Planning Statement

THE EMBANKMENT, CARDIFF

Planning Statement

January 2021

Contents

1. Introduction 3 2. The Application Site 5

3. The Proposed Development 11 4. Planning Policy Context 16 5. Planning Assessment 23 6. Draft Heads of Terms 38 7. Summary and Conclusion 40 Appendix 1: DCfW Response to the Proposals 43 Appendix 2: Site Location Plan 44 Appendix 3: Policy KPA 2 (A) Extract 45

Huw Jones [email protected] Client Vastint UK Services Limited Our reference VAST3000

January 2021

1. Introduction

1.1 This Planning Statement has been prepared by Turley on behalf of Vastint UK Services Limited (“Vastint”) in support of an outline planning application for the comprehensive mixed-use, residential-led redevelopment of the Embankment, Cardiff (“The Site”).

1.2 The formal description of development (“Proposed Development”) is as follows:

“Demolition of existing buildings and structures and the comprehensive mixed-use redevelopment of land at Curran Embankment to provide up to 2,500 new homes (Class C3), Business space (Class B1) and a mix of complementary leisure, food and drink, hospitality, retail and health and wellbeing uses (Class A1, A2, A3, C1, D1 and D2); creation of new open space (including a new riverside park and water taxi stop); new pedestrian, cycle and vehicular access points; pedestrian footbridge ; vehicular and cycle parking facilities; landscaping public realm and other associated ancillary and highways works. All matters reserved other than vehicular access.’’

1.3 This application is made in outline, with all matters reserved with the exception of vehicular access.

1.4 The application is supported by a set of parameter plans (prepared by 3D Reid). These establish the area in which development is proposed; the general arrangement of buildings and streets; maximum building heights; proposed uses; and green infrastructure. The parameter plans are supported by a Design Code, which provides further narrative to explain the plans and how the scheme could be delivered through detailed design.

1.5 Illustrative masterplan drawings are provided within the supporting Design and Access Statement (prepared by 3D Reid and Planit IE) to illustrate the potential future comprehensive redevelopment of the application site.

Vastint UK

1.6 Vastint UK is part of the Vastint Group, an international real estate organisation with over 30 years’ of experience. Vastint’s goal is to create distinct urban environments inspired by how people enjoy working and living in the modern world by unlocking the potential of large urban sites to create truly balanced mixed-use regeneration schemes. They look to create value in an area and ensure success through long term investment and management of a site.

1.7 Vastint has made a significant and long term investment in Cardiff and has spent a number of years consolidating land ownerships within the application site in order to deliver its ambition for the city.

1.8 Vastint proposes the creation of a vibrant new community within Cardiff city centre, providing enhanced connectivity between the city centre, Butetown, Grangetown and Cardiff Bay, along the River Taff.

1.9 The scheme will be mixed-use combining homes, workspaces, a range of commercial uses and amenity spaces to create a truly balanced mix of uses that will encourage people to come and go at all times of the day, connected by a well-designed landscape accessible to all, that encourages people to visit and stay.

Environmental Impact Assessment

1.10 Turley submitted an Environmental Impact Assessment (‘EIA’) Scoping Request to Cardiff Council on 6 August 2020. Cardiff Council (‘the LPA’) subsequently provided its formal Scoping Opinion on 23 October 2020. The outline planning application is supported by an Environmental Statement (‘ES’), which is the output of the EIA process undertaken in accordance with the Town and Country Planning (Environmental Impact Assessment) (Wales) Regulations 2017 (as amended 2019). The ES covers the agreed scope of assessment as set out in the Council’s Scoping Opinion.

Structure of the Planning Statement

1.11 This Statement is structured in the following order and should be read in conjunction with the other documents and plans submitted in support of the outline planning application:

• The Application Site

• The Proposed Development

• Planning Policy Context

• Planning Assessment

• Summary and Conclusions

1.12 An extensive programme of pre-application meetings and discussions with Cardiff Council’s planning, highways and urban design officers (in addition to liaison with relevant specialist consultees) took place in the preparation and development of the application proposal. Advice from officers has been key to the delivery of the scheme in its submitted form. The application proposal was also presented to the Design Commission for Wales (DCfW) on 10 December 2020. A copy of the DCfW response is reproduced at Appendix 1.

2. The Application Site

Site Location and Surrounding Context

2.1 The Site is located on the southern edge of Cardiff city centre within an area which has historically been dominated by industrial land uses. The decline in industry over recent years has resulted in much of the uses becoming redundant. Numerous commercial buildings located within the application site and the immediate surrounding area are in a poor state of repair, with many unoccupied and derelict.

2.2 In more recent years, the surrounding area has been the subject of significant urban regeneration. Residential uses are now located to the south (Century Wharf and Overstone Court), residential and educational uses to the east, and commercial office uses to the north.

2.3 This area of the city (including the application site) has long been recognised as forming part of a key area for change and comprehensive regeneration. This includes identification in previous development plans, the City Centre Strategy and area appraisals, the Dumballs Road Area Planning Brief (2006) and the Core Area (South) Masterplan (2013).

2.4 The need for regeneration has been recognised by both Cardiff Council and Welsh Government. The area has been designated by the Welsh Government as an Enterprise Zone (referred to as the Central Cardiff Enterprise Zone). The application site is also identified as a strategic priority for urban regeneration within the adopted Cardiff Local Development Plan (2016) (the LDP). The development plan includes a ‘Schematic Framework Plan’, which identifies the application site for mixed use and residential uses.

The Site

2.5 The application site itself comprises approximately 19.1ha of existing and former industrial land, located to the east of the River Taff and the west of Dumballs Road. The site location is shown on the submitted Site Plan (Drawing No. 190139-3DR-SI-XX-DR-10005 Rev P02) (see Appendix 2).

2.6 The Site extends northwards from the Cardiff and Vale College (CAVC) Construction Training Centre and residential developments at Overstone Court and Century Wharf to Curran Embankment and Trade Street. It is bound to the north by an area currently undergoing redevelopment for commercial and residential uses. The northern boundary also extends beyond this in places to include two sections of the A4160 (Heol Penarth).

2.7 The below figure illustrates the ‘development area’ in the context of the wider city.

Figure 1: Development site in context

2.8 The eastern boundary is formed by Dumballs Road, with the recently built CAVC Campus and existing commercial and industrial land beyond this. This includes an area of land which is subject to a current planning application for mixed use redevelopment, referred to as ‘Anchorworks’ (LPA Ref. 20/01543/MJR).

2.9 To the south of the Site is the CAVC Cardiff Construction Training Centre and Overstone Court, beyond which lies the Century Wharf residential development. The western boundary is largely formed by the River Taff. The Site boundary also extends to the western bank of the River Taff, including part of the Taff Embankment Park and Blaenclydach Street.

2.10 The majority of the application site comprises underutilised previously developed (brownfield) land. The application site is characterised by buildings of low quality and fragmented design. The current activities taking place on the Site include heavy and light industrial units (Use Classes B1 and B2), workshops (Use Classes B1 and B2), garages (Use Class B2), a place of worship, commercial leisure uses and surface level car parking. Many of the remaining buildings within the Site are vacant, derelict and in a very poor condition.

Figure 2: Poor quality existing structures

2.11 The topography of the Site is generally flat, falling gently in a north-westerly direction. Ground levels range from between approximately 8.2m AOD to 8.9m AOD.

Figure 3: Underutilised land within the application site

2.12 No statutory designations (Listed Buildings, Registered Parks and Gardens, Conservation Areas) are located within the Site.

2.13 The River Taff Site of Interest for Nature Conservation (SINC) (which lies partly within the Site) is designated as a major wildlife corridor and provides habitat for migratory fish, otters, wildfowl and bankside vegetation. The Site is also located within 2km of the Cardiff Bay Wetlands & Hamadryad Park Local Nature Reserve (LNR) (635m south); Cwm Cydfin, Leckwith Site of Special Scientific Interest (SSSI) (1.9km southwest); and Severn Estuary SSSI, Ramsar, Special Protection Area (SPA) and Special Area for Conservation (SAC) (2km southeast). Other habitats within the Site include tall ruderal vegetation, grass verges, semi- natural woodland, shrubs and scattered trees.

Figure 4: Extensive riverside frontage with no public access

2.14 The Natural Resource Wales (NRW) Development Advice Map (DAM) indicates that the majority of the Site is located within Flood Zone B (areas known to have flooded in the past). A small proportion of the Site, located towards the north-west and eastern fringes of the Site, lies within Flood Zone C1 (areas at risk of flooding).

2.15 The majority of the Site is located within the Butetown Ward, with the exception of a small area of land to the west of the River Taff which falls within the Grangetown Ward.

Site Accessibility

2.16 The Site is located in a highly sustainable location on the southern edge of the city centre. The city centre offers a diverse range of facilities and services and is a major centre of employment and retail.

2.17 The Site benefits from excellent transport connectivity in terms of public transport and all active travel modes, such as walking and cycling. There are several bus stops in close proximity to the Site, the nearest being on Dumballs Road. Additional services are available within the vicinity of the Site on Bute Street (approximately 500m), Corporation Road (approximately 450m) and Lloyd George Avenue (approximately 850m).

2.18 The new Cardiff Central Bus Station is currently being constructed approximately 900m from the centre of the Site. The new Central Bus Station will be a significant interchange providing a comprehensive range of bus services connecting with all areas of Cardiff as well as long- distance destinations.

2.19 The Site is also well positioned to existing rail connections, with Cardiff Central Station, Cardiff Bay Station and Grangetown Station all situated within 1km. Cardiff Central Station is the largest of the three stations and is located within the closest proximity to the Site, approximately 500m to the north. Cardiff Central Station provides local, regional, and long- distance rail services.

