Application for Full Planning Permission Former Quinn

APPLICATION FOR FULL PLANNING PERMISSION

FORMER QUINN RADIATOR FACTORY, IMPERIAL PARK, NEWPORT

APPLICATION FOR FULL PLANNING PERMISSION FOR THE CHANGE OF USE OF THE MAIN BUILDING FROM B2 (GENERAL INDUSTRIAL) AND B8 (STORAGE AND DISTRIBUTION) USE CLASS WITH ANCILLARY B1 (BUSINESS) USE TO FLEXIBLE USE CLASS COMPRISING B1 (BUSINESS), B2 (GENERAL INDUSTRIAL) AND B8 (STORAGE AND DISTRIBUTION) TO ALLOW THE SUBDIVISION OF THE BUILDING TO CREATE 5 NEW UNITS WITH ASSOCIATED WORKS

PLANNING STATEMENT

FEBRUARY 2021

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CONTENTS

Chapter 1 Introduction

Chapter 2 Site and Surroundings

Chapter 3 Development Proposals

Chapter 4 Planning Policy Context

Chapter 5 Material Considerations

Chapter 6 Summary and Conclusion

APPENDICES

Appendix 1 - Planning Policy Context

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EXECUTIVE SUMMARY

This Planning Statement outlines that, on the basis of and informed by a comprehensive review of both the policy and physical context of the application site, the site is considered to be suitable to accommodate a change of use for the sub-division of the main building to allow flexible uses of B2/B8 use classes per unit and general associated work, and therefore the proposals should be viewed favourably for the following reasons:

The proposed development seeks to change the existing use factory to a variety of B Class Uses on a brownfield site within a sustainable location.

It is considered that there are several material considerations in support of the application, including the following:

• The site lies within settlement boundary limits and on an under-utilised, vacant brownfield site; • The principle of developing the site as an employment would be acceptable in principle in terms of the LDP; • The proposal will benefit economically both the city of Newport and the wider Cardiff Capital City Region; • The change of use will create employment opportunities in the locality and improve Imperial Park as an ‘employment hub’; • The development would not result in a harmful impact on the residential amenity of the neighbouring properties; • The proposals would not result in an adverse highways impact, and the parking provision is considered acceptable given the sustainable location of the site; • It is not envisaged that there would be any adverse impacts in respect of flood risk, PRoWs and landscape.

Having regard to the above material considerations, it is considered that the proposed development represents an appropriate and policy compliant scheme, which makes good use of this existing site to the benefit of the wider community.

Accordingly, it is considered that the proposed development comprises a high-quality employment scheme in a much-needed location and is acceptable by way of its location, design, scale, community safety and its minimal environmental impacts. We therefore respectfully request that this application be approved.

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1.0 INTRODUCTION

1.1 This Planning Statement has been prepared in support of an application for Full Planning Permission, submitted on behalf of F55 Sterling Newport S. à r. l. in relation to the following development proposal at the Former Quinn Radiator Factory, Imperial Park, Newport.

“APPLICATION FOR FULL PLANNING PERMISSION FOR THE CHANGE OF USE OF THE MAIN BUILDING FROM B2 (GENERAL INDUSTRIAL) AND B8 (STORAGE AND DISTRIBUTION) USE CLASS WITH ANCILLARY B1 (BUSINESS) USE TO FLEXIBLE USE CLASS COMPRISING B1 (BUSINESS), B2 (GENERAL INDUSTRIAL) AND B8 (STORAGE AND DISTRIBUTION) TO ALLOW THE SUBDIVISION OF THE BUILDING TO CREATE 5 NEW UNITS WITH ASSOCIATED WORKS.”

1.2 This Planning Statement outlines the context within which the application is made and provides a detailed examination of the main planning considerations raised by the proposals, together with reasoned justification in support of the proposed development.

1.3 The statement is structured as follows:

• Section 2 provides a description of the characteristics of the site and surrounding area, and details regarding the planning history associated with the site; • Section 3 provides details of the development proposals; • Section 4 outlines the relevant planning policy framework in relation to the site and the development; • Section 5 analyses the key planning considerations arising from the proposed development (considering the planning policy context); • Section 6 sets out our conclusions.

Documents submitted in support of Application

1.4 The following documents are submitted in support of the application, and should be read alongside this planning statement:

• Planning Application Form; • Plans & Drawings; • Plans and Drawings: o 312_A(--)001B Proposed Site Plan; o 312_A(--)002A Proposed Ground Floor Plan; o 312_A(--)003A Proposed First Floor Plan; o 312_A(--)004A Proposed Roof Plan; o 312_A(--)005A Proposed Elevations; o 312_A(--)101A Prop. Unit 1 Ground Plan; o 312_A(--)102A Prop. Unit 2 Ground Plan; o 312_A(--)103A Prop. Unit 3 Ground Plan; o 312_A(--)104A Prop. Unit 4 Ground Plan; o 312_A(--)105A Prop. Unit 5 Ground Plan; o 312_A(--)204A Prop. Unit 4 First Plan; o 312_A(--)205A Prop. Unit 5 First Plan; o 312_A(--)301A Proposed SOUTH Elev. Ext-01; o 312_A(--)302A Proposed SOUTH Elev. Ext-02; o 312_A(--)303A Proposed SOUTH Elev. Ext-03; o 312_A(--)304A Proposed NORTH Elev. Ext-01; o 312_A(--)305A Proposed NORTH Elev. Ext-02; o 312_A(--)306A Proposed NORTH Elev. Ext-03; o 312_A(--)307A Proposed WEST Elev. Ext-01; o 312_A(--)308A Proposed WEST Elev. Ext-02; o 312_A(--)309A Proposed EAST Elev. Ext-01;

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o 312_A(--)310A Proposed EAST Elev. Ext-02; o 312_A(--)500A Proposed Area Schedule; o 312_L(--)001A Existing Site Plan; o 312_L(--)002A Existing Ground Floor Plan; o 312_L(--)003A Existing First Floor Plan; o 312_L(--)004A Existing Roof Plan; o 312_L(--)005A Existing Elevations; o 312_L(--)301A Existing SOUTH Elev. Ext-01; o 312_L(--)302A Existing SOUTH Elev. Ext-02; o 312_L(--)303A Existing SOUTH Elev. Ext-03; o 312_L(--)304A Existing NORTH Elev. Ext-01; o 312_L(--)305A Existing NORTH Elev. Ext-02; o 312_L(--)306A Existing NORTH Elev. Ext-03; o 312_L(--)307A Existing WEST Elev. Ext-01; o 312_L(--)308A Existing WEST Elev. Ext-02; o 312_L(--)309A Existing EAST Elev. Ext-01; o 312_L(--)310A Existing EAST Elev. Ext-02; o 312_L(--)500A Existing Area Schedule; and o 312_L(--)1000A Location Plan. • Design and Access Statement; and • Transport Statement.

