposal

The Proposal 4.1 The proposed layout plan illustrates that the site is capable of accommodating 79 no. residential units along with associated car parking, access and landscaping. The mix of the dwellings is proposed as follows:

• 22 x 1 Bed Walk up Flats; • 4 x 2 Bed Bungalows; • 2 x 3 Bed Bungalows; • 26 x 2 Bed House; • 19 x 3 Bed House; • 6 x 4 Bed House.

4.2 It is considered that the scheme represents an efficient use of land on an allocated housing site in Llandrindod Wells and the proposed development will reflect and enhance the residential character of the surrounding area. As the proposed Layout Plan shows, the layout, position and orientation of the dwellings have been designed to be similar to that in design of phase 1 & 2 as well as the surrounding vernacular and to ensure these phases assimilate into the first two phases that have already been built.

4.3 As the site can accommodate such a substantial number of units, it will be brought forward as a scheme of mixed tenure, managed by Newydd Housing. Given the recent withdrawal of Rent-to-Own, the proposed tenure mix currently consists of 59 affordable units and 20 units of homes for market sale. Depending on timescales surrounding the availability of SHG and therefore allowing a site start to begin, the reasonable consideration of any other Welsh Government initiatives that may be introduced remains possible.

Access 4.4 Access to the site will be provided via a new priority ‘T’ junction with Ithon Road (A4081). The access point will be located on the site’s western boundary and will comprise of a 5.5m wide carriageway along its entire length with 2m footways on one or both sides of the carriageway. In addition, the access will incorporate facilities for pedestrians and cyclists, with 2m wide footways provided along both sides of the carriageway as well as a network of footpaths through the site connecting to the recently re-routed public right of way (CF22/1) to the north of the site.

4.5 Internally, the access point enters the western part of the site before reaching a simple priority junction where the road is directed out in a northerly and southerly direction before being re-directed westwards in a cul-de-sac arrangement towards Ithon Road. A total of two spur

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 15

roads will be located to the north of the access road with private drives providing access to dwellings and one to the south of the access road. Turning heads situated at the end of each arm will cater for vehicular movement and refuse collection. The required visibility splays at the site access are based on stopping distance of vehicles travelling at 30mph, accordingly a 2.4m x 43m splay is achieved.

4.6 The dwellings are to be positioned either side of the proposed adoptable carriageway as well as off private drives along the western boundary. The layout is connected via footpaths which enhances connectivity and encourages Active Travel. In terms of wider connectivity, the layout will connect to the recently re-routed public right of way (CF22) and Ithon road so residents can walk and cycle into the town centre where the majority of local facilities are available.

Parking 4.7 The accompanying Site Layout Plan demonstrates that car parking for the proposed dwellings are to be provided on the basis of one space per bedroom with two spaces provided for all two, three and four- bed properties. Despite being lower than the standards set in Powys’ adopted parking standards, ‘Car Parking Standards, 2017’, it is considered that the site benefits from good connectivity to local facilities and to public transport and the reduction in one space for all three and four bed properties provides an opportunity to present a well-designed scheme which is not overly dominated by parking which in turn establishes better placemaking.

4.8 The parking spaces will be located in front or to the side of each respective plot with visitor parking spaces to be accommodated on- the carriageway.

4.9 In terms of cycle parking, each proposed dwelling is provided with ample private amenity space which can accommodate either garages or garden sheds which will provide space for secure storage of bicycles.

Layout 4.10 As illustrated by the accompanying plans, the proposed layout has been designed to reflect and enhance the surrounding vernacular as much as possible. The dwellings are to be positioned either side of the proposed adoptable carriageway and the dwellings along the northern boundary are orientated so they have a positive back-to- back relationship with the existing residential dwellings situated along Holcombe Drive. In order to further mitigate the impact on residential amenity, the dwellings within the north-eastern corner are propsoed as bungalows to reflect the predominant character along Holcombe Drive. It is clear from the accompanying plans that each

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 16

dwelling along this boundary is sufficiently located in excess of 21m from the properties along Holcombe Drive as well as the dwellings that have recently been approved at phases 1 and 2.

4.11 A strong residential building line is proposed along the internal highway to ensure presence and frontage within the street scene. The properties along the access road have been orientated to front onto Ithon Road, similar to the approved dwellings at Phases 1 and 2. Regard has also been paid to the outlook from the access road and to ensure there is sufficient soft landscaping to enhance the scheme and to encourage a sense of place. The retention of the common oak on the entrance to the site establishes this further.

4.12 The site comprises a mix of dwellings, including bungalows, flats and 2-storey houses which will ensure an architecturally interesting street scene. It is considered that the proposed heights are appropriate within its surroundings and provides interest and rhythm in this particular location. The site delivers a medium density development of 33 dwellings per hectare (dph), in accordance with Policy H4 of the LDP.

4.13 The accompanying site layout shows that pockets of open space areas are provided throughout the development, in accordance with Fields in Trust guidance and each area of open space has been consciously designed to ensure they can be accessible and are sufficiently overlooked.

4.14 As a result of the site’s topography, the eastern boundary will require retaining walls, however, extensive engineering input has established the preferred layout from a viability, buildability and aesthetical perspective. Accordingly, the current scheme is considered the optimal layout and is the result of significant work to allow the site to accommodate residential dwellings without swathes of retaining walls. The site also successfully delivers the density required in the LDP whilst also avoiding the easement associated with the foul sewer which crosses the site. This is considered to eb a positive solution to the site’s constraints.

4.15 From the above, it is clear that a positive layout can be delivered which makes positive use of the opportunities and constraints on-site complies whilst also being compatible with the overall character and density of the area.