2.20 Cardiff Bay Station can be accessed from both Bute Street and Lloyd George Avenue and forms a key, frequent route of connectivity between Cardiff Bay and the City Centre (Cardiff Queens Street station) which site users can utilise. This line also forms part of the Cardiff Metro proposals.

2.21 The Site is currently accessed via four different locations on foot (with very limited public access), namely:

• Curran Embankment from the north and west;

• Curran Road and Trade Street from the north;

• Tresillian Terrace/Dumballs Road from the north and east; and

• Dumballs Road from the south.

2.22 A local network of formal and informal footpaths provides connectivity with the city centre, Cardiff Bay, Grangetown and Riverside. The site is currently a barrier to movement throughout this area of the city centre.

2.23 The Site is well positioned in terms of access to the local surrounding cycle network. A cycle route runs along Clarence Road and James Street to the Wales Millennium Centre in Cardiff Bay. Segregated cycle facilities are provided around Callaghan Square (to the north of the Site), which provides a key east-west connection between cycle lanes along Bute Street and Lloyd George Avenue to east and via cycle lanes over the Penarth Road Bridge linking onto the Taff Trail to the west.

2.24 The Taff Trail is a largely traffic-free shared pedestrian/cycle facility that runs from the Bay waterfront along the River Taff corridor to Brecon. This forms part of the National Cycle Network Route 8 and connects to the Bay Trail. Generally, the Taff Trail is well paved and maintained and is wide enough to facilitate a shared environment for pedestrians and cyclists. The Taff Trail forms a key part of Cardiff’s cycle network and provides a high-quality connection to many areas within the city.

2.25 The primary vehicular access to the Site is from Dumballs Road, although the existing access points either lead to an un-adopted industrial access road or are in the form of private vehicle crossovers. The Site can also be accessed from Curran Road (a partially adopted single carriageway road), Trade Street (an adopted single carriageway) and Curran Embankment (an un-adopted single carriageway).

Planning History

2.26 The site has an extensive and complex planning history. The most relevant planning applications relate to previous proposals for mixed-use residential-led redevelopment:

• Outline planning permission was granted in May 2011 for mixed use regeneration, including erection of up to 2,070 dwellings, 45,000 sq m of Class B1(a) offices, 16,000 sq m of Class C1 hotel, as well as a training centre, assembly and retail uses, open space landscaping, road, foot and cycle access (LPA Ref. 07/1637/C).

• A hybrid planning application was approved in August 2014 (Ref. 14/00430/DCI). This comprised full planning permission for the erection of up to 695 dwellings and 357 sq m of Class A1/A2/A3/D1 floorspace, associated car parking and secure cycle storage, access, servicing and landscaping. Outline planning permission was also granted for a further 1,460 dwellings as well as Class A1 retail, Class A2 financial and professional services, Class A3 food and drink, Class B1 office, Class C1 Hotel, Class

C3 residential, Class D1 non-residential institution, Class D2 assembly and leisure uses, access, parking, servicing and landscaping.

2.27 The principle of comprehensive mixed-use redevelopment at the Site is firmly established through its allocation within the adopted local plan and the planning permissions previously granted by the LPA.

3. The Proposed Development

3.1 As identified within Section 1 of this report, this outline planning application proposes the following development:

Documents for Approval

3.2 This application is made in outline, with all matters reserved for future consideration with the exception of vehicular access. The plans submitted for approval are the Location Plan (which defines the geographical extent of the proposed development); the parameter plans; and, the proposed access plans, which define in detail the proposed access and highways proposals for the development.

3.3 The documents and plans for approval are:

• Existing Site Plan (Drawing No. 190139-3DR-SI-XX-DR-10005 Rev P02)

• Existing Location Plan (190139-3DR-SI-XX-DR-10010 Rev P02)

• Parameter Plan 1: Demolition (Drawing No. 190139-3DR-SI-XX-DR-PP001 Rev P02)

• Parameter Plan 2: Build Zone (Drawing No. 190139-3DR-SI-XX-DR-PP002 Rev P02)

• Parameter Plan 3: Street (Drawing No. 190139-3DR-SI-XX-DR-PP003 Rev P02)

• Parameter Plan 4: Maximum Permitted Heights (Drawing No. 190139-3DR-SI-XX-DR- PP004 Rev P02)

• Parameter Plan 5: Uses – Ground and First Floors (Drawing No. 190139-3DR-SI-XX- DR-PP005 Rev P02)

• Parameter Plan 6: Uses – Upper Floors (Drawing No. 190139-3DR-SI-XX-DR-PP006 Rev P02)

• Parameter Plan 7: Green Infrastructure (Drawing No. 190139-3DR-SI-XX-DR-PP007 Rev P02)

• Site Access 1 General Arrangement Plan (Drawing No. 42655/5501/SK015)

• Site Access 2 General Arrangement Plan (Drawing No. 42655/5501/SK018)

• Site Access 3 General Arrangement Plan (Drawing No. 42655/5501/SK021)

• Site Access 4 General Arrangement Plan (Drawing No. 42655/5501/SK024)

3.4 The parameter plans are supported by a Design Code, which provides further narrative and details the options available for the future delivery of the scheme through detailed design.

Other Plans and Documents

3.5 Other plans, including the illustrative masterplan and those included within the Design and Access Statement (‘DAS’) are illustrative and show how the development could be delivered.

Land Uses

3.6 The application proposes a range of Use Classes that will make up the development of the Site. The range of uses and approximate floorspace/unit numbers are set out below. It should be noted that this represents a maximum quantum of floorspace that could be delivered as part of the redevelopment.

Use Proposed Maximum Floorspace Class C3 (mix of dwelling types and 2,500 units tenures, including townhouses and flats)

Class A1, A2, A3, D1 and D2 (mixed 11,500 sq m (GIA) commercial uses) Class B1 (Office) 54,000 sq m (GIA) Class C1 (Hotel) 4,800 sq m (GIA)

3.7 Further details regarding the uses proposed are included within the accompanying Design Code and Design and Access Statement, prepared by 3D Reid and Planit IE.

Scale and Massing

3.8 Building heights will range from between 22.4m AOD and 97.4m AOD (as illustrated on the Parameter Plans). The illustrative masterplan demonstrates how the development can be delivered. It shows a range of heights from between 3 and approximately 25 storeys across the Site. It is envisaged that the majority of residential buildings will be between four and six storeys.

3.9 Taller buildings are proposed throughout the proposed development to achieve specific urban objectives (up to a maximum of 97.4m AOD). Several tall buildings are proposed in the south-east corner of the Site to terminate views along Dumballs Road and form a cluster of tall buildings (together with the proposed Anchorworks development) to the east.

3.10 Other tall buildings will mark views north and south along Trade Street and along the western edge of the Site to celebrate views along the arc of the River Taff and respond to long-range strategic vistas on approaches to the city from the South and West.

Access and Parking

3.11 Permeable pedestrian links through the Site are to be provided in the form of north-south ‘amenity streets’ and east-west ‘green streets’. The amenity streets will be vehicle-free (with the exception of emergency access), but will facilitate cycling within a shared space. The amenity streets will provide a north/south link through the Site. The green street are the main circulation routes incorporating SuDs on either side to efficiently manage rainwater run-off

3.12 A footbridge/cycle bridge over the River Taff is proposed. The new bridge will provide enhanced connectivity to the local amenities and residential areas located to the west of the Site in Grangetown. It will also reduce the walk time to the existing bus services on Corporation Road and Clare Road and provide a direct connection onto the Taff Trail.

3.13 Parking needs will be met within two ‘park house’ structures (multi-storey car parks) to the north and south of the Site. The park houses will provide the total parking requirement of the residential and employment uses proposed. A total of 924 parking spaces will be provided, with 513 spaces in the northern park house and 411 in the southern park house. Disabled parking and some limited short-term car parking will be provided on street.

3.14 The northern park house will provide cycle parking for the office use (Business Garden) at ground level. Permanent cycle parking spaces for residents will be provided on the ground floor in secure storage areas within the buildings themselves. Visitor cycle parking will be provided for the commercial and residential properties on-street, in convenient locations throughout the development.

3.15 Four main vehicular access points from Dumballs Road are proposed. The layout of the Site has been designed to direct a significant proportion of the traffic (90%) to Site Access Junctions 1 and 3 (as shown on Figure 6.1, page 31 of the supporting Transport Assessment, prepared by Stantec, extract below), which will lead to the park houses.

Figure 5: Location of main vehicular access points

3.16 Site Access Junctions 2 and 4 will only provide access for limited on-street parking demand together with servicing and deliveries. There will also be the potential for delivery/servicing only access from Curran Embankment (via Penarth Road). Consequently, these two junctions will experience significantly lower traffic volumes.

3.17 The existing junction between Curran Embankment and Penarth Road will remain, but will only service the existing properties along Penarth Road and the most north-western development plot. There will not be a direct connection between this junction and Dumballs Road (except for a potential future public transport route, as discussed below).

3.18 The scheme has been designed to accommodate a public transport corridor from the northwest access onto the A4160 (Curran Road junction) through the Site to Dumballs Road. The outcome of any new bus service or route through the Site will be subject to further discussions (given the entire Site is already within a 400m walking distance of the nearest bus stops) and is likely to require the inclusion of a ‘bus gate’ to stop other vehicle taking short cuts through the site.

3.19 A water pontoon is also proposed, which will provide a new stop for the Water Bus service midway between Cardiff Bay and the City.