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2.0 SITE AND SURROUNDINGS

The Site

2.1 The site, Former Quinn Radiator Factory, sits within the Imperial Park situated on the outskirts of Newport which comprises manufacturing, distribution and warehousing facilities and offices. The site sits within a much larger and wider strategic employment area that includes Airbus, R&D centres, and Gocompare.com. The site itself, contains 6 units, currently for the uses of B2 (General Industrial) and (B8 Storage and Distribution). Ancillary to the factory is an office space which is established as a B1 (Business) use. The site is currently vacant. The site comprises approximately 16.49ha and the location is shown in the red line plan below:

Aerial View of the Site

2.2 The site was most recently occupied by Quinn Radiators Limited as a radiator production facility. The site currently comprises a large warehouse building, two smaller warehouses and an ancillary office building. Access to the site is provided via an unnamed road that connects to the A48. The site is well located in terms of access to the M4 which enables travel to Newport, Cardiff, Swansea and Bristol.

2.3 Images depicting the site, including the warehouse and the associated offices, and its access are provided overleaf:

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Image of Warehouse Building from the West

Image of the Western Access to the Site

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Image of the Roundabout located on the Site’s Western Boundary

Image of the Main Warehouse/Distribution Building from the East

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Image of Associated Offices from the East

Image of Eastern Access to Site

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The Surroundings

2.4 The site is bound by industrial development to the north and east within Imperial Park. The western boundary is bounded by a dual-carriageway from linking to the A48 and a small residential area further afield. South of the site is developed land, albeit it is vacant.

2.5 As forementioned, the site is located within an area allocated for employment uses and comprises a variety of companies / organisations including, most famously, Airbus, Dwr Cymru Welsh Water, NHS and Office for National Statistics (ONS).

Employment unit north of the site

2.6 The site is located within a sustainable location – in close proximity to a number of local facilities and services. The site is within a close distance to Lloyds Bank, The Vanilla Pod Coffee Bar and the Parc Golf Club.

2.7 In terms of public transport provision, the nearest bus stop is located north of the site, 0.5km away and provides access to both Cardiff and Newport via sustainable travel.

2.8 It is therefore considered that the site is located within a sustainable location and is well provided for in terms of services and facilities including some sufficient public transport.

PLANNING HISTORY

2.9 In assessing the site for development, a planning history search for the site has been undertaken using the planning application search register on the council’s website. The site has an extensive planning history and an executive summary is provided below:

Application Location Proposal Decision Decision Reference Date The Site 07/0720 Celtic Way, Celtic Lakes Certificate of Lawfulness for 26/09/2008 Refused proposed use of existing buildings to accommodate electrical energy storage plant 05/0207 Former LG Electronics Change of use to radiator 28/07/2005 Granted Site, Imperial Park, manufacturing plant together Coedkernew, Newport with alterations and extension

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The Surroundings 20/1176 Land South of Unit 3, Erection of two storey data - Awaiting The Courtyard, Imperial centre buildings comprising B8 Decision Park, Coedkernew, Use and ancillary B1C use, Newport, South Wales provision of emergency generators, roof mounter air handling units, security cabin and vehicle airlock, fencing and CCTV, lighting, hard and soft landscaping, car parking and sustainable drainage 10/0073 Unit 4, The Courtyard, Change of use to cardiac 29/03/2010 Granted Imperial Park, diagnostic centre Coedkernew, Newport, NP10 8UL 02/0383 Units 2 & 3, Imperial Change of use of existing 15/05/2002 Granted Park, The Courtyard, building from the welsh Newport semiconductor training centre to research and development of semiconductors (Class B1)

2.10 The two applications that are considered to have the most relevance to the determination of the proposals are discussed below. Including its current use that was previously approved and discussed further below:

Application Ref. 07/0720

2.11 This application sought a Certificate of Lawfulness for the proposed use of the existing building to accommodate an electrical energy storage plant, which was subsequently refused on 26 September 2008.

2.12 The application was refused on the basis that there was insufficient evidence submitted to prove that the proposed use could be classed as B2 Use. The Officer’s Report outlined that the proposed used did not fall within the description of Class B2 (General Industrial) as defined in article 2 of the Town and Country Planning (Use Class) Order 1987. 2.13 It was also outlined that it was possible that the proposed use was within Use Class B8 (Storage), but whilst there were permitted development rights of use from B2 to B8, this was subject to a floor space restriction of 235 square metres which the site exceeded.

Application Ref. 05/0207

2.14 An application was submitted and approved for the change of use of the plant to a radiator manufacturing plant together with alterations and extension. The application was approved on 28th July 2007 with conditions.

2.15 The proposed site layout from this application is provided below for reference.

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05/0207 Proposed Site Plan

2.16 No Officer’s / Committee’s Report is available for this application on the Council’s portal.

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3.0 DEVELOPMENT PROPOSALS

3.1 This application seeks the approval of Full Planning Permission for:

“Application for Full Planning Permission for the change of use of the main building from B2 (General Industrial) and B8 (Storage and Distribution) Use Class with Ancillary B1 (Business) Use to Flexible Use Class Comprising B1 (Business), B2 (General Industrial) and B8 (Storage and Distribution) to allow the subdivision of the main building to create 5 new units with associated works.”

3.2 The proposed development comprises the following works:

• Internal subdivision of the large warehouse building to create 5 new units comprising B2 (General Industrial) and B8 (Storage and Distribution) Class Uses; • The retention of the ‘existing office building’ at B1 office space for the wider complex; • The retention of the ‘existing building’ (as annotated on the plans), for B2/ B8 uses as a standalone unit, and the provision of new service bays on this southern elevation; • The retention of the existing pump house; • Minor re-configuration to the hardstanding areas to appropriately accommodate servicing areas, vehicle circulation and parking; • Creation of openings to western, eastern and southern elevations of main building to establish new loading doors for each unit; and • Removal of western parking area to create new service areas, parking to be re-provided in eastern area of site.

3.3 The proposal seeks to change the existing use of the Former Quinn Radiator Factory to a flexible use comprising B1 (Business), B2 (General Industrial) and B8 (Storage and Distribution). This flexibility allows the owners of the units to market the vacant factory to a wide variety of suitors.

3.4 The proposals also comprise the subdivision of the units to allow more future tenants to occupy the building in the foreseeable future. The proposals are to divide the large warehouse building into five smaller units through internal re-configuration and provide some minor re- configuration to the hardstanding areas to appropriately accommodate new servicing areas for each unit.

3.5 The gross internal area (GIA) for each unit is set out as follows:

• Unit 1: 8,890 sqm • Unit 2: 15, 908 sqm • Unit 3: 11, 557 sqm • Unit 4 (Ground Floor): 15, 322 sqm • Unit 4 (First Floor): 15, 368 sqm • Unit 5 (Ground Floor): 14, 065 sqm • Unit 5 Canopy: 2, 100 sqm • Unit (First Floor): 1, 567 sqm.