Appearance and Materials 4.16 The proposed dwellings have been designed with a material palette which is sympathetic to that of the existing surrounding vernacular. The appearance and the material palette will be consistent with phases one and two, as such, will comprise of a mix of buff and

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 17

red/brown brick with matching brickwork and blue brick detailing. The roofs are to comprise of blue/grey concrete tiles with black uPVC rainwater goods and white fascias and soffits. The windows are to be white uPVC with the front doors to consist of GRP doors of varying colours.

4.17 From the above, it is clear that a positive residential development can be delivered which complies with relevant planning policy and is compatible with the overall character and density of the area.

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 18

Summary of accompanying documents

5.1 The following section intends to provide a brief overview of the supporting documents which have been prepared to accompany the planning application for the proposed development.

Design and Access Statement 5.2 Asbri Planning Ltd have produced a Design and Access Statement which details the design concept for the scheme and addresses the five objectives of good design in line with the requirements of TAN 12 (Design), as detailed in the Planning Policy chapter of this report.

Arboricultural Report 5.3 A tree survey was conducted by ArbTs on the 11th June 2020 in accordance with British Standard 5387:2012, Trees in relation to design, demolition and construction – Recommendations. The purpose of this survey was to assess the quality of the trees at Ithon Road, assess the arboricultural impact of the proposed development design and provide details regarding the protection of retained trees during construction works.

5.4 A total of 4 no. individual trees were surveyed along with a woodland area and 7 no. hedgerows across the site. Of the individual trees that were surveyed, 2 were classed as Category B (Moderate Quality – Desirable for Retention), 1 was classed as Category C (Low Quality – Optional for Retention) and 1 was Categorised as U (Poor Quality – Unsuitable for Retention). Alongside this, the woodland area was classed as Category A (High Quality – Most Desirable for Retention) and the 7 no. hedgerows were all classified as Category C (Low Quality – Optional for Retention).

5.5 The report concludes that the site has potential to accommodate development whilst retaining the trees of value. Therefore, no trees are identified to be removed to facilitate the construction of the proposed development design. Only 6 metre section of hedgerow is required to be removed to create the new access into the site. This hedgerow loss can be readily mitigated for by suitable compensatory hedgerow planting.

Site Investigation Report 5.6 Terra Firma (Wales) Limited have been appointed as the Geotechnical Engineers to undertake a desk-based site investigation provide information on likely ground conditions, likely environmental liabilities and to produce an initial site conceptual model and a tentative engineering foundation and slab floor recommendations for future development.

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 19

5.7 Based upon the available desk-study information, it is likely that a traditional foundation consisting of mass concrete strips/trench fill and/or pad foundations will be feasible. Soakaway drainage is unlikely to be viable for future development of the site and it is anticipated that ground conditions are likely to preclude the use of infiltration given their low permeability.

5.8 It is recommended that an intrusive investigation is undertaken to inspect the ground conditions, to take soil samples for laboratory chemical and geotechnical testing. It is perceived that the trial pitting will be suitable to investigate the site. Percolation tests should also be undertaken to inform the SuDS design.

Preliminary Ecological Appraisal 5.9 The proposed development site has been subject to previous ecological survey work; an Extended Phase 1 Survey by Dusk to Dawn Ecology was completed in October 2017 and an updated site visit was undertaken on 14th May 2020 by Ecological Services which was the optimum time to undertake a phase 1 habitat survey. The report considers the likely presence of great crested newts, dormice, bats, otters, badgers, birds and reptiles as well as amphibians.

5.10 The report concludes that the proposed development has the potential to impact nesting birds, bats, mature vegetation and reptiles; therefore, the following recommendations have been made, all of which will be adhered to during the implementation of the development:

• Hedgerows and trees must be retained where possible as they provide shelter and food for birds and small mammals. Any loss of hedgerow must be replaced elsewhere on a like- for-like basis. Replacement hedges should be exclusively native species which are indigenous to the locality. Long term management proposals will be required for any planting to ensure the habitat establishes and is maintained. • The trees, hedgerows and scrub within the site boundary have potential for use by nesting birds. Any vegetation removal must be completed outside of the bird nesting season of March to August inclusive. • A root protection zone (RPZ) must be implemented around any retained trees throughout the development, British Standard BS 5837, Trees in relation to design, demolition and construction - Recommendations will be followed. Measures will include clear marking of the RPZ to guarantee no machinery is used or digging carried out in that area. This will ensure that there is no detrimental impact to the trees and the flora or fauna it supports.

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 20

• If any of the trees highlighted to have potential for use by bats are to be removed they must be soft felled. The tree work must be completed during the winter months when bats are least likely to be present. The trees have low potential to support roosting bats, as such soft felling will allow any bats which may be present the opportunity to move away. Any trees removed must be replaced with native species and incorporated into the landscaping scheme. • Careful consideration must be given to the use of lighting within the development site, as this can adversely affect activity by a variety of fauna, particularly foraging bats, nesting birds and invertebrates. All boundaries must be retained as dark corridors to provide suitable commuting routes for bats. No external light source will be placed within 2m of a roost location for bats. • The provision of bird boxes of varying design in suitable locations within the development site. These could include house martin, swift, sparrow terrace boxes as well as small and large holed boxes on the mature trees retained during works. • The use of native plant species within areas of landscaping proposed for the development. • All fencing around the site will be hedgehog friendly in design. A friendly design is considered to allow the passage of small animals across the site. It should provide either a continuous gap between the bottom of the fence and ground of approximately 5cm or gaps cut a set distance along fencing.

5.11 As such, it is clear there is potential to offer ecological gain for bats and nesting birds if the project proceeds. This would help satisfy the local planning authority’s legal responsibility to preserve and enhance biodiversity under the Environment (Wales) Act 2016. The creation of existing features will be incorporated into the schedule of works. This can be achieved at very little expense and with no impact to the owners of the building.