Open Space and Green Infrastructure

3.20 The application proposal will bring about significant enhancements to the landscape character of the application site, providing up to 2.4ha of new public spaces and gardens. The proposals aim to extend Cardiff’s network of natural and semi-natural landscapes along the River Taff, linking adjoining communities to freshwater habitats across the Bay.

3.21 The new public open spaces are illustrated on the masterplan and include:

• the ‘River Park’ – proposed along the length of the Site adjacent to the River Taff. The park will enhance ecological value and create a new biodiverse green space for the wider community. A series of different scale and character spaces within the park will offer opportunities for relaxation, sports, recreation and interaction for the various users.

• the ‘Urban Square’ – this forms the central public space in a central location across the main public transport corridor.

• the ‘Business Garden’ – proposed within the Business Garden character area, a natural environment to escape the workplace during lunch breaks and to enjoy during the day or after work.

3.22 The masterplan also includes a series of well-connected green and amenity streets. All east to west streets incorporate SUDS and tree planting, whilst all north to south amenity streets have generous planting provision. SAB approval will be secured at the detailed design (Reserved Matters) stage. Preliminary pre-application discussions have taken place with Cardiff Council’s SAB officers and have informed the design development.

3.23 All areas of public realm and amenity landscape that surround the built form have been designed to be sympathetic to the setting and ecology of the Site.

3.24 Further details regarding the design considerations of the application proposal are included within the accompanying Design and Access Statement prepared by 3D Reid and Planit IE.

4. Planning Policy Context

The Development Plan

4.1 The development plan for the Site comprises the Cardiff Local Development Plan (LDP), which was adopted in January 2016. This is the primary consideration in the determination of the planning application.

4.2 The Council is currently at an early stage of preparing a Replacement LDP. A draft Review Report and draft Delivery Agreement are currently subject to a four week consultation period (until 4 February 2021). The draft Delivery Agreement indicates adoption of the Replacement LDP in October 2024.

4.3 Whilst the review process is at a very early stage, it is envisaged that key strategic policy direction will remain unchanged, certainly in respect of the application site and the surrounding area.

4.4 The following LDP policies are relevant to the determination of this application.

Policy KP2 (A) Cardiff Central Enterprise Zone and Regional Transport Hub 4.5 The Site forms part of the Cardiff Central Enterprise Zone and Regional Transport Hub strategic allocation, as identified by Policy KP2 (A) of the LDP. Land allocated within this area is identified for major employment-led regeneration together with other mixed uses, including residential. An extract of Policy KP2 (A) is provided at Appendix 3.

4.6 Policy KP2 (A) sets out a number of ‘key masterplanning requirements’ that development in this area should accord with. This includes maximising densities to make efficient use of land. It notes that high rise, high density developments at appropriate locations within the area are encouraged. It states that residential densities in excess of 100 dwellings per hectare are not considered unreasonable in principle.

4.7 The policy advocates a range of uses at the Site, including mixed-use commercial, leisure, business and residential uses. This includes a range of employment provision, including Grade A office accommodation, start-up businesses, creative workshops and incubator units. The policy also requires the creation of ‘destination spaces’ which complement business.

4.8 The policy requires, inter alia, the redevelopment proposals improve routes and connections; maximise linkages to the Taff Trail and Canal Park; maximise the asset of the River Taff frontage; develop opportunities for natural greenspaces to create urban parkland settings; integrate new development sensitively with new and existing developments and take opportunities for commercial activity along Dumballs Road; and seek to develop opportunities for SUDS to relate to/ extend the “Greener Grangetown” scheme.

4.9 Policy KP2 (A) indicatively shows the infrastructure and masterplanning requirements on a ‘Schematic Framework’. The Schematic Framework identifies the Site for predominantly residential use and partially for mixed-uses.

Figure 6: Policy KP2 (A) Schematic Framework

Source: Cardiff LDP 2016

Policy KP10: Central and Bay Business Areas 4.10 The Site lies within the ‘Central and Bay Business Area’ as identified by Policy KP10 of the LDP. The policy confirms that new offices, residential and commercial leisure uses are all considered appropriate within the designated area. The policy notes that others uses most appropriately located in city centres are also considered acceptable.

Other LDP Policies of Relevance 4.11 Beyond the above site/area specific policies, the following policies within the LDP are of direct relevance to the Proposed Development:

• Policy KP1: Level of Growth

• Policy KP4: Masterplanning Approach

• Policy KP5: Good Quality and Sustainable Design

• Policy KP6: New Infrastructure

• Policy KP7: Planning Obligations

• Policy KP8: Sustainable Transport

• Policy KP9: Responding to Evidenced Economic Needs

• Policy KP13: Responding to Evidenced Social Needs

• Policy KP14: Healthy Living

• Policy KP15: Climate Change

• Policy KP16: Green Infrastructure

• Policy H3: Affordable Housing

• Policy EC2: Provision of Complementary Facilities for Employees in Business, industrial and Warehousing Developments

• Policy EC3: Alternative Use of Employment Land and Premises

• Policy EC5: Hotel Development

• Policy EN4: River Corridors

• Policy EN12: Renewable and Low Carbon Technologies

• Policy EN13: Air, Noise, Light Pollution and Land Contamination

• Policy EN14: Flood Risk

• Policy T1: Walking and Cycling

• Policy T5: Managing Transport Impacts

• Policy C3: Community Safety/Creating Safe Environments

• Policy C5: Provision for Open Space, Outdoor Recreation, Children’s Play Space and Sport

• Policy C6: Health

• Policy W2: Provision for Waste Management Facilities in Development.

4.12 The above policies have been considered and assessed, and have informed the preparation of this application proposal.

Planning Policy Wales 10 (PPW)

4.13 PPW (Edition 10) (December 2018) sets out the overarching land use planning policies for Wales.

4.14 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 set out by the Planning (Wales) Act 2015 and the Well-being of Future Generations (Wales) Act 2015.

4.15 PPW places an emphasis on Placemaking as a guiding principle for maximising well-being and creating sustainable places. PPW sets out the themes that collectively contribute to Placemaking, as follows:

• Strategic and Spatial Choices

• Active and Social Places

• Productive and Enterprising Places

• Distinctive and Natural Places

4.16 Chapter 3 of PPW focuses on ‘Strategic and Spatial Choices’. Paragraph 3.3 states that to achieve sustainable development, design must go beyond aesthetics and include the social, economic, environmental and cultural aspects of the development. This includes how space is used, how buildings and the public realm support this use, as well as its construction, operation, management and its relationship with the surrounding area. Paragraph 3.37 notes that an essential component for a sustainable place is where development is to be located. Paragraph 3.51 confirms that previously developed land should, wherever possible, be used in preference to greenfield sites where it is suitable for development.

4.17 Chapter 4 of PPW relates to ‘Active and Social Places’ and covers the well-connected cohesive communities components of Placemaking. Paragraph 4.1.33 states that development proposals should prioritise the provision for access and movement by walking and cycling and, in doing so, maximise their contribution to the objectives of the Active Travel Act. Paragraph 4.1.51 advises a design-led approach to the provision of car parking should be taken, which ensures an appropriate level of car parking is integrated in a way which does not dominate the development. Paragraph 4.2.1 states that new housing development should incorporate a mix of market and affordable house types, tenures and size to cater for the range of identified housing needs and contribute to the development of sustainable and cohesive communities.

4.18 Chapter 5 of PPW focuses on ‘Productive and Enterprising Places’. Emphasis is placed on providing well-connected employment and sustainable economic development. Paragraph 5.4.4 states that development which generates economic prosperity and regeneration should be supported. Paragraph 5.8.3 seeks to ensure that sustainable building design principles are integral to the design of new development.

4.19 Chapter 6 of PPW focuses on ‘Distinctive and Natural Placemaking’, covering the environmental and cultural components of Placemaking. Paragraph 6.0.2 states that the special and unique characteristics and intrinsic qualities of the natural and built environment must be protected in their own right, for historic, scenic, aesthetic and nature conservation reasons. Paragraph 6.0.3 continues by stating that other environmental components of places, such as clean air, access to open spaces and water quality, are linked to the quality of the built and natural environment.

4.20 The environmental components of places influence and shape health and wellbeing as well as playing a role in sustaining and creating places which are adaptable and resilient to change. Chapter 6 of PPW emphasises the benefits of green infrastructure. Paragraphs 6.2.3

to 6.2.4 state that green infrastructure offers multiple benefits, for social, economic and cultural as well as environmental resilience, and plays a fundamental role in shaping places and our sense of well-being.

Other Material Considerations

4.21 In addition to PPW, the following documents are material considerations in the determination of the planning application:

• Government guidance contained within the following documents:

‒ Technical Advice Notes (TAN’s) published by Welsh Government

‒ Wales Spatial Plan (updated July 2008)

• Supplementary Planning Guidance and Technical Guidance Notes published by Cardiff Council:

‒ Dumballs Road Area Planning Brief (2006)

‒ Tall Buildings Design Guide (2009)

‒ Residential Design Guide (2017)

‒ Managing Transportation Impacts (Incorporating Parking Standards) (July 2018)

‒ Planning Obligations (2017)

‒ Green Infrastructure (2017)

‒ Food, Drink and Leisure Uses (2017)

‒ Planning for Health and Wellbeing (2017)

‒ River Corridors Technical Guidance Note (2017)

‒ Protection and Provision of Open Space in New Development Technical Guidance Note (2017)

‒ Waste Collection and Storage Facilities (2016)

The Wellbeing of Future Generations (Wales) Act (2015)

4.22 The Act defines sustainable development in Wales. It addresses the needs of a more diverse population and larger aging demographic by providing requirements related to the integration of services, embedding social cohesion, and encouraging a sense of belonging.