• Total GIA: 84, 777 sqm

3.6 The total floorspace of the main building is the same for the existing use as the proposed use, therefore, there will be no net gain / loss in floorspace.

3.7 The proposals do not comprise any changes to the size of the building or additional hardstanding or structures. As such, there will be no material changes to the office building (this will be retained as an o or the two smaller warehouses.

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3.8 A proposed site layout is provided below:

Proposed Site Plan

3.9 As shown above, the proposals only seek to re-configure the existing floorspace of the main building to create 5 units at the site. New loading docks for each unit will also be implemented as part of the development.

3.10 The ‘existing building’ labelled above will continue to function as a B2/B8 facility and will see new loading bays added to the southern elevation. Whilst the ‘existing office’ building will remain as a B1 office function for the overall site.

3.11 The above extract clearly shows the proposed uses of B2/B8 have been ‘blanket applied’ to the units to allow for flexibility to future occupiers.

Operational Vehicle Traffic Routing within the site

3.12 The main access to the site for all vehicles will be via the western entrance and all vehicles will depart via the eastern exit of the site. The above plan outlines the proposed access routes for vehicles using each unit within the site and this clearly shows the proposed internal highway layout of the site.

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3.13 The proposed elevations of the main building depicting the new service areas are provided below:

Proposed Southern Elevation of Main Building

Proposed Western Elevation of Main Building

Proposed Eastern Elevation of Main Building

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4.0 PLANNING POLICY CONTEXT

4.1 A review of the planning policy context associated with the site and proposed development (at the national and local level) is provided within this section of the Planning Statement.

4.2 The key planning policies of relevance to the determination of the application are outlined below. A detailed assessment of how the proposed development accords with these policies is provided in Section 5 (Material Considerations) of this Statement.

National Planning Policy

4.3 The following policy / guidance documents prepared at the national (Welsh Government) level is of relevance to the determination of this planning application.

Planning Policy Wales (10th Edition, December 2018)

Key Planning Principles

4.4 Paragraph 2.13 states that “The plan-led system underpins the delivery of sustainable places. To ensure all development plans and decisions taken by the planning system work together to deliver sustainable places. The 5 Key Principles (see Figure 3) represent a guiding vision for all development plans, including the NDF”. The key principles are as follows:

• Growing our economy in a sustainable manner; • Making best use of resources; • Facilitating accessible and healthy environments; • Creating and sustaining communities; • Maximising environmental protection and limiting environmental impact.

4.5 Paragraph 2.17 states “In responding to the key principles for the planning system, the creation of sustainable places and in recognition of the need to contribute to the well-being of future generations in Wales through placemaking, development plans and development proposals must seek to deliver development that address the national sustainable placemaking outcomes”.

4.6 Paragraph 2.22 provides the key factors in the assessment process with regards to economic development. This includes:

• “The numbers and types of long-term jobs expected to be created or retained; • Whether, and how far, the development will help redress economic disadvantage or support regeneration priorities, for example by enhancing local employment opportunities or upgrading the environment; • The contribution the development would make to achieving wider strategies, for example the growth or regeneration of certain areas; • The contribution this economic activity will have to wider policy goals; and • How the proposal would support the achievement of a more prosperous, low carbon, innovative and resource efficient Wales.”

4.7 Significantly, PPW requires that the planning system should support economic and employment growth which generate economic prosperity and regeneration where possible. (Paragraph 5.4.3) To this end, the planning system, including planning policies, should aim to ensure that the growth of output and employment in Wales as a whole is not constrained by a shortage of land for economic uses.

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Sustainability

4.8 Sustainable development forms a key consideration central to all policies contained within PPW10. Paragraph 2.1 states: “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”.

4.9 Paragraph 2.17 of PPW10 sets out that “The relationship between development proposals, planning policy topics and the well-being goals is complex. At a strategic level traditional planning policy topics are clustered around four distinctive themes.”

4.10 Paragraph 2.24 sets out how to assess the sustainable benefits of development:

“Planning authorities should ensure that economic, social, cultural and environmental benefits are given equal consideration in the decision - making process, by following the five Ways of Working, to ensure 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 when one type of benefit it of a development proposal or site allocation outweighs others, and in such cases robust evidence should be presented to support these decisions, whilst seeking to maximise contribution against the well - being goals.”

4.11 Moreover, in respect of the Re-Use of Previously Developed Land Paragraph 3.51 states: “Previously developed land in settlements should generally be considered suitable for development because their re-use will promote sustainability principles.”

National sustainable placemaking outcomes

4.12 Figure 5 on page 21 outlines how PPW should be used to achieve sustainable places in diagram format:

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PPW Figure 5

4.13 Paragraph 2.2 sets out how to assess the sustainable benefits of development:

“Planning authorities should ensure that economic, social, cultural and environmental benefits are given equal consideration in the decision-making process, by following the five Ways of Working, to ensure 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 when one type of benefit of a development proposal or site allocation outweighs others, and in such cases robust evidence should be presented to support these decisions, whilst seeking to maximise contribution against the well-being goals. In assessing these benefits, key factors include:

Economic Considerations

• The numbers and types of long-term jobs expected to be created or retained; • Whether and how far the development will help redress economic disadvantage or support regeneration priorities, for example by enhancing local employment opportunities or upgrading the environment; • A consideration of the contribution to wider strategies, for example for the growth or regeneration of certain areas; • The contribution this economic activity will have to wider policy goals, for example in the green growth sector; and • How does the proposal support achievement of a more prosperous, low carbon, innovative and resource efficient Wales.

Social Considerations

• Who are the interested and affected people and communities; • How does the proposal change a persons way of life, which can include: • How people live, for example, how they get around and access services; • How people work, for example, access to adequate employment; • How people socialise, for example, access to recreation activities; and • How people interact with one another on a daily basis. • Who will benefit and suffer any impacts of the proposal;

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• What are the short and long-term consequences of the proposal on a community, including its composition, cohesion, character, how it functions and its sense of place; and • How does the proposal support development of more cohesive communities.

Cultural Considerations

• How far the proposal supports the conditions that allow for the development and growth of the Welsh Language; • Whether or not the development protects areas and assets of cultural and historic significance; • Have the cultural links and their relationships with the tourism industry been appropriately maximised; if the proposal protects areas known for their cultural value in terms of music, literature, sport and the arts; and • Vibrant cultural experiences.