Ecological Impact Assessment (EcIA) 5.12 The EcIA document builds upon all survey findings and work completed to support the proposed planning application. The role of a EcIA is to address significant effects which the project may have. For the purpose of this assessment significant impacts will be those that affect legally protected sites and species within and directly adjacent to the proposed development site. The proposed development site owner will have the responsibility to ensure the measures within this document are fully and continually implemented during the life time of the project.

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 21

Geophysical Survey Report 5.13 In order to assess the archaeological merits of the site, Sumo Services Ltd were commissioned by Earth Dimension Partnership to undertake a geophysical survey of the site. In summary, no evidence of archaeological features were identified within the northern area (phases 1 and 2), however, the area which covers phases 3, 4 and 5, as submitted under this application, shows natural and uncertain areas of increased response along with areas identified as former boundaries or paths. The form of some of the responses suggests natural variations, but the zones appear to have distinct edges and have roughly rectangular shapes which might hint at an anthropogenic origin such as landscaping or deliberate dumping of material.

Transport Statement 5.14 The planning submission is accompanied by a Transport Statement (TS) prepared by Asbri Transport Ltd which details the transport characteristics of the proposed development, and its potential impact on the surrounding transport network.

5.15 It is estimated that the proposed development could generate up to 29 vehicular movements (two-way) in the AM peak period and 28 vehicles (two-way) in the PM peak period. It is considered that this level of traffic generation will have a marginal impact on the performance of Ithon Road.

5.16 The report confirms that there are opportunities for residents of the proposed development to undertake trips by alternative modes of travel to the private car and that the site is closely situated to existing bus services and local amenities.

5.17 The Transport Statement concludes that the development is appropriate and acceptable in traffic and transport terms. It is considered that the traffic movements associated with the development proposals could be accommodated on the highway network and will not have a detrimental impact on the free flow of traffic due to the existing volumes of traffic using the local highway network.

Drainage Strategy Surface Water Strategy 5.18 The surface water design for phases 3, 4 & 5 will be subject to a full SAB design application demonstrating compliance with the Statutory SuDS Standards for the design, construction, operation and maintenance of surface water systems serving the new development.

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 22

5.19 Similar to phase 1 & 2, infiltration is not viable due to heavy clay soils. As such non infiltrating SUDS systems will be used to treat and manage the on site surface water.

5.20 A schematic design has been formalised that outlines the strategy of the final SUDS design which will be using a series of SUDS systems that attenuate to the 100 year rain fall event and restricts flows to an outfall detention basin where flows can be further stored and the rate of discharge restricted further to achieve the 1.1 l/s final discharge rate to the existing Phase 1 & 2 DCWW surface water system. The series of SUDS systems are outlined below:

• Non infiltrating Permeable paving/taramc to adopted road areas to provide treatment and storage of catchment rainfall. This type of system will provide a high level of treatment by means of the porous joints, permeable geotextiles and graded stone. The system will attenuate to the 1 in 100 year rainfall event plus a 30% allowance for climate change. Discharge from these systems will be restricted using a controlled discharge to the outfall detention basin located in the North East corner of the site, where water will be stored in under drained attenuation cells and flows restricted further to comply with the 1.1 litre per second requirement. • Flows from the road sub grade will be distributed across the surface of the open depressed area using swale outlets and channels where there will be some settling of particulate pollutants. Enhanced infiltrating soils, permeable membranes and stone sub base will provide a high level of treatment to contamination, such as hydrocarbons, metals, suspended soils and possible detergents. These soils will enable water to infiltrate rapidly to the storage cells below. This area of land will also function as a recreational facility. Flows from permeable road areas located at the Southern end of the site will be conveyed above and below ground strategically through green corridor areas along the Western boundary where pollution prevention will occur, with flows being distributed directly into the sub base of the detention basin. • Run off from dwelling roofs will primarily will be captured by non infiltrating permeable paving/tarmac to driveway areas, where water will be treated and stored to manage the 1 in 100 year rainfall event plus 30% climate change allowance. Where landscaped areas permit, a number of roofs will have run off captured by rain garden areas, where settling of pollutants will occur at the surface and a high level of treatment provided from enhanced infiltrating soils and membranes. Flows will be attenuated to the same rainfall event and both system will have flows restricted to the main road sub-base which will convey these onward to the surface of the main detention area located in the North-West corner of the site. • Larger private drive areas to plots 16-18, 13-15, 74-77 & 66-67 will be managed using permeable paving, swales and public open space

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 23

rain gardens in these areas. From these two locations the restricted run off will be conveyed above and below ground strategically through green corridor areas along the Western boundary where pollution prevention will occur, with flows being distributed directly into the sub base of the detention basin.

Foul Strategy All new foul waste-water will be gravity fed to the existing DCWW foul sewer that crosses the phase 3,4 & 5 development land from North-East to South-West

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 24

Planning Policy Framework

6.1 The planning policy framework for the determination of this application is provided by national planning guidance, together with the statutory ‘development plan’.

6.2 National planning policy is contained within the eleventh edition of Planning Policy Wales (PPW), published by the Welsh Government in February 2021. PPW is supported by 21 topic-based Technical Advice Notes (TANs), which are also relevant. The statutory ‘development plan’ for this site is currently provided by Powys County Council’s Local Development Plan which was adopted in April 2018.

Planning Policy Wales (PPW) 6.3 Planning Policy Wales (PPW) Edition 11 (February 2021) sets out the land use planning policies of the Welsh Government. It is supplemented by a series of Technical Advice Notes (TANs), Welsh Government Circulars, and policy clarification letters, which together with PPW provide the national planning policy framework for Wales.

6.4 The primary objective of PPW is to ensure that the planning system contributes towards the delivery of sustainable development and improves the social, economic, environmental and cultural well-being of Wales, as required by the Planning (Wales) Act 2015, the Well- being of Future Generations (Wales) Act 2015 and other key legislation. PPW and the National Development Framework (NDF) set out how the planning system at a national, regional and local level can assist in delivering these requirements through Strategic Development Plans (SDPs) and Local Development Plans (LDPs).