Figure 7: Well-being goals

4.23 The Sustainable Development Principle means that decision making must be undertaken so as to ensure that development will contribute to improving the economic, social, environmental and cultural well-being of Wales. The proposals will achieve this, as described within in this statement

Policy Overview

4.24 In assessing the Proposed Development against the objectives and general principles of national and local planning policy, we conclude that:

• Strategic Placemaking seeks to prioritise previously developed (or brownfield) sites over greenfield sites, where possible. The application site meets PPW’s definition of previously developed (or brownfield) land. As a brownfield site within the settlement boundary, PPW expresses a presumption in favour of its redevelopment. This is supported by Policy KP2 (A) of the LDP. The proposal will regenerate an underutilised brownfield site, with numerous sustainability and economic spin-off benefits.

• National and local planning policy recognise that good design is fundamental to creating sustainable places where people want to live, work and socialise. Whilst in outline only at this stage, the proposals demonstrate how a high quality development could be achieved in accordance with the PPW objectives for Placemaking in Action and Policies KP4 and KP5 of the LDP.

• Planning policy at all levels advocates development that creates well-connected communities. The Proposed Development will deliver a comprehensive development that promotes economic growth, meets housing needs and creates business opportunities.

• The Proposed Development is consistent with PPW’s objectives for active places and Policies KP8, KP14, C6, T1 and T5 of the LDP by encouraging the use of sustainable transport options, accessibility for all, and active travel at all opportunities.

• The use and variety of public open space has been well-thought out to ensure the importance of nature and that its influence on health and well-being is reflected in the Proposed Development. This is in accordance with PPW and LDP Policies KP14, KP16 and C5 and the Council’s Open Space Technical Guidance Note (2017).

• The Proposed Development is consistent with PPWs objectives and LDP Policies KP9 and EN12 for creating productive and enterprising places through well connected employment and sustainable economic development. The Proposed Development provides the opportunity for a range and choice of high quality commercial development and will adopt the nationally recognised energy hierarchy of reducing demand.

• Planning policy at all levels seeks to protect and enhance distinctive and natural environments. The application demonstrates that the built heritage and the natural environment have been considered from the outset. The River Taff has been a guiding principle for the masterplan, with the aim of embracing and enhancing the natural wildlife and landscape of the river through the proposals.

• The development will help to deliver the housing target of 45,415 homes set out in Policy KP1 of the LDP.

5. Planning Assessment

5.1 This section assesses the Proposed Development against prevailing development plan policies, taking into account material considerations.

Principle of Development

5.2 The application site is located within the defined settlement boundary and consists of brownfield, previously developed land. The site’s redevelopment is supported by planning policy at all levels. As a brownfield site within the settlement boundary, PPW expresses a presumption in favour of its redevelopment, especially sites that would promote sustainability objectives.

5.3 The application site also forms part of a wider area allocated under LDP Policy KPA2 (A) for major employment-led mixed-use redevelopment. The application proposal, and proposed mix of uses, is entirely consistent with the aims and objectives of this policy.

5.4 The Site is within a highly sustainable location, which is identified as a focus for urban regeneration and to accommodate future growth. This is demonstrated by its inclusion as part of the Cardiff Central Enterprise Zone.

5.5 The development will strengthen Cardiff’s role as a regional focus and will deliver major mixed-use development and the more efficient use of land, in keeping with the aims and objectives of the adopted LDP.

5.6 The Proposed Development will deliver significant residential development, including a range and choice of market and affordable housing. The scheme will also deliver significant levels of commercial floorspace, together with ancillary commercial uses. In addition, the proposals will secure new transport, pedestrian and green infrastructure that will facilitate a sustainable urban community.

5.7 The proposed comprehensive redevelopment of the site will deliver a mix of office, commercial and leisure uses, which when combined with the proposed residential units, creates a diversity of activities that will sustain and enhance the City’s day-time and night- time economies.

5.8 As set out above, the principle of bringing forward a comprehensive mixed-use residential- led redevelopment proposal at the application site is a longstanding policy aspiration. The principle of development is therefore entirely consistent with the national and local planning policy.

5.9 The site’s comprehensive redevelopment will require the displacement of the existing uses (as proposed by the site’s allocation within the adopted LDP). This will present an opportunity for existing employment uses to be relocated to a more appropriate location within the city, beyond the immediate city centre. The scheme will be delivered in a phased manner, with development likely to commence in 2021/22. Vastint anticipates that it will take circa 10 years (subject to market demand) to complete the comprehensive

regeneration of the Site. This will allow the phased relocation of existing uses to appropriate employment locations.

5.10 Vastint is committed to working with existing tenants and land owners. For example, it is currently working with Biffa to secure a relocation site at Lamby Way. There are a number of unregistered land parcels within the boundary of the scheme that need to be acquired and this is only possible through the use of Compulsory Purchase Powers. Cardiff Councill has recently signed an Indemnity Agreement with Vastint to complete the assembly of the final land parcels that will enable the development to proceed and to meet the expected timetable.

Placemaking in Action

5.11 The design approach is of high quality and responds positively to the locality. This approach has been informed by working collaboratively with the LPA and other stakeholders. The proposal will transform this area of the City, creating a new and vibrant community. It will significantly enhance the amenity of the area. The application proposal complies with Policies KP2 (A) and KP5 of the LDP and the underlying principles of the Government’s placemaking approach, as set out in PPW.

5.12 The Design and Access Statement (prepared by 3D Reid and Planit IE) submitted in support of this application sets out the design rationale in full. A summary of the design considerations is provided below.

5.13 The Proposed Development (as illustrated within the Design Code, DAS and supporting illustrative masterplan) is arranged into a series of distinct character areas. These areas are defined by a particular landscape quality, building use, or particular urban characteristics. The areas are:

• River Park;

• Business Garden;

• Central;

• South.

5.14 The Proposed Development makes efficient use of city centre land by maximising densities where appropriate across the Site in order to support a new and active community. To create a diverse townscape, a variation in density across the masterplan is proposed.

5.15 The massing and location of tall buildings will be addressed on a plot by plot basis at the detailed design stage, based on the immediate urban context and use of the building. Notwithstanding this, a series of general principles are set out in the submitted design material.

5.16 A base massing of four to eight storeys is promoted throughout the Site. This scale provides sufficient containment of the street and is considered a comfortable datum for this city centre location. Variation should be provided within each plot to create a diverse townscape.

5.17 Tall buildings are part of sustainable placemaking strategy in order to bring density to the city centre. They also promote efficient land use by focusing development onto smaller footprints to maximise the extent of amenity offered. Tall buildings are located at strategic points within the masterplan in response to views from the wider city, the urban situation, or to assist with navigation through the city.

5.18 Further detail regarding the design evolution and the approach proposed is set out in detail within the accompanying DAS and Design Code.

Development Management, Masterplanning and Timescales

5.19 The application proposal consists of a number of discrete elements that will be delivered in a phased manner. At the time of submission, it is envisaged that the comprehensive redevelopment of the Site will come forward in four phases. An indicative phasing plan is provided at Section 10 of the DAS. The exact phasing of development will, however, be determined by the market. Specific details will be provided through the submission of applications for reserved matters once outline approval has been granted.

5.20 Subject to the approval of this outline planning application, and subsequent Reserved Matters applications, Vastint is currently targeting that development will commence in 2021/22.

Public Open Space and Green Infrastructure

5.21 Planit IE and Stantec have produced a Green Infrastructure (GI) Statement, which forms part of the Environmental Statement. The Statement demonstrates how GI has been taken into consideration and integrated into the development. It also illustrates how all elements of the proposed and existing GI, any associated uses and movement network have a clear role and purpose in the new development and comply with key Green Infrastructure strategic policies.

5.22 The overall masterplan has been informed by a cohesive, long-term landscape strategy. The key aim for the public realm and landscaping is to create a series of well-connected parks, streets, civic and amenity spaces that celebrate a climate adaptive approach and integrate nature in people’s daily lives.

5.23 Vastint is committed to providing meaningful and generous amenity spaces to ensure the long-term success of the Site. A number of public spaces are provided within the masterplan in key locations. These spaces are connected through green streets ensuring a successful and vibrant new neighbourhood in Cardiff. The intention is for the proposed river park, urban square, business garden and amenity streets to become integral to the urban fabric of Cardiff. The indicative phasing plan (Section 10 of the DAS) illustrates Vastint’s aspiration to invest in the early implementation of the proposed River Park. This will assist in establishing a sense of place and development quality at the outset of the project.

5.24 All residential perimeter blocks are designed to provide secure communal garden spaces and safe streets with a range of local amenities, such as play areas, seating and places to meet with a mix of both hard and soft landscaping appropriate to each. These spaces will offer

plentiful trees and planting, creating a soft environment and a pleasant outlook from the proposed dwellings, ensuring there is always a visual or physical connection to nature.

5.25 A key aim of the Proposed Development is to re-connect surrounding communities to the river and add a walkable new neighbourhood to Cardiff city centre. Protecting, conserving and enhancing the River Taff and its function as an ecological corridor has therefore been a guiding principle in the development proposals. The proposed river park is a key feature of the scheme to support and enhance the ecology of the River, improving the environment for flora, fauna and people.

5.26 The masterplan has been designed to retain and enhance as many of the existing landscape features as possible especially around the River Taff. The proposals aim to extend Cardiff’s network of natural and semi-natural landscapes along the River Taff, linking adjoining communities to freshwater habitats across the Bay.