Environmental Considerations

• Will important features of the natural, historic and built environment be protected and enhanced; • Are the environmental impacts of development on health and amenity limited to acceptable levels and the resilience of ecosystems improved; • Is environmental protection for people, natural and cultural resources, property and infrastructure maximised and environmental risks prevented or appropriately managed; • Will high standards of restoration, remediation, decommissioning and beneficial after uses be achieved; • Will the depletion of non-renewable resources be minimised, waste prevented and the efficient and most appropriate use of materials made and re-use and recycling promoted; • Will the causes and impacts of climate change be fully taken into account through location, design, build, operation, decommissioning and restoration; and • Does it support decarbonisation and our transition to a low carbon economy”

Good Design

4.14 Paragraph 2.27 states:

“Good design is fundamental to creating sustainable places where people want to live, work and socialise and enjoy. Design is not just about the architecture of a building but the relationship between all elements of the natural and built environment. To achieve sustainable development, design must go beyond aesthetics and include the social, environmental, cultural and economic aspects of the development, including its construction, operation and management, and the relationship with its surroundings.”

4.15 Paragraph 3.4 sets out the above in an illustrative / diagrammatic manner.

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Planning Policy Wales Figure 7

Economic Development

4.16 Paragraph 5.4.1 states that the Welsh Government defines economic development as development of land and buildings for activities that generate wealth, jobs and incomes.

4.17 Paragraph 5.4.13 states that Planning authorities should aim to:

• Co-ordinate development with all forms of infrastructure provision such as transport and utilities; • Support national, regional, and local economic policies and strategies; • align jobs and services with housing and sustainable transport infrastructure, to reduce the need for travel, and dependency on travel by car; • Promote the re-use of previously developed, vacant and underused land; • deliver physical regeneration and employment opportunities to disadvantaged communities; • Control and manage the release of unwanted employment sites to other uses; • Propose specific locations for locally and strategically important industries which are detrimental to amenity and may be a source of pollution; and • Identify protection zones around land and premises that hold hazardous substances and protect the ability of existing businesses to operate or expand by preventing the incremental develop.

4.18 Paragraph 5.4.4 of PPW states that ‘Wherever possible, planning authorities should encourage and support developments which generate economic prosperity and regeneration. Sites identified for employment use in a development plan should be protected from inappropriate development.’

4.19 Paragraph 5.4.14 outlines that ‘Planning authorities should aim to:

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• co-ordinate development with all forms of infrastructure provision such as transport and utilities; • support national, regional, and local economic policies and strategies; • align jobs and services with housing and sustainable transport infrastructure, to reduce the need for travel, and dependency on travel by car; • promote the re-use of previously developed, vacant and underused land…’

Technical Advice Notes

4.20 Technical Advice Notes (TANs) supplement the policy principles of PPW and add further detail on issues which might affect development potential of the site. TANs which are considered relevant to the proposal and should therefore be given weight are:

TAN Title TAN 12 Design (2016) TAN 18 Transport (2007) TAN 23 Economic Development (2014)

Technical Advice Note (TAN) 12 – Design (2016)

4.21 Further detailed guidance on the objectives of good design as set out in PPW is provided within TAN 12. The objectives of good design are set out within the following categories:

Access • Ensuring ease of access of all.

Character • Sustaining or enhancing local character • Promoting legible development • Promoting a successful relationship between public and private space • Promoting quality, choice and variety • Promoting innovative design.

Community Safety • Ensuring attractive, safe public spaces; and • Security through natural surveillance.

Environmental Sustainability • Achieving efficient use and protection of natural resources; • Enhancing biodiversity; and • Designing for change.

Technical Advice Note (TAN) 18: Transport (2007)

4.22 TAN 18 describes how to integrate land use and transport planning. It includes advice on transport related issues when planning for new development including integration between land use planning and transport, location of development, parking and the design of development.

Technical Advice Note (TAN) 23: Economic Development (2014)

4.23 This advice note provides guidance on proposed developments that seek to generate wealth, jobs and income.

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4.24 Paragraph 1.1.6 outlines that the traditional land use class B1-B8 must continue to be planned for in a sustainable way as they form the cornerstone of many development plan employment policies and site allocations.

4.25 Relating to the economic visions of local planning authorities, 4.3.5 states the following:

“local planning authorities should assess current and future business requirements, considering potential new inward investment opportunities and new start-ups as well as established local firms. They should search for opportunities to create better and more competitive business locations, responding to business requirements and filling any gaps in supply.”

Local Planning Policy

Local Development Plan

4.26 The current (adopted) Development Plan for Newport City Council consists of the Newport Local Development Plan (LDP) 2011-2026. This Development Plan was formally adopted by the Council in January 2015.

4.27 The Newport LDP Proposal Map is extracted below.

Newport LDP Proposals Map

Key:

Employment

Archaeologically Sensitive Area

Countryside

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Environmental Space

Green Wedge

Special Landscape Areas

Urban Boundary

Site

Newport LDP Constraints Map

Key:

Current M4 Relief Polygon July 2014

Current M4 Protected Corridor

TAN 15 Zone B

TAN 15 Zone C1

Landscape of Outstanding Historic Interest

Site

4.28 To summarise, in terms of its designations, the site is:

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• Located within the defined settlement boundaries of Newport; • Immediately adjacent to an employment allocation; • Adjacent to an Archaeologically Sensitive Area; • Adjacent to the Countryside and Green Wedge; • Adjacent to a Special Landscape Area; • Partially sits within a Tan 15 Zone B area; and • Partially sits within a Landscape of Outstanding Historic Interest.

4.29 In light of the above, the following Local Planning Policies are considered to be of relevance:

Policy Title Summary

Proposals which make a positive contribution to sustainable development are SP1 Sustainability favoured. Development should be directed away from areas where flood risk is identified as SP3 Flood Risk a constraint and ensure that the risk of flooding is not increase elsewhere. Conservation of the The conservation, enhancement and management of recognised sites within the SP9 Natural, Historic and natural, historic and built environment will be sought in all proposals. Built Environment Enables contributions to be sought from developers that will help deliver SP13 Planning Obligations infrastructure which is necessary to support development Provision will be made for approximately 172 hectares of employment land for the SP17 Employment Land period 2011-2026. Development will not be permitted where it has a significant adverse effect on local General Development amenity in terms of noise, disturbance, overbearing, light, odours and air quality. GP2 Principles – General Development will not be permitted which is detrimental to the visual amenity. Amenity Proposals should seek to design out crime and anti-social behaviour, promote inclusion and provide adequate amenity for future occupiers. Development should provide appropriate access for pedestrians, cyclists and public General Development transport along with appropriate car parking and cycle storage. Development GP4 Principles – Highways should not be detrimental to the highway, highway capacity or pedestrian safety and Accessibility and should be designed to enhance sustainable forms of transport and accessibility. Proposals should be designed to protect and encourage biodiversity and ecological connectivity and ensure there are no negative impacts on protected habitats. General Development Proposals should not result in an unacceptable impact of water quality or the loss GP5 Principles – Natural or reduction in quality of agricultural land (Grades 1, 2 and 3A). There should be Environment no unacceptable impact on landscape quality and proposals should enhance the site and wider context including green infrastructure and biodiversity. Good quality design will be sought in all forms of development. In considering General Development proposals, a number of factors are listed which should be considered to ensure a GP6 Principles – Quality of good quality scheme is developed. These include consideration of the context of Design the site; access, permeability and layout; preservation and enhancement; scale and form of the development; materials and detailing; and sustainability. General Development Principles – Development will not be permitted which would cause or result in unacceptable GP7 Environmental harm to health. Protection and Public Health Routeways, Corridors Development proposals should protect and enhance the appearance and CE1 and Gateways connectivity of existing and future main route corridors and gateways into the city. T4 Parking Development will be expected to provide appropriate levels of parking.