6.5 Sustainable development is defined as:

“Sustainable development” means the process of improving the economic, social, environmental and cultural well-being of Wales by taking action, in accordance with the sustainable development principle, aimed at achieving the well-being goals. Acting in accordance with the sustainable development principle means that a body must act in a manner which seeks to ensure that the needs of the present are met without compromising the ability of future generations to meet their own needs. “

6.6 PPW Edition 11 states that up-to-date development plans are the basis of the planning system and set the context for rational and consistent decision making. Plans at all levels of the development plan hierarchy must be prepared in accordance with national planning policies. Planning applications must be determined in accordance with the adopted plan, unless material considerations indicate otherwise.

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 25

6.7 Under Section 2 - People and Places (Achieving Well Being Through Placemaking), 5 Key Planning Principles are highlighted, under the general heading of Achieving the Right Development in the Right Place which are:

1. Growing our economy in a sustainable manner 2. Making best use of resources 3. Facilitating Accessible and Healthy Environments 4. Creating and Sustaining Communities 5. Maximising environmental protection and limiting environmental impact.

6.8 Paragraph 2.27 states that planning authorities should ensure that economic, social, cultural and environmental benefits are given equal consideration in the decision-making process, by following the 5 ways of working, to ensure that a balanced assessment is carried out and to implement the Well Being of Future Generations Act and the Sustainable Development Principle. There may be occasions where one type of benefit outweighs others, and in such cases robust evidence should be presented to support these decisions.

6.9 Section 3 – Strategic and Spatial Choices, states that effective strategic placemaking requires early collective consideration of placemaking issues at the outset, in the formulation of a development plan, or when developing specific proposals. The policy issues should not be considered in isolation from one another. This includes considering the design of a development and its impacts upon everyday lives as well as thinking holistically about where people might live and work and which areas should be protected.

6.10 Paragraph 3.3 emphasises that good design is fundamental to creating sustainable places where people want to live, work and socialise. Design is not just about the architecture of a building but the relationship between all elements of the natural and built environment and between people and places.

6.11 Paragraph 3.51 encourages higher densities in urban centres and near major public transport nodes or interchanges, to generate a critical mass of people to support services such as public transport, local shops and schools.

6.12 Section 4 – Active and Social Places defines those places which promote our social, economic, environmental and cultural well-being by providing well-connected cohesive communities. Places which are active and social contribute to the seven goals of the Well-being of Future Generations Act.

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 26

6.13 The key issues in this theme include:

• ensuring there is sufficient housing land available to meet the need for new private market and affordable housing; • facilitating a range and choice of housing to respond to the change in household need, such as the predicted increase in single person households over the next 20 years; • assisting in the delivery of cohesive communities which will meet the needs and are accessible to all members of society, including older people; • tackling inequalities between communities, delivering services and jobs closer to where people live and acknowledging the importance of inclusive communities and the wider environment for good health and well-being; • improve sustainable access to services, cultural opportunities and recreation facilities to support people to adopt healthy, culturally fulfilled lifestyles which will assist in improving health and wellbeing; • reducing reliance on travel by private car, and the adverse impacts of motorised transport on the environment and people’s health, by prioritising and increasing active travel and public transport; • ensure our transportation infrastructure is adaptable to future advances in innovation such as the mainstreaming of electric vehicles or possible advent of autonomous or driverless vehicles in the next ten to 15 years; and • diversifying retail and commercial centres so they can adapt to future retail trends, such as the continued rise in internet shopping, so that they can continue to meet the needs of their local communities.

6.14 This theme supports and enables the provision of a range of well- designed and located homes which are well connected to existing retail and commercial centres situated at the heart of our communities and job opportunities. It emphasises that when planning and managing future development planning authorities need to ensure that residents of existing and new communities have access to jobs and an appropriate range of community facilities.

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 27

Well-being and Future Generations (Wales) Act 2015 6.15 The Well-being of Future Generations (Wales) Act came into force in 2015 and seeks to improve the social, economic, environmental and cultural well-being of Wales. The Act puts in place seven well-being goals in order to make sure that everyone works towards the same vision. The well-being goals are set out below.

Technical Advice Notes (TANs) 6.16 PPW is supported by 21 Technical Advice Notes (TANs) which provide more detailed guidance on a variety of issues. In respect of this application, the following TANs are considered to be of relevance.

Technical Advice Note 2: Planning and Affordable Housing (2006) 6.17 TAN 2 defines affordable housing for planning purposes and provides advice to local planning authorities on how to determine affordability. The need to work collaboratively is stressed, including the requirement for housing and planning authorities to undertake local housing market assessments in participation with key stakeholders.

6.18 Paragraph 8.1 of TAN 2 states:

“Local planning authorities should ensure that development plan policies are based on an up-to-date assessment of the full range of housing requirements across the plan area over the plan period.”

Technical Advice Note 12: Design (2016)

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 28

6.19 TAN 12 provides advice on design considerations and, in relation to housing design, it states that local planning policies and guidance should aim to:

▪ “create places with the needs of people in mind, which are distinctive and respect local character; ▪ promote layouts and design features which encourage community safety and accessibility; ▪ focus on the quality of the places and living environments for pedestrians rather than the movement and parking of vehicles; ▪ avoid inflexible planning standards and encourage layouts which manage vehicle speeds through the geometry of the road and building; ▪ promote environmental sustainability features, such as energy efficiency, in new housing and make clear specific commitments to carbon reductions and/or sustainable building standards; ▪ secure the most efficient use of land including appropriate densities; and ▪ consider and balance potential conflicts between these criteria.”

Technical Advice Note 18: Transport (2007) 6.20 TAN 18 offers national guidance on transportation related planning policies and advises that it should be read in conjunction with Manual for Streets. It advocates:

▪ “The integration of land use planning and transport in order to promote resource and travel efficient settlement patterns; ▪ Ensuring that development is located where there is good accessibility by public transport, cycling and walking. This minimises the need to travel and promotes social inclusion; and ▪ Managing parking provision.”