5.27 The Proposed Development incorporates Green Corridors with SUDs features to ensure the extension of the existing the ‘Greener Grangetown’ initiative. All east to west streets incorporate SUDS and tree planting and all north to south amenity streets have generous planting provision. This will also help to strengthen wildlife corridors within and around the Site.

5.28 The GI Statement demonstrates the development complies with key Green Infrastructure strategic policies.

Sustainable Transport

5.29 A Transport Assessment (‘TA’), prepared by Stantec, has been submitted in support of the application proposal. The TA demonstrates that the proposed development accords with local and national planning policy in respect of providing safe access and general transportation matters.

5.30 The TA confirms that the Site benefits from excellent transport connectivity to accommodate public transport users, as well as active travel modes such as walking and cycling. The Proposed Development provides a legible, well-connected network of streets that prioritise pedestrian and cycling movement and create a sustainable and pleasant setting.

5.31 The Proposed Development will implement a network of high-quality pedestrian and cycle links throughout the development, creating a permeable environment through the Site, which will link to the existing walking and cycle network in the surrounding area.

5.32 The TA confirms that the proposal has been designed to encourage the uptake of sustainable travel modes by those using the Site where possible, reducing the number of private vehicles and minimising the impact on the surrounding highway network. To reduce the impact of the car on the streetscape, and encourage walking and cycling, parking for the residential and employment uses will be provided within two ‘park house’ structures (multi-storey car parks) to the north and south of the Site.

5.33 Four new site access points are proposed to provide vehicular and pedestrian access to the site. The TA confirms that the four proposed access points from Dumballs Road have been modelled using industry standard software. Each access point has been identified as working within capacity with the traffic generated by the Proposed Development. Junctions on the wider network (north and south on Dumballs Road) operate over capacity with the development traffic during the peak hours. In order to mitigate these off-site impacts, Stantec has proposed potential off-site mitigation to enhance the performance of the junctions in question. This includes road widening to provide additional queuing capacity at the Tresillian Way/Tresillian Terrace/Penarth Road Junction; and signalising the Dumballs Road/James Street/Hunter Street /Clarence Road junction. This has an added benefit of creating dedicated pedestrian crossing facilities. The mitigation measures proposed are subject to ongoing discussion with Cardiff Council’s highways officers.

5.34 The development proposes the provision of up to 924 car parking spaces (including 22 disabled spaces) in two dedicated multi-story car parks (park houses). Parking spaces will be proportionally distributed between residential (708) and office (216) uses. Incidental short- stay car parking provision to serve visitors and the proposed commercial uses (17 spaces) will be provided on street. The TA considers the proposal to be in accordance with local parking thresholds as it represents a significantly lower level of car parking provision than could be provided on the basis of the maximum parking standards. Motorcycle parking provision will also be provided. The application proposal also makes allowance for the provision of four car club spaces (two in each of the proposed park houses).

5.35 Significant long and short stay cycle parking is proposed (5,186 spaces). Cycle parking provision is distributed across the Site, including within the northern park house (to serve the Business Garden) and within the residential blocks. The level of cycle provision proposed has been informed by the site’s highly sustainable location, within comfortable walking distance of a wide range of services and amenities.

5.36 The TA is supported by an Umbrella Travel Plan and a Residential Travel Plan. The Travel Plan documents set out the processes and monitoring measures proposed to support the transport principals proposed.

Environmental Statement

5.37 In line with Cardiff Council’s Scoping Opinion, the application is supported by an Environmental Statement.

5.38 It is acknowledged that there are elements of the application proposal for which full details are not available at this outline application stage. The ES has therefore provided a realistic worst-case assessment based on the information that is available at this stage, and is based on stated assumptions and professional judgement, including, where applicable, topic- based definitions of the worst-case assumption.

5.39 The ES concludes that the Proposed Development, when taken as a whole, is predicted to result in a limited number of significant effects. These effects include both adverse and beneficial effects. These are listed at Chapter 18 of the ES. Proposed mitigation measures are provided where appropriate, and the residual significance once the proposed mitigation

has been applied is confirmed. A number of the significant effects predicted would be during the construction phase and as such are temporary. For an urban regeneration development of this scale and nature such effects are not unusual.

5.40 It is expected that some identified significant adverse residual effects will reduce as more information about the design detail of the project becomes clear. However, further detailed design information is not available at this outline stage and is not expected to be available until subsequent Reserved Matter(s) applications are progressed. Whilst the potential for further mitigation is explored in the relevant chapters where applicable, the assessment has nevertheless been undertaken on a worst-case assessment based on the information that is available at this outline stage. The ES is based upon a set of maximum parameters that could not be built out in full. The maximum quantum of development proposed could not enable this to happen. Detailed mitigation is to be provided through detailed design (at the Reserved Matters stage), to assist in addressing significant effects that have been identified and will be subject to further assessment as appropriate.

Economic Benefits

5.41 The economic benefits of the Proposed Development are significant and should be afforded due (substantial) weight in the determination of this outline planning application.

5.42 Due to the scale and nature of the comprehensive redevelopment of the Embankment, the supporting ES includes a ‘Socio-Economic and Human Health’ chapter (prepared by Turley Economics). The Chapter assesses the potential effects of the Proposed Development on the local economy and population during both construction and operational (post completion) phases.

5.43 During the construction stage it is estimated that the proposal will create a total of 705 full- time or equivalent (FTE) jobs across Wales (the wider impact area). Of these FTE jobs, 300 were estimated to be created in Cardiff (the local impact area).

5.44 The Assessment estimates that the generation of economic output by the construction employment of the proposed development, which includes the purchase of construction materials and expenditure of the construction workforce, has the potential to benefit both the local and wider impact areas. The estimated construction capital expenditure associated with the proposed development could deliver a net additional £57.9 million in GVA per annum contribution to the Wales economy during this phase based on the average GVA per employee in the sector of which circa £48.4 million per year is estimated to contribute to the growth of the economy in Cardiff. Over the 11 year construction period, total GVA generation will therefore equate to £637.2 million across Wales, inclusive of £532.8 million in Cardiff. This would account for 6.9% of the GVA in the construction sector in Cardiff, and so is considered a significant beneficial effect.

5.45 During the operational phase employment opportunities will be created within the proposed office, retail, hotel and hospitality uses. It is estimated that this will equate to an estimated on-site creation of 4,066 FTE jobs. Accounting for the displacement of the (estimated) 912 FTE employees of current Site uses, as a worst case scenario, this would equate to the creation of 3,950 operational FTE jobs across Wales, of which 1,570 would be in Cardiff.

5.46 Over the operational lifetime of the proposed development, the economic productivity of the proposed on site uses is predicted to generate £171.9m per annum. Accounting for the knock-on creation of jobs elsewhere in the economy, this would equate to the generation of £187.5m per annum across Wales, of which £133.3m would be generated in Cardiff.

5.47 It is estimated that the delivery of 2,500 new dwellings will accommodate approximately 4,389 residents once fully occupied. An estimated 2,210 of these residents are predicted to be of working age (16 – 64), who have the potential to earn a collective annual salary of £57.5m. Of these earnings, an estimated £25.9m would be spent by residents on convenience and comparison goods and services; a further £13m on goods and services; and £13.7m on ‘making a house feel like a home’.

5.48 Both Cardiff Council and the Welsh Government support a pro-growth economic agenda, prioritising economic development and the creation of jobs. The potential economic impacts of the proposed development clearly strongly accord with the principles and policy provisions of national and local plan policy.

Townscape and Visual Impact

5.49 A Townscape and Visual Impact Assessment (‘TVIA’), prepared by Planit IE, forms part of the ES. The Assessment focuses on the construction and operational effects of the Proposed Development on townscape character; urban grain; land use; public open space; movement and linkages between the Site and surrounding area; site character and the amenity of views.

5.50 The TVIA concludes that there are no significant effects (adverse or beneficial) predicted at the construction phase with respect to townscape character; urban grain; land use; public open space; movement and linkages between the Site and surrounding area; or site character.

5.51 At the operational phase, the TVIA concludes there are no significant adverse effects predicted. Significant beneficial effects were, however, predicted for the proposed development with respect to townscape character; urban grain; land use; public open space; movement and linkages between the Site and surrounding area; and site character.

Biodiversity

5.52 An assessment of biodiversity, prepared by Stantec, forms part of the Environmental Statement. The Assessment reports the outcome of the likely significant effects arising from the Proposed Development in relation to protected ecological sites, habitats and species from site clearance / demolition and operational phases of the development.

5.53 Four sensitive receptors were identified for inclusion within the Assessment, and were categorised as follows:

• Non-Statutory Designated Sites & Habitat:

‒ River Taff SINC, River HPI & Lowland deciduous woodland Habitat of Principal Importance (HPI).

29 • Protected and Notable Species:

‒ Foraging bats;

‒ Otters; and

‒ Migratory fish.

5.54 The Assessment concludes that through the incorporation of diverse habitat planting and vegetation buffers, all effects with the exception of disturbance to otters and bats from lighting, vibration and noise during construction (considered negligible) were deemed beneficial but not significant.

5.55 A number of measures will be implemented as part of the construction period to minimise any potential impacts on biodiversity. This will include works being supervised by an Ecological Clerk of Works (where necessary), careful site set up (compounds, welfare facilities etc), general controls on working hours and recognising seasonal restrictions when carrying out certain works (e.g. piling).

Archaeology and Built Heritage

5.56 A Historic Environment Desk Based Assessment (prepared by Orion) is submitted in support of this application. The Assessment considers the known and potential archaeological and cultural heritage assets within and immediately adjacent to the application site.