Supplementary Planning Guidance

4.30 The following published Supplementary Planning Guidance is considered relevant to the current application.

• Planning Obligations (2020); and • Parking Standards (2015).

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5.0 MATERIAL CONSIDERATIONS

5.1 The key planning considerations arising from the proposed development (considering the nature and form of the proposed development, the planning policy context, outlined within the preceding section of the Statement) are as follows:

• Principle of Development; • Economic Development; • Highways and Access; • Residential Amenity; • Landscape; • Servicing; • Flood Risk; and • Other Considerations.

Principle of Development

5.2 The proposed development seeks the approval for the flexible uses of the site comprising B1 (Business), B2 (General Industrial) and B8 (Storage and Distribution). The change of use will also include the subdivision of the main building to provide 5 no. of units.

5.3 In terms of its location, the site sits within an employment park that comprises a variety of companies operating within the B Use Classes. As such, the proposed change of use to the above conforms to the surrounding uses of the site and will not undermine the function of the employment uses. The development will also result in smaller units at the site which will allow for greater flexibility within the current economic market conditions. For larger units, there are limited requirements, so therefore, the proposed subdivision will support the site’s viability and potential to bring it back into use.

5.4 Policy SP1 ‘Sustainability’ outlines that proposals are required to make a positive contribution to sustainable development by concentrating development in sustainable locations on brownfield land within the settlement boundary.

5.5 The Foreword by the Cabinet Secretary for Energy, Planning and Rural Affairs within PPW10 outlines the following:

‘Productive and Enterprising places are those which promote our economic, social, environmental and cultural well-being by providing well-connected employment and economic development in pleasant surroundings.’

5.6 As such, the above quotation highlights the importance that proposals promote well-being characteristics to create productive and enterprising places which is achieved by providing well- connected employment and economic development in appropriate locations. Within the context of this application, it is considered that the proposal represents the above quotation in that it will enhance the productivity of the locality, situated within a sustainable and well-connected location and will result in employment opportunities created.

5.7 It is considered that the proposal complies with the above requirements, as it sits within the urban settlement boundary of Newport, and it seeks to change the use of an existing building that sits on brownfield land within a sustainable location. Further to this, the site sits within close proximity to several key services and facilities in the locality. As forementioned, bus stops are located within walking distance to the site which offer services to the cities of Cardiff and Newport. This, therefore, offers sustainable travel to employers / employees working at the proposed B Class site.

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5.8 Therefore, it is considered that the proposal makes efficient use of land and that it will bring back brownfield land into use. As such, this proposal complies with the requirements of Policy SP1 ‘Sustainability’.

5.9 Therefore, it is considered that the principle of development is acceptable in principle in terms of its proposed uses and location.

Economic Development

5.10 The proposed change of use of the site is considered to bring a wide range of economic benefits to Newport, and the proposal is supported by guidance set out in PPW10 in terms of its economic prosperity.

5.11 Paragraph 5.4.4 states that local planning authorities should encourage and support development proposals which generate economic prosperity and regeneration. As aforementioned, the proposal seeks to bring back a vacant site into use for economic benefit and therefore complies with PPW10 guidance on economic development.

5.12 It is considered that this proposed change of use will improve the vitality and attractiveness of businesses locating to Imperial Park and subsequently, support the agglomeration of businesses in the locality. Imperial Park is considered to be a key employment hub in the western area of Newport and as such, this proposal will support the park’s important economic role within the Newport economy and support the local economy itself.

5.13 Further to the above, the change of use represents a prosperous and viable economic proposal that will not only benefit the ever-growing city of Newport, but also the wider Cardiff Capital City Region. The site sits within a key location within South Wales adjacent to the M4, and as such, can be accessed by a wider population in the region. Paragraph 5.4.10 of PPW10 outlines that ‘effective planning for the economy requires planning authorities to work strategically and co-operatively directing development and investment to the most efficient and most sustainable locations, regardless of which local authority area they are in.’ Therefore, the proposal’s potential to benefit not only Newport but also the wider region is strongly supported by national planning policy.

5.14 Insofar as employment is concerned, given the current economic climate, the proposal will create a platform to increase employment opportunities in Newport and the South Wales region.

5.15 Policy SP18 ‘Urban Regeneration’ favours proposals which assist the regeneration of the urban area, particularly where they contribute to:

i. ‘The vitality, viability and quality of the environment of the city centre; ii. The provision of residential and business opportunities with the urban area; iii. Reuse of vacant, underused or derelict land; iv. Encourage the development of community uses where appropriate.’

5.16 It is considered that the proposal will conform to criterions (ii) and (iii) in the above policy as it will seek to improve business opportunities within the defined urban settlement of Newport. The proposal will also reuse vacant land that is located close to existing facilities and services, and in turn will make good use of available hard and soft infrastructure in the locality.

5.17 Therefore, the proposed change of use will improve Imperial Park as an important employment hub along the M4 corridor in South Wales, create employment opportunities and support the economy of Newport and the wider Cardiff Capital City Region.

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Highways and Access

5.18 As forementioned, the site will make use of the existing accesses provided to the site, both east and west of the units. The below proposed site plan depicts the proposed travel routes within the internal highway network:

Operational Vehicle Traffic Routing within the Site

5.19 As shown above, all vehicles will enter the site from the western entrance and depart via the eastern entrance apart from any potential emergency vehicles. The above plans also depicts the proposed routes vehicles will take within the site depending on which unit they are servicing. This is discussed further below in the servicing section.

5.20 Policy GP4 ‘General Development Principles – Highways and Accessibility’ sets out that development proposals should:

i. ‘Provide appropriate access for pedestrians, cyclists and public transport in accordance with national guidance; ii. Be accessible by a choice of means of transport; iii. Be designed to avoid or reduce transport severance, noise and air pollution; iv. Make adequate provision for car parking and cycle storage; v. Provide suitable and safe arrangements; vi. Ensure that development would not be detrimental to highway or pedestrian safety or result in traffic generation exceeding the capacity of the highway network.’

5.21 It is considered that the proposed development will comply with the above principles of Policy GP4 in that it will enable appropriate access for all means of travel, provide appropriate car parking provision as well as cycle storage and will ensure that there are suitable and safe arrangements in place. Further to this, the development will not materially impact to highway / pedestrian safety in the locality.