Powys County Council Local Development Plan (2011-2026) 6.21 The development plan for the purposes of Section 38 (6) of the Planning and Compulsory Purchase Act 2004 is the adopted Local Development Plan which forms the statutory framework for the development and use of land within Powys (except for the area designated within the Brecon Beacons National Park Authority). The LDP was adopted in April 2018.

6.22 The site lies within the defined settlement boundary for Llandrindod Wells where development is normally permitted, subject to compliance with all design management policies. In addition, the site identified as a new housing allocation (P28 HA3) within the adopted

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 29

Local Development Plan. The site is part of a wider allocation which is identified as being capable of accommodating a total of 122 dwellings over 3 phases (with a requirement for a minimum of 30% to be affordable). As aforementioned, Phases 1 and 2 have already been constructed and phases 3, 4 and 5 are proposed to be delivered through the granting of this planning application.

6.23 Considering the site’s allocations, the following policies are considered most relevant to the proposed application:

Policy Reference Relating to Strategic policies SP1 Housing Growth SP3 Affordable Housing Target SP5 Settlement Hierarchy Distribution of Growth across the SP6 Settlement Hierarchy Development Management Policies DM1 Planning Obligations DM2 The Natural Environment DM4 Landscape DM5 Development and Flood Risk Flood prevention measures and Land DM6 Drainage DM7 Dark Skies and External Lighting DM10 Contaminated and Unstable land Development in Welsh Speaking DM12 Strongholds DM13 Design and Resources Topic Based Policies T1 Travel, Traffic and Transport Infrastructure H1 Housing Development Proposals H2 Housing Sites H3 Housing Delivery H4 Housing Density H5 Affordable Housing Contributions

6.24 As the site is allocated for residential purposes, Policy H1 is of

particular relevance, stating:

“In accordance with Strategic Policies SP1, SP3, SP5 and SP6, housing development proposals must comply with the following site criteria:

1. In Towns and Large Villages:

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 30

i. On sites allocated for housing and other suitable sites within the development boundary. ii. On sites forming logical extensions outside development boundaries for affordable housing in accordance with Policy H5.”

6.25 The site is identified for residential development under ref no. P28 HA3, as contained under Policy H2.

6.26 Policy H3 relates to the delivery of residential developments, advising:

“Housing development proposals must be of an appropriate scale and shall:

i. Provide a suitable mix of housing types to meet the range of identified local housing needs. ii. Be phased if appropriate to reflect the context of the development and mitigate its impact on the local community.

Applications Proposals to develop parts of sites must not prejudice the development of the remainder of the site or seek to avoid planning obligations.”

6.27 Policy H4 is also of particular relevance as it relates to housing density advising that for sites within tows and large villages, there should be a delivery of 27+ units per hectare.

6.28 Policy H5 – Affordable Housing Contributions states:

“Housing development proposals will be required to make contributions towards affordable housing in accordance with the following criteria:

1. A contribution will be required from open market housing development proposals of 5 or more dwelling units or on sites of 0.25 ha and above.

2. The target contributions required for each a sub-market area are as follows:

i. Central Powys – 30% contribution. ii. Severn Valley – 20% contribution. iii. North Powys - 10% contribution. iv. South West/Powys – 0% contribution.

The above target contributions will be kept under review in order

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 31

to reflect changes in viability. Any amendments made to the target contributions as a result of this review will be confirmed through the Affordable Housing Supplementary Planning Guidance.

Supplementary Planning Guidance (SPG) 6.29 The following SPG documents are considered to be relevant in the consideration of this application:

▪ Affordable Housing SPG - Approved September 2010, Updated July 2011; ▪ Residential Design Guide – October 2004; and ▪ CSS Wales Parking Standards.

6.30 The Council, in its role as the Highways Authority, has adopted an SPG on Parking Standards, ‘Car Parking Standards, 2017’, which requires parking to be provided at a rate of 1 parking space per bedroom up to a maximum of 3 spaces per dwellings. Visitor parking should be allocated on a rate of one space per five dwellings.

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 32

Appraisal

7.1 This section aims to identify the main issues relevant to the determination of the application and assess the scheme against the relevant planning policy framework. These matters are considered to be as follows:

▪ The principle of development in terms of land use planning policy and sustainable development; ▪ The impact of the development on the character and appearance of the surrounding area; ▪ The impact of the development on the residential amenity of surrounding properties; ▪ The acceptability of the development in terms of highways capacity and safety; ▪ Any other material considerations.

The principle of development in terms of land use planning policy and sustainable development 7.2 It has been established within the preceding chapter that the site is located within the defined settlement boundary for Llandrindod Wells and is allocated for housing development in the Powys County Council Local Development Plan, adopted in 2018 (Ref: P28 HA3). It is, therefore, clear that the general principle of residential development on the site has been robustly assessed through the LDP site assessment process and it emerged as a suitable site for the allocation of residential land. The delivery of the site for residential development, as proposed, is therefore in compliance with national guidance contained under PPW as well as Spatial Policy 5 and 6 and policy H2 and H5 of the adopted LDP.

7.3 Moreover, the site has been subject to positive pre-application enquiry with the planning authority at Powys County Council, where it was agreed that subject to an appropriate scheme being presented which complies with development management policies and the adoption of the LDP, the principle of residential development on this site would be acceptable.

7.4 In regards to the affordable housing provision and in light of the most up-to-date housing market assessment, the overall requirement for affordable housing and the target contributions identified under Policy H5 of the impending LDP, the provision of at least 30% affordable dwellings is considered to be wholly acceptable for this location and fully in compliance with the pertinent local policies. In fact, the provision of affordable dwellings will assist in achieving the council’s ambitions to deliver 952 units over the plan period. It is likely that Newydd Housing Association who are responsible for the delivery of the phase 1 and 2 development will also deliver the

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 33

affordable housing for phase 3. The tenure is neutral at this stage with further work to be carried out to housing need in the area.