5.57 The Assessment confirms that there are no designated or non-designated archaeological remains within the Site. It also confirms that no statutory designations (Listed Buildings, Registered Parks and Gardens, Conservation Areas) located within the Site. The Site does not contain any Locally Listed Buildings, nor are any of the extant buildings recorded on then Glamorgan-Gwent Archaeological Trust (GGAT) Historic Environment Record (HER).

5.58 The Assessment identified one building of historical interest, which is understood to have formerly been the ‘Holloware Factory of Curran Engineering’. The building is located in the southern part of the Site and comprises a large linear two storey red-brick building. The structure is in disused and poor condition. The Assessment notes that whilst some original features survive, the building has undergone significant alteration. This includes the loss of many of the original windows along the southern elevation, modification of the original roof and removal of much of the original industrial fittings. The Assessment concludes that the value of the building is therefore somewhat diminished. On balance the Assessment concludes that the building scores low against the criteria set by Cadw and it not included on the Local List for Cardiff, nor the GGAT HER.

5.59 The ES also includes a specific chapter addressing built heritage. The Chapter considers the impacts of the Proposed Development on the setting of designated heritage assets during the Operational Phase.

5.60 Five sensitive receptors were identified for inclusion within this assessment, due to absence from any of the 16 Townscape and Visual viewpoints:

• The Pierhead Building (Grade I listed building);

• Cardiff Bay Station (Grade II* listed building);

• The Church of St Mary and St Stephen the Martyr (Grade II listed building);

• The Pierhead Conservation Area; and

• The Mount Stuart Square Conservation Area.

5.61 Due to the distance of the Proposed Development from these five sensitive receptors, and the positioning of intervening buildings, views from the heritage receptors to the Proposed Scheme are only predicted to be partial or glimpsed.

5.62 As such, despite the sensitivity of these listed buildings and Conservation Areas being deemed as ‘high’, the Proposed Scheme is considered to only impose negligible effects to all five sensitive receptors. These effects are not significant.

Drainage and Flood Risk

5.63 A Flood Consequences Assessment (‘FCA’) and a Surface Water Drainage Strategy (prepared by Stantec) are submitted in support of this application.

5.64 The Surface Water Drainage Strategy confirms the strategy proposed has been demonstrated to manage the surface water drainage requirements of the Proposed Development as required by the local SAB.

5.65 The FCA confirms that as the application site is allocated for residential/mixed use development within the adopted LDP. It therefore satisfies the justification test outlined in Section 6 of TAN15.

5.66 The FCA notes that the main source of flood risk to the Site is tidal. The risk is, however, considered low due to the presence of the Cardiff Bay Barrage, which protects the Site and surrounding area to the 1 in 1000 (0.1%) annual probability standard. The risk of flooding from all other sources is considered to be ‘low’ or ‘very low’.

5.67 Taff and Ely Velocity Depth Mapping Study and mapping indicates that the Site lies outside the existing defended 1 in 1000 (0.1%) annual probability event, as well as the 1 in 100 (1%) annual probability +25% climate change allowance event.

5.68 The FCA concludes that the future users of the Proposed Development will be safe from flooding and there will be no detrimental impact on third parties. The proposal complies with the TAN15 and local planning policy with respect to flood risk and is an appropriate development at this location.

Noise and Vibration

5.69 An assessment of noise and vibration has been undertaken (prepared by Stantec) to determine the effect of the Proposed Development on the surrounding area and to assess

the suitability of the development for the Site. The assessment forms part of the ES which supports this application.

5.70 The Assessment concludes that the effect of construction noise was considered adverse, but not significant. The effects of construction vibration and noise produced by construction vehicle movements were both considered negligible.

5.71 At the operational phase, the increase in noise experienced by future receptors (on-site); the noise generated by the new water taxi stop; and noise generated from play areas were all considered negligible. The noise of operational traffic and its effects to all existing were all considered adverse, but not significant generating activities at the application site.

Air Quality

5.72 An Air Quality Assessment (prepared by Stantec) forms part of the Environmental Statement. The Assessment focuses on changes to pollution concentrations resulting from traffic generated by the proposed development, and the deterioration of human health as a result of ambient air quality within the Site.

5.73 The assessment was based on quantitative technical analysis informed by computer models, to establish the baseline (2019), future baseline (2026) and future with Construction and Operational phase traffic flows (2026), in order to understand the changes in air quality brought about by the Proposed Development.

5.74 19 existing sensitive air quality receptors and 22 future sensitive air quality receptors were identified for inclusion in the analysis of two effects:

• Changes to pollutant concentrations resulting from traffic generated by the Proposed Scheme during construction and operation; and

• Deterioration of human health as a result of ambient air quality within the Site during operation.

5.75 In both instances, the concentration of the air pollutants nitrogen oxide (NO2) and particulate matter (PM10 and PM2.5) were not predicted to exceed their respective National Air Quality Objectives (NAQOs).

5.76 The Assessment concludes that the pollutant concentrations resulting from traffic generated by the Proposed Development during construction and operation stage were considered adverse, but not significant. The effect of the deterioration of human health as a result of ambient air quality within the Site during operation was considered negligible.

Ground Conditions

5.77 A Phase 1 Ground Conditions Assessment (prepared by Stantec) forms part of the Environmental Statement. The Assessment considers the effects of contamination exposure to human health, ground instability and ecology through the pollution of ground, groundwater and the River Taff.

5.78 The Assessment concludes that with the exception of the risk of the pollution of land and groundwater contamination, which was considered adverse but not significant, all effects assessed at the construction phase were deemed negligible.

5.79 For the operational phase, the Assessment concludes the effects to human health from potential exposure to contamination associated with historical land use; and groundwater pollution from leaching and migration of contamination associated with historical land uses were considered negligible.

5.80 The risk of ground gas migration and accumulative in confined spaces, which may affect future users of the Site, was deemed adverse but not significant.

Sustainability and Energy

5.81 An Outline Energy Statement (prepared by Stantec) is submitted in support of this application. The Statement confirms that the Proposed Development will adopt the nationally recognised energy hierarchy of reducing demand. The Statement demonstrates how this can be delivered in the context of the outline planning application. In conjunction with the energy hierarchy approach, a series of design principles have been adopted within the masterplanning process and will be considered in building design to both passively and actively reduce energy demand and increase energy efficiency.

5.82 The ES includes a Climate Change chapter. The Chapter focuses on the impacts of the Proposed Development in relation to the production of greenhouse gas (GHG) emissions from the combustion of fuels on Site (direct GHG emissions); purchased electricity, heat or steam (indirect GHG emissions); and embodied carbon during construction and operation.

5.83 At the construction phase, the Chapter states that direct GHG emissions are predicted to include the burning of fossil fuels during the use of plant engines, equipment and transportation of building materials and waste by Heavy Goods Vehicles (HGVs) to and from the Site. At the operational phase, these would include the generation of GHGs by increased traffic volumes through the Site and along the local transport network. At both development phases, these effects were considered not significant.

5.84 The Assessment concludes at the construction phase, indirect GHG emissions are predicted to include the use of electricity within the construction office, welfare facilities and lighting on Site; and at the operation phase by proposed residential, commercial and industrial uses, which is generated by the burning of fossil fuels. These effects were predicted to only be noticeable on the local scale. With the implementation of mitigation measures to include the use of energy-efficient building materials and installation of low carbon energy generation technologies (e.g. solar panels), at both development phases there effect are not considered significant.

5.85 The Assessment concludes at the construction phase, embodied carbon emissions are predicted to result from the production of materials such as concrete for use by the Proposed Scheme; and at the operation phase by waste and water treatment. At both development phases, these effects were considered not significant.

Lighting

5.86 A Lighting Strategy (prepared by Stantec) is submitted in support of this application. The Assessment confirms that the Proposed Development will introduce new sources of light into an urban area which is mostly classed as a suburban area.

5.87 The Lighting Strategy confirms that lighting will be designed in accordance with industry standard guidance. The lighting scheme will minimise spill onto adjacent habitat features (specifically the River Taff SINC); it includes directional lighting with shields to minimise the illumination of retained or adjacent habitat features and the LED lighting will use a warm white light colour temperature (at around 3000K) which has less impact on bats. Where lighting is required close to the River Taff corridor, the lighting design will be sensitive, with lower levels of light provided.

5.88 In addition, lighting planned for the proposed footbridge that spans the River Taff will avoid light spill onto the river channel through low level lighting that is either incorporated into the structure of the bridge (i.e. in footways or handrails) or at a low height that is exclusively directed at the path.

5.89 Vastint’s aspiration is for high standards of lighting design that will seek to be:

• Efficient;

• Safe and secure for people moving in and around the Proposed Development; and

• Meet the recognised standards and guidance.

5.90 These aspirations will be met whilst minimising obtrusive light onto sensitive receptors to within guideline levels established by the ILP.

5.91 A lighting design for externally lit areas of the scheme (e.g. buildings, roads, car parks) will be prepared once further details and operational requirements of the development are known and will aim to keep lighting levels within the thresholds of ILP Environmental Zones.

5.92 Subject to the incorporation of the recommendations set out within the Lighting Strategy, obtrusive lighting would not pose a material constraint to the development.

Daylight, Sunlight and Overshadowing

5.93 The Environmental Statement includes a Daylight, Sunlight and Overshadowing Chapter (prepared by Stantec). The assessment focuses on changes in the levels of daylight and sunlight received at the windows of 24 sensitive receptors, which include residential, commercial, education and health care service properties.