5.22 As part of this submission, a Transport Statement has been undertaken and prepared by Apex Consulting and please refer to this standalone document for greater detail and assessment. However, a succinct summary is provided below.

5.23 In relation to the proposed vehicle movements at the site, the report found that the proposed change of use could reduce movements in the peak hours and over a daily period. The analysis undertaken as part of the transport assessment confirmed the original conclusion that the

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proposals are unlikely to result in an increase in vehicle movements. Therefore, it is considered that the proposals will have no material impact upon road safety or highway capacity in the locality.

Servicing

5.24 As the main building is proposed to be divided into five different units, the servicing arrangements will change, and each individual unit will require access by articulated vehicles. As such, the internal site layout will be altered to enable servicing movements to be made safely and appropriately through the site, whilst also separating operational traffic from light vehicle traffic.

5.25 The routing enables access to all service areas within the site from both the east and west, although deliveries to units 2 and 3 will be encouraged to use the west access and unit 1,4 and 5 to use the east access, where possible. In order to facilitate this and to ensure that the internal traffic operates efficiently, a one-way clockwise route along the norther permitter will be in pace with vehicles routing around the outside of the service yard for unit 5. The southern perimeter road will provide two-way movements and link the east and west access points.

5.26 In order to achieve the implementation of rear loading service bats to each unit on the site, a minor reconfiguration of the hardstanding within the site is proposed. A row of 60 car parking spaces within Car Park 1 will be removed, and these will be re-provided within the existing lorry parking area in the east of the site. This lorry park area would no longer be utilised for the parking of operational vehicles. As such, there will be no loss of parking on the site and no ‘development’ of hardstanding or surfacing.

5.27 The minor amendments to the layout provide a slight increase in servicing area in comparison to the existing use and as such are considered appropriate to accommodate the likely operational vehicle demand for each unit.

Residential Amenity

5.28 The site is not immediately adjacent to any nearby residential properties, and as the proposal is for the change of use only, it is considered that the development will not have any unacceptance impact upon the amenity of residential properties.

Landscape

5.29 The site partially within an area of that is part of a Landscape of Outstanding Historic Interest and Policy SP9 ‘Conservation of the Natural, Historic and Built Environment’ outlines that proposals should be of the highest quality to reduce its impact upon this area. As the proposal seeks to change the use of the building, and will not result in any external material change to the site, it is considered that it will have no detrimental impact upon the Landscape of Outstanding Historic Interest which a small portion of the site sits within. There are no changes proposed in terms of the built form of the building and therefore there will be no material harm.

5.30 The proposal will also not have any unacceptable impact upon the adjacent Special Landscape Area due to the nature of the proposal and that external changes are proposed to the building.

Flood Risk

5.31 As mentioned previously, and as shown in the overleaf Natural Resources Wales Development Advice Map extract, part of the site lies within a flood Zone B area. NRW define Zone B as ‘areas known to have been flooded in the past evidenced by sedimentary deposits.’

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5.32 Due to the nature and type of the proposal and the units within the site, the development is classed as ‘less vulnerable development’ and therefore it is considered that the proposed development will neither be at risk of flooding nor increase the risk of flooding elsewhere.

. NRW’s Development Advice Map

Other Considerations

5.33 The following considerations have also been reviewed in relation to the proposals:

Green Wedge

5.34 The site sits adjacent, albeit not within, a Green Wedge situated to its western boundary. It is considered that the nature of the proposals comprising the change of use will not have any detrimental impact upon the Green Wedge designation. The existing use of the site is also considered acceptable in terms of its proximity to the Green Wedge and the proposal does not seek to construct any new buildings and therefore, is acceptable in principle.

Coal Risk

5.35 A review of the Coal Mining Authority’s Map confirms that the site is not contained within a coal risk designated area.

Rights of Way

5.36 There are no Rights of Way that will be affected by the proposals.

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6.0 SUMMARY AND CONCLUSIONS

6.1 The proposed development seeks to change the existing use of the Former Quinn Radiator Factory to a variety of B Class Uses on a brownfield site within a sustainable location.

6.2 It is considered that there are several material considerations in support of the application, including the following:

6.3 Having regard to the above material considerations, it is considered that the proposed development represents an appropriate and policy compliant scheme, which makes good use of this existing site to the benefit of the wider community.

6.4 Accordingly, it is considered that the proposed development comprises a high-quality employment scheme in a much-needed location and is acceptable by way of its location, design, scale, community safety and its minimal environmental impacts. We therefore respectfully request that this application be approved.

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Appendix A – Newport City Council Local Development Plan relevant policy

Policy Text Policy SP1 – PROPOSALS WILL BE REQUIRED TO MAKE A POSITIVE CONTRIBUTION TO Sustainability SUSTAINABLE DEVELOPMENT BY CONCENTRATING DEVELOPMENT IN SUSTAINABLE LOCATIONS ON BROWNFIELD LAND WITHIN THE SETTLEMENT BOUNDARY. THEY WILL BE ASSESSED AS TO THEIR POTENTIAL CONTRIBUTION TO:

i) THE EFFICIENT USE OF LAND;

ii) THE REUSE OF PREVIOUSLY DEVELOPED LAND AND EMPTY PROPERTIES IN PREFERENCE TO GREENFIELD SITES;

iii) PROVIDING INTEGRATED TRANSPORTATION SYSTEMS, AS WELL AS ENCOURAGING THE CO-LOCATION OF HOUSING AND OTHER USES, INCLUDING EMPLOYMENT, WHICH TOGETHER WILL MINIMISE THE OVERALL NEED TO TRAVEL, REDUCE CAR USAGE AND ENCOURAGE A MODAL SHIFT TO MORE SUSTAINABLE MODES OF TRANSPORT;

iv) REDUCING ENERGY CONSUMPTION, INCREASING ENERGY EFFICIENCY AND THE USE OF LOW AND ZERO CARBON ENERGY SOURCES;

v) THE MINIMISATION, RE-USE AND RECYCLING OF WASTE;

vi) MINIMISING THE RISK OF AND FROM FLOOD RISK, SEA LEVEL RISE AND THE IMPACT OF CLIMATE CHANGE;

vii) IMPROVING FACILITIES, SERVICES AND OVERALL SOCIAL AND ENVIRONMENTAL EQUALITY OF EXISTING AND FUTURE COMMUNITIES;

viii) ENCOURAGING ECONOMIC DIVERSIFICATION AND IN PARTICULAR IMPROVING THE VITALITY AND VIABILITY OF THE CITY CENTRE AND DISTRICT CENTRES;

ix) CONSERVING, ENHANCING AND LINKING GREEN INFRASTRUCTURE, PROTECTING AND ENHANCING THE BUILT AND NATURAL ENVIRONMENT;