7.5 In light of the above, it is considered that the proposed development is acceptable and compliant with national aim, as contained in PPW and its associated TAN’s and compliant with local planning policies SP5, SP6, H2 and H5.

The impact of the development on the character and appearance of the surrounding area 7.6 The site is located at the western edge of the settlement of Llandrindod Wells. By virtue of its position, it’s considered that the site is well-related to the existing settlement and the surrounding residential context. Its allocation as a housing site in the LDP confirms that the LPA are happy that the character and appearance of the area will not be compromised by virtue of the development of the site for residential purposes.

7.7 The proposed layout plan demonstrates that the potential density of the site and its form, scale, massing and urban grain are acceptable in reflecting the distinctive character of this part of the settlement. The site delivers a medium density development of 33 dwellings per hectare (dph) so that it makes use of a sustainable location whilst ensuring that sufficient land is provided for off-setting drainage easements and in the provision of on-site open spaces. This density of development accords to Policy H4 of the LDP which advocates a density of 27+ within the towns and villages.

7.8 The development has also been designed to complement and enhance the character of the surrounding area and the siting, appearance, integration, scale, height, massing, and design detailing have been consciously selected to ensure that the impact on adjoining residential context has been mitigated as much as possible.

7.9 On this basis, it is considered that the proposed development fully complies with both national and local policies, including DM13 and H3 of the LDP, in that it promotes high quality, healthy, sustainable and locally distinct places and it will not have an unacceptably detrimental impact upon the character and appearance of the surrounding landscape area nor on the adjacent areas of existing residential development along Holcombe Drive.

The impact of the development on the residential amenity of surrounding properties 7.10 The layout presented as part of this planning application demonstrates that the site can be delivered in a sympathetic manner with negligible impacts upon the occupiers of the properties along Holcombe Drive and dwellings currently under construction, to the north, in terms of overshadowing and overbearing as well as a

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 34

positive relationship with each proposed property. The dwellings have been designed so that they have a positive back-to-back relationship with each other and the position of the bungalows along the site’s north-eastern corner is considered a positive addition to ensure the impacts are sufficiently mitigated.

7.11 Internally, the layout has been designed to achieve appropriate amenity standards with each dwelling provided with ample external amenity areas and parking provision which is well related to the associated dwelling. As such, the scheme represents an acceptable relationship, both internally and externally on the neighbouring residential context. As such, it is considered the development is acceptable and the impact on residential amenity has been fully considered in the design process, in accordance with local policies.

The acceptability of the development in terms of highways capacity and safety 7.12 Vehicular parking for the proposed dwellings are to be provided on the basis of one space per bedroom with two spaces provided for all two, three and four-bed properties. Despite being lower than the standards set in Powys’ adopted parking standards, ‘Car Parking Standards, 2017’, it is considered that the site benefits from good connectivity to local facilities and to public transport and the reduction in one space for all three and four bed properties provides an opportunity to present a well-designed scheme which is not overly dominated by parking which in turn establishes better placemaking.

7.13 The site is located within a sustainable location and due to the enhanced connectivity to local facilities, there is scope to reduce the parking for the 3-bed properties. This has also been designed on the basis that car ownership rates for affordable housing are appreciably lower than for open market dwellings and Although the scheme does not provide any formal visitor spaces, the proposed carriageway throughout the site is to be 5.5m wide, which is considered to be sufficient for visitor parking.

7.14 Furthermore, in terms of cycle parking, each proposed dwelling is provided with ample private amenity space which can accommodate either garages or garden sheds which will provide space for secure storage of bicycles.

7.15 Based on all of the above, it’s considered that the development of the site would be acceptable from a highway perspective, in accordance with Policy T1 of the LDP.

Other material considerations 7.16 Trees - The application is supported by a Tree Survey prepared by ArbTs. The indicative site layout has been prepared to take into account the root protection areas of these trees in order for the

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 35

existing trees and hedgerows may be retained as part of the development. It is clearly demonstrated that the site has potential to accommodate development whist retaining the common oak adjacent to the access point; in fact this natural feature has been consciously retained to provide interest at the access and to ensure the development can integrate into the surrounding countryside as much as possible. No trees are identified to be removed to facilitate the construction of the proposed development design. As such, the proposed residential development will not result in any significant loss of trees or hedgerows.

7.17 Ecology - The application is supported by a Preliminary Ecological Appraisal undertaken by Ecological Services Wales. The report recommends that the proposed development has the potential to impact upon nesting birds and reptiles, however, subject to the implementation of the recommendations contained within the report, there should be no ecological reason why the site cannot be developed for residential purposes.

7.18 Phosphate – Pre-application discussions with Dwr Cymru have confirmed that Llandrindod WwTW has phosphate stripping in place, and as we are within our consents to strip phosphates at Llandrindod Wwtw there is capacity to strip the increase in phosphates from the above proposal. Therefore, this is not considered to be an issue in the determination of the planning application.

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 36

Conclusion

8.1 This Planning Statement accompanies the planning submission for residential development and associated works on land to the east of Ithon Road (Phases 3, 4 and 5) in Llandrindod Wells.

8.2 This Planning Statement demonstrates that the principle of development on the site is firmly established; the adopted LDP shows the whole site as a housing commitment site (P28 HA3) and located within the defined settlement boundary for Llandrindod Wells.

8.3 The application is supported by a comprehensive set of supporting plans and documents which all demonstrate that there are no significant constraints which would prevent the development of the site for residential use. In particular, access to the site can be achieved without detriment to the existing highway network or on highway safety and the drainage infrastructure has been fully considered and built into the development.