5.94 The assessment was based on quantitative technical analysis informed by digital 3D computer models, to establish the baseline (i.e. existing levels of daylight, sunlight and overshadowing) and a future scenario with the operational Proposed Development in place, in order to understand the changes brought about by the scheme.

5.95 The assessment identifies where adverse effects are expected in relation to reduction in daylight and sunlight to existing and future properties. The assessment also considers where there may be an increase in overshadowing to adjacent amenity spaces.

5.96 Future mitigation will be delivered through the detailed design phase of the Proposed Development. This will include further review, analysis and assessment as part of the preparation of future reserved matters applications.

Wind Microclimate

5.97 A Wind Microclimate Assessment, (prepared by Arcaero) forms part of the ES. The assessment focuses on changes to the local wind environment and whether these conditions exceed criteria known as the Lawson Safety Criteria (LSC) and Lawson Comfort Criteria (LCC) as experienced by pedestrians at ground level of the proposed development.

5.98 The LSC identify areas where someone could find walking difficult where wind speeds exceed 15 m/s, and should not be exceeded for more than 0.025% of the time annually. In contrast, LCC thresholds grade wind speeds based on the ability of pedestrians to either sit for a long or short periods, stroll, walk quickly or where wind conditions are made uncomfortable.

5.99 The Assessment concludes that much of the Proposed Development is sheltered from prevailing winds by the western portions. As such wind conditions across much of the Site are negligible and would be expected to be suitable for proposed entrances, thoroughfares and play spaces.

5.100 The Assessment sets out where exceedances do occur, primarily along the western boundary of the Site, careful considerations should be taken to reduce the acceleration of prevailing winds, such as:

• Soft landscaping

• Screens and canopies

• Recessing to provide acceptable conditions for otherwise-exposed entrances

5.101 The Assessment concludes that where significant exceedances of the wind comfort / safety criteria occur, more significant measures could be considered:

• Radius & chamfered corners to reduce corner accelerations

• Stepping mass away from the prevailing wind to interrupt downdraughts

• Podium levels to stop downdraughts reaching ground level

• Increasing spacing between buildings and reducing channelling of wind

5.102 It should also be noted that the effects have been identified prior to detailed design considerations, which form part of later stages in the planning process. These detailed design considerations are expected to ameliorate the effects identified above.

Arboriculture

5.103 A Tree Survey and Arboricultural Assessment have been prepared by Mackley Davies Associates Ltd in support of the application. The majority of the existing trees and vegetation are located along the edge of the River Taff with a few, smaller formal avenue tree clusters spread across the Site. Dense groups of mature and early-mature river corridor trees and shrubs define the edge of the river.

5.104 The Assessment confirms the Proposed Development will result in the loss of 5no. category ‘B’ trees, together with a loss of a small section of category ‘B’ bankside trees (G6) to accommodate the proposed bridge crossing. The proposals would also result in the loss of two groups (G1 & G9) of category ‘C’ trees (containing 17no individual trees), together with 12no individual category ‘C’ trees.

5.105 The Design and Access Statement and GI Statement confirm that the Proposed Development will be supported by a comprehensive planting strategy. This will include generous new native trees and biodiverse planting across the Site. Trees and planting will also be incorporated within communal courtyards within the perimeter residential blocks and will form an integral part of the proposed street hierarchy.

Waste

5.106 The application is supported by a Waste Strategy prepared by Stantec, which considers and estimates the levels of waste expected to be generates and set out the waste management strategies through the construction and operational phases of the Proposed Development.

5.107 The Waste Strategy confirms the Proposed Development will follow the principles of the Waste Hierarchy – ‘eliminate, reduce, reuse, recycle, other recovery and disposal’ - to allow the environmental, social and economic risks from waste to be minimised in line with national and local policy.

Commercial Uses

5.108 The application proposal will deliver a significant quantum of high quality office floorsapce. The intention is that this will deliver a range of options to accommodate start-up business (in the Creative Quarter) to large floorplate high quality office provision within the Business Garden. This will have a positive impact upon the availability of quality modern office floorspace within the city centre and assist in generating footfall across the site throughout the day.

5.109 The application also proposes up to 11,500 sq m of complementary commercial uses to support the approach to placemaking across the Site. The uses proposed include Class A1, A2, A3, D1 and D2. In order to achieve a successful mix of uses across the site, Vastint does not propose to deliver a proportionately large quantum of floorspace dedicated to any one particular commercial use.

5.110 Vastint has no intention to create large floorplate retail (convenience or comparison) units within the application site (defined as having greater than 1,000 sq m (net) retail floorspace).

The intention would be to promote a blend of high quality independent businesses to provide an ancillary offer appropriate to this city centre location and to provide activity throughout the day and into the evening.

5.111 In light of the above, and given the site’s location within a strategic mixed-use allocation within the city centre, a Retail Impact Assessment has not been requested by Cardiff Council in support of this application. An appropriately worded condition could be applied to any future permission to limit the quantum of Class A1 (retail) floorspace and the maximum permitted floorspace for individual units if deemed necessary.

6. Draft Heads of Terms

6.1 Due to the scale and nature of the development proposed it is considered that mitigation in the form of planning obligations is likely to be required. Such mitigation will be secured by means of Section 106 of the Town and Country Planning Act 1990 (as amended).

6.2 Negotiations with the LPA are ongoing and will be concluded during the determination of the application proposal. Discussions will be informed by the Cardiff Planning Obligations SPG (January 2017). The SPG sets out the Council’s overall approach towards planning obligations to secure the provision of affordable housing and site specific measures required to mitigate the impact of development. The process will also be subject to the completion of a detailed viability assessment, which will be independently reviewed by the District Valuer.

6.3 At this stage, Vastint considers that the following matters will need to be addressed as part of the Proposed Development and/or through appropriate financial contributions or the provision of works ‘in-lieu’ of financial contributions:

• Affordable housing;

• Education;

• Highways infrastructure improvements;

• Public realm enhancements;

• Local transport improvements;

• Employment and training; and

• Signage/city legibility enhancements.

6.4 Following further detailed discussions with the Local Planning Authority (and relevant stakeholders) and the completion of a detailed viability assessment, it is envisaged that Heads of Terms can be agreed and a full Section 106 agreement prepared.

6.5 Obligations will need to be phased so that items and/or payments are triggered by either the commencement of development, or the completion and occupation of dwellings. It will be necessary to agree the final triggers for each obligation as part of the final Section 106 package.

Affordable Housing

6.6 Affordable homes will be delivered as part of the application proposal. These will help to alleviate pre-existing affordability issues and accommodate those who are unable to afford market housing. The precise proportion of affordable housing will be confirmed through the determination of the application and subject to viability testing. However, Vastint has agreed separately with Cardiff Council that a minimum of 5% affordable housing will be

provided on-site. In addition, an off-site contribution of £9m will be payable to the Council for the provision of affordable housing. The timing of the delivery of the affordable housing and payment of the contribution are defined in the Unilateral Undertaking dated 23 December 2020.

7. Summary and Conclusion

7.1 This Planning Statement has demonstrated that the comprehensive residential-led, mixed use redevelopment of The Embankment site is entirely appropriate within this location and is fully compliant with both national and local planning policy.

7.2 The proposal will deliver the comprehensive redevelopment of the Site and surrounding land, a strategic and under-utilised area of City, transforming this area to provide a vibrant and highly permeable new community in the heart of Cardiff.

7.3 The proposal is in accordance with all tiers of planning policy. The development will deliver long term policy objectives to implement the residential-led regeneration of this area of Cardiff, as anticipated in the adopted LDP (and previous policy documents). The application proposals are consistent with the site specific allocation identified under Policy KP 2(A).

7.4 The supporting documentation submitted with the application demonstrates that there are no environmental or technical constraints to developing this site, which is well located within Cardiff City Centre, with excellent access to existing local services and facilities.

7.5 The Proposed Development will deliver sustainable development, for which there exists a presumption in favour, in line with national and local planning policy objectives.

7.6 The proposal represents an integrated approach to development, which addresses the economic, social, environmental and cultural themes of national and local policy (and enshrined through the WBFG Act) and will ensure the delivery of ‘sustainable development’.

7.7 The proposals will have a positive impact on the wider City Centre by increasing resident footfall at the heart of the city and providing significantly enhanced pedestrian connections. The development will also deliver key spin-off benefits, such as the creation of new public open space, public realm improvements, enhanced access to the River Taff, and the regeneration of parts of the centre that are a blight on the wider area.

7.8 The scale of the proposals and the comprehensive approach to regeneration will transform this area of City Centre, creating a new sustainable city centre neighbourhood. The development is also likely to act as a catalyst for further investment.

7.9 The supporting ES concludes that the application proposal will result in a limited number of both beneficial and adverse significant effects. A number of the significant effects predicted would be during the construction phase and would be temporary. It is likely that significant adverse residual effects will reduce as the detailed design of the scheme emerges at the Reserved Matters stage. Detailed mitigation will be provided through detailed design (at the Reserved Matters stage), to assist in addressing significant effects that have been identified and will be subject to further assessment as appropriate.

7.10 The application proposal is fully compliant with both national and local planning policy and will deliver a development that is appropriate to, and will significantly enhance, the

local context. We therefore consider that the benefits of the Proposed Development are substantial and that there are no adverse impacts that would significantly and demonstrably outweigh those benefits.

7.11 The Proposed Development will deliver substantial benefits including:

• The delivery of development in a highly sustainable location, which is identified as a strategic priority for urban regeneration within the adopted Cardiff Local Development Plan (2016) (the LDP).

• The sustainable regeneration of the Site, without any unacceptable impact on the supply of employment land and associated considerations.