x) CONSERVING AND ENSURING THE EFFICIENT USE OF RESOURCES SUCH AS WATER AND MINERALS. Policy SP3 – Flood NEWPORT’S COASTAL AND RIVERSIDE LOCATION NECESSITATES THAT DEVELOPMENT Risk BE DIRECTED AWAY FROM AREAS WHERE FLOOD RISK IS IDENTIFIED AS A CONSTRAINT AND ENSURE THAT THE RISK OF FLOODING IS NOT INCREASED ELSEWHERE. DEVELOPMENT WILL ONLY BE PERMITTED IN FLOOD RISK AREAS IN ACCORDANCE WITH NATIONAL GUIDANCE. WHERE APPROPRIATE A DETAILED TECHNICAL ASSESSMENT WILL BE REQUIRED TO ENSURE THAT THE DEVELOPMENT IS DESIGNED TO COPE WITH THE THREAT AND CONSEQUENCES OF FLOODING OVER ITS LIFETIME. SUSTAINABLE SOLUTIONS TO MANAGE FLOOD RISK SHOULD BE PRIORITISED. Policy SP9 – THE CONSERVATION, ENHANCEMENT AND MANAGEMENT OF RECOGNISED SITES Conservation of the WITHIN THE NATURAL, HISTORIC AND BUILT ENVIRONMENT WILL BE SOUGHT IN ALL Natural, Historic and PROPOSALS. Built Environment Policy SP13 – DEVELOPMENT WILL BE REQUIRED TO HELP DELIVER MORE SUSTAINABLE Planning Obligations COMMUNITIES BY PROVIDING, OR MAKING CONTRIBUTIONS TO, LOCAL AND REGIONAL INFRASTRUCTURE IN PROPORTION TO ITS SCALE AND THE SUSTAINABILITY OF ITS LOCATION.

THIS LIST IS NOT EXHAUSTIVE, BUT THE FOLLOWING ARE INFRASTRUCTURE PRIORITIES THAT DEVELOPMENTS WILL BE EXPECTED TO PROVIDE OR CONTRIBUTE TO IN ORDER TO MITIGATE ANY NEGATIVE CONSEQUENCES OF DEVELOPMENT:

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• EDUCATIONAL FACILITIES AND/OR THEIR UPGRADES; • AFFORDABLE HOUSING; • IMPROVEMENTS TO THE HIGHWAY NETWORK, INCLUDING WALKING AND CYCLING ROUTES AND PUBLIC TRANSPORT; • OUTDOOR RECREATION; • PROTECTION, ENHANCEMENT AND MANAGEMENT OF THE NATURAL, HISTORIC AND BUILT ENVIRONMENTS; • COMMUNITY FACILITIES AND/OR THEIR UPGRADES; AND • IMPROVEMENTS TO THE PUBLIC REALM. Policy SP17 – PROVISION WILL BE MADE FOR APPROXIMATELY 172 HECTARES OF Employment Land EMPLOYMENT LAND FOR THE PERIOD 2011 - 2026. Policy GP2 – General DEVELOPMENT WILL BE PERMITTED WHERE, AS APPLICABLE: Development Principles – General i) THERE WILL NOT BE A SIGNIFICANT ADVERSE EFFECT ON LOCAL AMENITY, Amenity INCLUDING IN TERMS OF NOISE, DISTURBANCE, PRIVACY, OVERBEARING, LIGHT, ODOURS AND AIR QUALITY;

ii) THE PROPOSED USE AND FORM OF DEVELOPMENT WILL NOT BE DETRIMENTAL TO THE VISUAL AMENITIES OF NEARBY OCCUPIERS OR THE CHARACTER OR APPEARANCE OF THE SURROUNDING AREA;

iii) THE PROPOSAL SEEKS TO DESIGN OUT THE OPPORTUNITY FOR CRIME AND ANTI- SOCIAL BEHAVIOUR;

iv) THE PROPOSAL PROMOTES INCLUSIVE DESIGN BOTH FOR THE BUILT DEVELOPMENT AND ACCESS WITHIN AND AROUND THE DEVELOPMENT;

v) ADEQUATE AMENITY FOR FUTURE OCCUPIERS. Policy GP4 – General DEVELOPMENT PROPOSALS SHOULD: Development Principles – Highways i) PROVIDE APPROPRIATE ACCESS FOR PEDESTRIANS, CYCLISTS AND PUBLIC and Accessibility TRANSPORT IN ACCORDANCE WITH NATIONAL GUIDANCE;

ii) BE ACCESSIBLE BY A CHOICE OF MEANS OF TRANSPORT;

iii) BE DESIGNED TO AVOID OR REDUCE TRANSPORT SEVERANCE, NOISE AND AIR POLLUTION;

iv) MAKE ADEQUATE PROVISION FOR CAR PARKING AND CYCLE STORAGE;

v) PROVIDE SUITABLE AND SAFE ACCESS ARRANGEMENTS;

vi) DESIGN AND BUILD NEW ROADS WITHIN PRIVATE DEVELOPMENT IN ACCORDANCE WITH THE HIGHWAY AUTHORITY’S DESIGN GUIDE AND RELEVANT NATIONAL GUIDANCE;

vii) ENSURE THAT DEVELOPMENT WOULD NOT BE DETRIMENTAL TO HIGHWAY OR PEDESTRIAN SAFETY OR RESULT IN TRAFFIC GENERATION EXCEEDING THE CAPACITY OF THE HIGHWAY NETWORK. Policy GP5 - General DEVELOPMENT WILL BE PERMITTED WHERE, AS APPLICABLE: Development Principles – Natural i) THE PROPOSALS ARE DESIGNED AND MANAGED TO PROTECT AND ENCOURAGE Environment BIODIVERSITY AND ECOLOGICAL CONNECTIVITY, INCLUDING THROUGH THE INCORPORATION OF NEW FEATURES ON OR OFF SITE TO FURTHER THE UK, WELSH AND/OR NEWPORT BIODIVERSITY ACTION PLANS;

ii) THE PROPOSALS DEMONSTRATE HOW THEY AVOID, OR MITIGATE AND COMPENSATE NEGATIVE IMPACTS TO BIODIVERSITY, ENSURING THAT THERE ARE NO SIGNIFICANT ADVERSE EFFECTS ON AREAS OF NATURE CONSERVATION INTEREST INCLUDING INTERNATIONAL, EUROPEAN, NATIONAL, WELSH SECTION 4232 AND LOCAL PROTECTED HABITATS AND SPECIES, AND PROTECTING FEATURES OF IMPORTANCE FOR ECOLOGY;