8.4 It’s considered that the Planning Statement clearly demonstrates that the scheme, as presented, complies with the relevant national and local planning policies H1, H2, H3 and H4 of the LDP, all of which relating to acceptable forms of residential development.

8.5 It is for these reasons that Powys County Council is respectfully requested to grant full planning permission for the development, as proposed.

ITHON ROAD PHASE 3, 4 AND 5, LLANDRINDOD WELLS | PLANNING STATEMENT PA G E | 37

Planning Policy Wales v.10 - National Sustainable Development Placemaking Appraisal Framework Phases 3, 4 and 5 Ithon Road, Llandrindod Wells

PPW

Placemaking Natural

Outcomes Globally

Resilient

Healthier Cohesive Prosperous

More Equal More Manner in which scheme complies

Responsible

Enterprising

Productive & & Productive

Communities

Strategic and and Strategic

Distinctive and and Distinctive

Spatial Choices Spatial Culture Vibrant Active and Social Social and Active

Maximising Environmental Protection and Limiting Environmental Impact Has resilient The site lies within close proximity to the river Ithon, a tributary of the river Wye SAC and, whilst having no direct impact, the development will ensure that water biodiversity and pollutants do not enter the drainage ditch habitat by virtue of pollution prevention measures. ecosystems ● ● ● ● ● ●

Has distinctive and The site is not situated within a National Park or Special Landscape Area, as such, is not subject to protected landscape designations. Notwithstanding it is considered special landscapes that the development will blend seamlessly into the residential context within the western part of Llandrindod Wells, complementing the first two phases of residential ● ● ● ● ● ● ● ● development on land to the north. The development will also be softened to ensure it assimilates into is wider countryside location by selecting appropriate boundary treatments and materials whilst also being sympathetic in terms of location and variety of landscaping and open spaces. Has integrated green The application is accompanied by a proposed layout which illustrates that a large area of Public Open Space will be established in the western part of the site as well as infrastructure within smaller pockets within the internal layout. Furthermore, a carefully selected landscape strategy with appropraite planting will be incorporated. The proposed ● ● ● ● ● ● ● ● ● ● ● development will therefore enhance green infrastructure.

Has appropriate Given the scale and nature of the development, it is considered that no concerns in regard to noise will arise. soundscapes ● ● ● ● ● ● ● ● Reduces Given the nature of the development and the site's previous use, it is not envisaged that any environmental risks will arise. Discussions with Dwr Cymru have confirmed environmental risks the Waste Water Treatment Works at Llandridod Wells has phosphate stripping technology, therefore, the development will not have a detrimental impact on the River ● ● ● ● ● Wye SAC. Manages water The development will be required to accord with the Sustainable Drainage Systems (SuDS) for suface water legislation adopted by Welsh Government in January 2019. A resources naturally ● ● ● ● ● ● ● ● full SAB application will be produced prior to commencment of development. Has clean air Through the adoption of best practice construction methods, it is not envisaged that the development will present any Air Quality concerns. A Construction ● ● ● ● ● ● ● ● ● Environmental Management Plan will be prodcued prior to commencment of development to ensure air quality will not be compromised. Reduces overall Given the site's location within close proximity to the river Ithon, it is vital that the development does not result in pollution spill, particularly during construction phase. pollution As such, the developer will be required to comply with a Construction Environmental Management Plan which will include mitigatory measures to ensure that no impacts ● ● ● ● ● ● ● ● ● ● as a result of pollution arise. Is resilient to climate The site lies within close proximity to services and facilities, therefore reducing the need for long car journeys to commute or shop. Moreover, the development seeks to change improve pedestrian access and promotes active travel principles to provide an enhanced connection to local publioc transport nodes and local amenities. The dwellings ● ● ● ● ● ● ● ● ● ● ● are to be affordable and are therefore required to comply with Welsh Government's DQR standards, as such, will be built with longevity in mind to be resilient to climate change. Has distinctive and The site is not occupied by any listed buildings, nor is it situated within a conservation area. As such, the proposed development will not result in a harmful impact to special historic distinctive and special historic environments. environments ● ● ● ● ● Facilitating Accessible and Healthy Environments Has accessible and Significant landscape planting is to be provided throughout the site. Moreover, the site's position on the edge of settlement means future occupiers will have immediate high quality green access to high quality green space within the site itself and surrounding area. space ● ● ● ● ● ● ● Is accessible by The site is accessible by existing footways providing Active Travel opportunities. The recently re-routed public right of way CF22/1 will facilitate pedestrian movements means of active either through walking or via bike to Llandrindod Wells town centre where local amenity provisions are located. Public Right of Way CF20/1 also runs parallel to the site’s travel and public ● ● ● ● ● ● ● ● ● ● eastern boundary. Cycle Route 825 runs along Ithon Road, the route comprises the majority of the Radnor Ring which is a circular route around the historic transport administrative county of Radnorshire Is not car dependent As mentioned above, the development provides connections with Ithon Road to the west and to the recently re-routed public right of way in order to ensure future occupiers can reach local amenities without the use of a personal car. The site is accessible, with bus services positioned along Holcombe Drive approximately 370m ● ● ● ● ● ● ● ● ● north of the site. Minimises the need The site lies within close proximity to services, public transport nodes and active travel routes. It is therefore considered the development will reduce reliance on the to travel private car. Notwithstanding, should car travel be required, the distances will be minimal given the services and facilities available within surrounding settlements. There ● ● ● ● ● ● ● ● are a number of primary/secondary schools in the surrounding area, all of which are accessible by walking, and public transport Provides equality of Given the affordable nature of the scheme, the dwellings are to be DQR compliant, as such, will be accessible to all. The dwellings will also be designed to ensure that access ● ● ● ● ● ● ● ● they are adaptive to change including provision to accommodate an ageing population. Feels safe and The proposed layout has been carefully designed to deter criminal activity and anti-social behaviour by minimising opportunities to commit crime or to impact negatively inclusive on the quality of life of those using the development. Car parking spaces are overlooked throughout the proposed development, improving levels of natural surveillance. ● ● ● ● ● ● ● ● Access to the rear of the dwellings from public spaces has generally been avoided and parking is in-curtilage or in adjoining courts that are in view of the dwellings. The proposed development will therefore feel safe and inclusive.