• Deliver good quality homes, employment and commercial uses whilst ensuring a positive contribution to health and prosperity in the city.

• A high quality and flexible design approach to Placemaking that complements the ongoing regeneration of the Cardiff Central Enterprise Zone in creating a new sustainable community in this area of the city centre.

• Safeguarding and enhancing the natural environment, including effective green infrastructure and protected species.

• Provide publicly accessible waterfront areas along the River Taff that are well laid out with good natural surveillance.

• Promoting the use of alternative modes of transport, highways safety and appropriate levels of car parking.

• Providing new connections and links across the city, including a new pedestrian and cycle bridge across the River Taff into Grangetown.

• Reducing on and off site flood risk, including through utilising sustainable urban drainage systems (SUDs).

• Ensuring any proposal avoid any unacceptable adverse impacts in terms of noise, air quality, ground conditions and waste.

• Significant job creation including the creation of 705 full-time or equivalent (FTE) jobs across Wales (the wider impact area) at construction phase and the creation of 3,950 operational net FTE jobs across Wales at the operational phase.

• Significant investment including a net total of £637.2m to be generated from economic output by the construction employment of the proposed development and £171.9m per annum from the economic productivity of the proposed on site uses.

7.12 There are no technical obstacles which cannot be appropriately mitigated or addressed to enable the Proposed Development to come forward on this Site. There are also demonstrable benefits to bringing forward development, including the overriding need for new sustainably located housing. The scheme will deliver market and affordable

housing, significant areas of public open space, new connections across the site to the wider city and substantial areas of Green Infrastructure. In this context, the positive social, environmental, economic and cultural benefits of the proposed housing provision weigh significantly in favour of granting planning permission.

7.13 The proposal would help to meet the identified needs of the current generation, for good quality market and affordable housing in a location where there are real opportunities to foster a sustainable lifestyle and where both new and existing residents of Cardiff can benefit from sustainable transport infrastructure improvements and high quality placemaking.

7.14 The well-considered placemaking proposals would bring environmental and cultural benefits along with social provision to support economic growth; good quality market and affordable housing would improve/sustain people’s health, as would the opportunities for active lifestyles and recreation/food production via the Green Infrastructure strategy for the Site.

7.15 In conclusion, the Proposed Development represents positive sustainable development that will continue the regeneration of this area of the city centre. The positive benefits are material considerations that weigh heavily in favour of granting planning permission without delay.

Appendix 1: DCfW Response to the Proposals

Design Review Report

Curran Embankment, Cardiff DCFW Ref: N222 Meeting of 10th December 2020

Review Status CONFIDENTIAL Meeting date 10th December 2020 Issue date 16th December 2020 Scheme location Cardiff Scheme description Mixed-use Scheme reference number N222 Planning status Pre-Application

Declarations of Interest

Panel members, observers and other relevant parties are required to declare in advance any interests they may have in relation to the Design Review and meeting Agenda items. Any such declarations are recorded here and in DCFW’s central records.

Note on current operational context: The Design Commission for Wales is operating during necessary public health measures due to the impact of the Coronavirus COVID-19 pandemic and this report follows the recent online review meeting.

Consultations to Date

DCFW considered pre-review material and provided questions in advance of design review in March 2020 but the review did not go ahead due to cancellation by the design team and rescheduling. Previous proposals for the site that have been brought forward by other potential developers/consortia have been reviewed in previous years.

The Proposals

A masterplan is being developed which for proposes mixed use redevelopment of the brownfield site of approximately 15ha. The proposed development would include residential, office, commercial and retail/leisure/food and drink accommodation.

Main Points

The Commission welcomed the comprehensive approach to this significant site within the city and the work that has been undertaken to set out key urban design considerations for the site. The following points are important in the further development of the proposals.

Identity Many urban design principles are well reflected in the proposals, but further work is needed to make the proposed development distinctive to Cardiff and/or Butetown. There is very little that distinguishes this development from any other place. Adding a further level of identity and meaning to the proposals will help to firmly ground it in its context. This will require further site, context and historic analysis as well as community engagement and involvement. It is important that a sense of place that is unique to this area of Cardiff develops here.

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While the existing buildings on the site may be considered to offer little architectural merit, they are a strong reflection of the history of the site and still offer accommodation to a range of businesses and employers that activate the site. Given that the site will take some years to develop completely we strongly recommend one or more of the buildings is retained to offer flexible meanwhile and/or long-term space to support local businesses. As office, retail and residential markets change (particularly given the recent impact of COVID-19) this would allow a more place-led and iterative approach that retains life and activity and makes the site more distinctive. There are many precedents that support this as an approach to a site of this scale and nature. Retaining some of the buildings will also help to ensure that the development is distinctive and remains part of Butetown.

Movement and Public Realm The proposed grid of streets is logical, but it is important to ensure that it does not become too homogeneous. The design of the streets should reflect their expected use in terms of the range of activities present and the how busy a route it is likely to be. Some routes will be busy with a concentration of activity whereas others will be quieter with much lower footfall and this should be reflected in the design. An important element of this will be landscape and planting and there may be opportunities to enhance the contrast between planting and buildings to increase the ecological value and provide some drama. Sufficient space needs to be allowed for this.

Street widths, distinctive buildings and landmarks will also be important for legibility. Exploring this as a journey through the site would be helpful.

We welcome consideration of flexibility of parking spaces that may not be needed in the future as travel habits change. This flexibility should be built into the proposed parking structures.

The delivery, management and maintenance of the public realm will be key to its success. Ensuring that key elements of the public realm are delivered with each phase of the development is necessary through planning conditions. A management plan should coordinate all aspects including privately managed spaces, adopted highways, SuDS and publicly managed open spaces.

Activity The proposals include a mix of uses that will help to bring life and activity to the place. This would be further enhanced through greater diversification of the range of residential sizes and tenures. The proposals for the public realm include play spaces but there are very few larger residential units (28 town houses) that would accommodate families. A dominance of one and two bed apartments will not create a diverse community and we encourage further review of how to integrate good provision for family living in a development of this type and density. This type of provision is currently very scarce in Cardiff and could be a distinctive and attractive feature of this development.

Form High density development is, in principle, appropriate for this location with good connections to the city centre and public transport. The proposals present an appropriate balance of development density with public and communal spaces. However, the riverside location where the individual buildings are two deep seems overcrowded and warrants further review. This arrangement erodes the connection to the riverfront and will be made

3 | P a g e more complex with access requirements to the buildings. Freeing up this space would allow more diversity within the riverside park.

Taller buildings in key locations are appropriate in principle as part of the townscape but must be well integrated at the ground floor level and the rationale for their height and location clearly set out. Any taller structures will need to be of the highest design and construction quality.

Energy Strategy The energy strategy for the site needs further development even at this stage. A fabric- first approach is positive, but consideration also needs to be given to the provision of heat and power for this significant development. Orientation should also be considered to optimise natural solar gain and avoid overheating.

Next Steps Reference could usefully be made to the Placemaking Wales Charter and guidance document that can be found on the DCFW website www.dcfw.org to help inform the development of a sense of place. A comprehensive engagement and involvement strategy should be set out to include the ongoing development of proposals for the site as well as during construction. We would welcome the opportunity to review the proposals as they develop beyond the outline planning stage.

Comisiwn Dylunio Cymru Design Commission for Wales is the trading name of DCFW LIMITED, a Private Limited Company established under the Companies Act 1985 and 2006, Company No: 04391072 incorporated in England and Wales as a wholly owned subsidiary of the Welsh Government. Registered office: 4th Floor, Cambrian Buildings, Mount Stuart Square, Cardiff CF10 5FL T: 029 2045 1964 E [email protected]. The comment recorded in this report, arising from formal Design Review through our Design Review Service, is provided in the public interest for the consideration of local planning authorities as a material consideration, and other users of the Design Review Service. It is not and should not be considered ‘advice’ and no third party is bound or required to act upon it. The Design Review Service is delivered in line with DCFW’s published protocols, code of conduct and complaints procedure, which should be read and considered by users of the service.

A Welsh language copy of this report is available upon request.

Attendees

Agent/Client/Developer: Andrew Cobden, Vastint Louise Robinson, Vastint

Architect/Design Team Euan McLaren, 3D Reid Huw Jones, Turley Ed Lister, Planit Michael Westlake, Supervene Architects Alexandra Chairetaki, Planit Henk, Gellens, Stantec

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Local Planning Authority Mike Biddulph, Cardiff Council Simon Gilbert, Cardiff Council Ross Cannon, Cardiff Council Amanda Sutcliffe, Cardiff Council

Chair: Jonathan Vernon-Smith Lead Panellist: Steve Smith Design Review Panel: Lynne Sullivan Jen Heal, Design Advisor, DCFW Efa Lois, Place Advisor, DCFW

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Appendix 2: Site Location Plan

44 Notes

Do not scale from this drawing. N All dimensions are to be checked prior to construction and any discrepancies are to be identified to the Architect.

Key

Planning application boundary

P02 08/01/21 PAC Issue. DP P01 21/07/20 First Issue DP

Revisions

Status Information

Client Vastint UK

Project The Embankment Cardiff

Title Existing Location Plan

Scale Size Date Drawn Checked 1:2500 A1 21/07/20 DP EMcL

3DReid www.3DReid.com Architecture Interiors Masterplanning

Drawing No. Rev. 190139-3DR-SI-XX-DR-10010 P02

Appendix 3: Policy KPA 2 (A) Extract

Turley Office 18 Windsor Place Cardiff CF10 3BY

T 029 2034 4445