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iii) THE PROPOSAL WILL NOT RESULT IN AN UNACCEPTABLE IMPACT ON WATER QUALITY;

iv) THE PROPOSAL SHOULD NOT RESULT IN THE LOSS OR REDUCTION IN QUALITY OF HIGH QUALITY AGRICULTURAL LAND (GRADES 1, 2 AND 3A);

v) THERE WOULD BE NO UNACCEPTABLE IMPACT ON LANDSCAPE QUALITY;

vi) THE PROPOSAL INCLUDES AN APPROPRIATE LANDSCAPE SCHEME, WHICH ENHANCES THE SITE AND THE WIDER CONTEXT INCLUDING GREEN INFRASTRUCTURE AND BIODIVERSITY NETWORKS;

vii) THE PROPOSAL INCLUDES APPROPRIATE TREE PLANTING OR RETENTION WHERE APPROPRIATE AND DOES NOT RESULT IN THE UNACCEPTABLE LOSS OF OR HARM TO TREES, WOODLAND OR HEDGEROWS THAT HAVE WILDLIFE OR AMENITY VALUE. Policy GP6 – General GOOD QUALITY DESIGN WILL BE SOUGHT IN ALL FORMS OF DEVELOPMENT. THE AIM Development IS TO CREATE A SAFE, ACCESSIBLE, ATTRACTIVE AND CONVENIENT ENVIRONMENT. IN Principles – Quality of CONSIDERING DEVELOPMENT PROPOSALS THE FOLLOWING FUNDAMENTAL DESIGN Design PRINCIPLES SHOULD BE ADDRESSED:

i) CONTEXT OF THE SITE: ALL DEVELOPMENT SHOULD BE SENSITIVE TO THE UNIQUE QUALITIES OF THE SITE AND RESPOND POSITIVELY TO THE CHARACTER OF THE AREA;

ii) ACCESS, PERMEABILITY AND LAYOUT: ALL DEVELOPMENT SHOULD MAINTAIN A HIGH LEVEL OF PEDESTRIAN ACCESS, CONNECTIVITY AND LAID OUT SO AS TO MINIMISE NOISE POLLUTION;

iii) PRESERVATION AND ENHANCEMENT: WHERE POSSIBLE DEVELOPMENT SHOULD REFLECT THE CHARACTER OF THE LOCALITY BUT AVOID THE INAPPROPRIATE REPLICATION OF NEIGHBOURING ARCHITECTURAL STYLES. THE DESIGNER IS ENCOURAGED TO DISPLAY CREATIVITY AND INNOVATION IN DESIGN;

iv) SCALE AND FORM OF DEVELOPMENT: NEW DEVELOPMENT SHOULD APPROPRIATELY REFLECT THE SCALE OF ADJACENT TOWNSCAPE. CARE SHOULD BE TAKEN TO AVOID OVER-SCALED DEVELOPMENT;

v) MATERIALS AND DETAILING: HIGH QUALITY, DURABLE AND PREFERABLY RENEWABLE MATERIALS SHOULD BE USED TO COMPLEMENT THE SITE CONTEXT. DETAILING SHOULD BE INCORPORATED AS AN INTEGRAL PART OF THE DESIGN AT AN EARLY STAGE;

vi) SUSTAINABILITY: NEW DEVELOPMENT SHOULD BE INHERENTLY ROBUST, ENERGY AND WATER EFFICIENT, FLOOD RESILIENT AND ADAPTABLE, THEREBY FACILITATING THE FLEXIBLE REUSE OF THE BUILDING. WHERE EXISTING BUILDINGS ARE PRESENT, IMAGINATIVE AND SENSITIVE SOLUTIONS SHOULD BE SOUGHT TO ACHIEVE THE RE- USE OF THE BUILDINGS. Policy GP7 – DEVELOPMENT WILL NOT BE PERMITTED WHICH WOULD CAUSE OR RESULT IN Environmental UNACCEPTABLE HARM TO HEALTH BECAUSE OF LAND CONTAMINATION, DUST, Development INSTABILITY OR SUBSIDENCE, AIR, HEAT, NOISE OR LIGHT POLLUTION, FLOODING, Principles – WATER POLLUTION, OR ANY OTHER IDENTIFIED RISK TO ENVIRONMENT, LOCAL Environmental AMENITY OR PUBLIC HEALTH AND SAFETY. Protection and Public Health Policy CE1 – DEVELOPMENT PROPOSALS SHOULD PROTECT AND ENHANCE THE APPEARANCE AND Routeways, CONNECTIVITY OF EXISTING AND FUTURE MAIN ROUTE CORRIDORS AND GATEWAYS Corridors and INTO THE CITY. THE ROUTES INCLUDE: Gateways i. THE M4 MOTORWAY; ii. THE LONDON TO SOUTH WALES RAILWAY;

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iii. THE A449 (T); iv. THE A4042 (T) MALPAS BYPASS AND BRYNGLAS TUNNELS RELIEF ROAD; v. THE A455, THE SOUTHERN DISTRIBUTOR ROAD, THE A4042 DOCKS WAY AND THE USK WAY; vi. THE A48; vii. THE A48(M); viii. THE MONMOUTHSHIRE AND BRECON CANALS; ix. OTHER PRINCIPAL TRANSPORT ROUTES IN THE URBAN AREA. Policy CE3 – IN AND ADJOINING THE URBAN AND VILLAGE AREAS, AND IN AREAS IDENTIFIED FOR Environmental Spaces COMPREHENSIVE DEVELOPMENT, SITES HAVING EXISTING IMPORTANCE FOR THEIR and Corridors VISUAL QUALITIES, AS WILDLIFE HABITATS OR FOR RECREATIONAL OR AMENITY PURPOSES, WILL BE SAFEGUARDED AS “ENVIRONMENTAL SPACES AND CORRIDORS”. DEVELOPMENT IN THESE SPACES WILL BE PERMITTED ONLY WHERE:

i) THE EXISTING OR POTENTIAL ENVIRONMENTAL QUALITIES OF THE SITE WILL BE IMPROVED OR COMPLEMENTED;

ii) THERE IS NO ADVERSE IMPACT ON INTERNATIONAL, EUROPEAN, NATIONAL, REGIONAL OR LOCAL NATURE CONSERVATION INTEREST;

iii) THERE IS NOT A LOSS, WITHOUT APPROPRIATE REPLACEMENT, OF A RECREATIONAL, OPEN SPACE, OR AMENITY RESOURCE FOR THE IMMEDIATE LOCALITY UNLESS IT CAN BE DEMONSTRATED THAT THERE IS AN EXCESS OF PROVISION OR FACILITIES CAN BE ENHANCED THROUGH DEVELOPMENT OF A SMALL PART OF THE SITE.

PROPOSALS TO ENHANCE OR IMPROVE EXISTING ENVIRONMENTAL SPACE PROVISION WILL BE ENCOURAGED WHERE PRACTICABLE. ADDITIONAL PROVISION WILL BE SOUGHT IN AREAS WHERE A DEFICIT HAS BEEN IDENTIFIED. Policy T4 – Parking DEVELOPMENT WILL BE REQUIRED TO PROVIDE APPROPRIATE LEVELS OF PARKING, WITHIN DEFINED PARKING ZONES, IN ACCORDANCE WITH ADOPTED PARKING STANDARDS.