Supports a diverse The proposed housing mix comprises 1, 2, 3 and 4 bed properties. It is therefore considered that the development, as a result of the housing mix and compliance with population DQR standards, will be occupied by a wide range of persons with varying needs. As the site can accommodate such a substantial number of units, it will be brought ● ● ● ● ● ● ● ● forward as a scheme of mixed tenure. Has good The site is accessible by existing footways providing Active Travel opportunities. Furthermore, the development provide internal footways throughout on either side of connections ● ● ● ● ● ● ● the adopted carriagweay connecting the site from north-to-south and east-west. Has convenient The site is situated in an inherently sustainable location by virtue of its position adjacent to Llandrindod Wells which forms the administrative centre of Powys County. access to goods and The town offers an array of services and facilities including; post office, library, restaurants, museum, Tesco Superstore, hospital and sports centre. n. services ● ● ● ● ● ● ● Promotes physical It is considered that through the provision of significant landscape planting and given that the site lies within close proximity to community facilities and active travel and mental health routes, the proposed development will promote physical and mental health and well-being. The right of way which runs to the north of the site provides connections to and well-being ● ● ● ● ● ● ● ● ● the wider network providing direct access into the open countryside. Makes best use of natural resources Makes best use of The site occupies a position within the settlement of Llandrindod Wells and within close proximity to facilities and public transport nodes. As such, occupiers will not be natural resources ● ● ● ● ● required to travel far distances to commute or to shop. Prevents waste ● ● ● ● ● Sustainable construction methods will be adopted which will reduce the creation of waste. Prioritises the use of The site comprises of a linear stretch of agricultural land which is allocated as a housing site within Powys County Council's adopted Local Development Plan (P28 HA1). previously developed Therefore, despite not being previously developed land, the site has been assessed as a positive site to deliver much needed affordable housing in the area. land and existing buildings ● ● ● ● ● ● ● ●

Unlocks potential The development possesses the potential to deliver a wholly affordable scheme and contribute to meeting an identified housing shortfall, in accordance with Policy SP3 and regenerates ● ● ● ● ● ● ● ● ● ● of the adopted Local Development Plan. The requirement for affordable housing in Llandrindod Wells is 30% of the overall development.

Is of high quality The homes will be built with longevity in mind to ensure they respond to social, technological, economic and environmental conditions/changes over time, minimising the and built to last ● ● ● ● ● ● ● need to demolish and rebuild. Growing our Economy in a Sustainable Manner Fosters economic Whilst the development does not comprise traditional economic uses, it is considered that the scheme will facilitate short term economic benefits in the form of activity ● ● ● ● ● ● construction works. Enables easy Given the nature of the residential nature of the scheme, communication is not considered to be relevant. communication ● ● ● ● ● ● ● ● Generates its own Given the nature of the residential nature of the scheme, renewable energy not considered to be relevant. renewable energy ● ● ● ● ● Is vibrant and The layout as proposed will foster activity and interaction between occupiers with the surrounding communities and facilities. It will also conect with the first two phases dynamic ● ● ● ● ● ● ● ● ● ● on land to the north which will increase the potential for social interaction Is adaptive to Given the 100% affordable nature of the scheme, the dwellings will be required to conform to DQR standards. As such, will be adaptive to change, particularly for an change ● ● ● ● ● ● ● ageing population. Embraces smart and Whilst not strictly relevant to a residential development, it is considered that the homes will be built with technological longevity in mind to ensure that they are able to innovative respond to technological advances. Moreover, the development will be connected to digital infrastructure enabling internet connection for all homes. technology ● ● ● ● ● ● ● Creating and Sustaining Communities Enables the Welsh The site lies within close proximity to Ysgol Trefonnen, a bilingual Primary School, Ysgol Calon Cymru, a bilingual secondary school as well as Coleg Powys. As such, language to thrive children of the development will have the opportunity to undertake their education through the medium of Welsh and contribute the Welsh Government's goal of ● ● ● ● ● ● reaching a million Welsh Speakers by 2050 Has appropriate The development comprises a housing density of 77no. affordable dwellings on a site measuring 2.6 hectares in extent which comprises a housing density of approx 33 development dwellings per hectare. This falls slightly short of the recommended density contained within Policy H4 of the adopted LDP which advocates a denisty of 27+ within towns densities ● ● ● ● ● ● ● ● and large villages. This takes into account the relevant amenity provision, parking, open space and SuDS as well as the foul drainage easement which runs through the site. Has homes and jobs The site is allocated as a housing site within the adopted Local Development Plan, therefore, it has aready been assessed as a deliverable site with adequate local to meet society’s facilities to cater for the prospective residents. needs ● ● ● ● ● ● ● Has a mix of uses The development comprises 77no. dwellings which are to be 100% affordable. The site is a housign allocation, therefore, the scope to provide a mix of uses on the site is inherently limited. The development will assimilate into its wider residential context and it would not be appropriate for any other use on this site due to its location on ● ● ● ● ● ● ● ● ● the edge of the settlement. Land to the south and east are playing fields assocaited with the school, therefore, residential development is considered to be the most appropriate use for this site. Offers cultural Given the nature of the residential nature of the scheme, cultural experience are not considered to be relevant. experiences ● ● ● ● ● ● ● ● ● ● Has community The proposed development site is located within close proximity to an array of services and facilities in the settlement of Llandrindod Wells, itself sitting on the highest based facilities and tier of the settlement strategy for Powys. services ● ● ● ● ● ●