CADER HOUSE,

CADER AVENUE, KINMEL BAY LL18 5HU

Draft DESIGN AND ACCESS STATEMENT

MARCH 2020

PARRY DAVIES ARCHITECTS LTD

PDA REF: 20.6005/8

OFFICE ADDRESS: STUDIO 55:20, NORTH BUSINESS PARK, LL22 8LJ 01745 585517 Plans reproduced by permission of the Ordnance Survey on behalf of the Controller of Her Majesty’s Stationery Office © Crown

Copyright. All rights reserved.

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1.0 Introduction: Location and Site- The statement has been prepared to support of a full planning application for the redevelopment of the former Elizabeth Anne factory in Kinmel Bay.

The purpose of this Design and Access Statement is to assist those assessing the proposals providing a simple and direct supplementary statement explaining the reasons behind the design decisions. This statement will explain the design and appearance, and other details as submitted in the planning application. A formal pre application consultation was undertaken with County Borough Council’s planning and building regulation departments and under the Town and Country Planning (Development Management Procedure) (Wales) Order 2012 a formal consultation was entered before applying for planning The development upon completion will provide flagship offices, warehouse and trade merchants together with 6 smaller lettable premises, on land which is allocated only for commercial ventures . 1.1 The Location-

Kinmel Bay is a north-facing, sandy beach fronted town on the coast, predominantly known for its tourism and caravan parks. The town is bordered on the landward side by a narrow promenade and sea wall along its entire length. Access to the beach is across the promenade from an extensive tarmac car park located on St Asaph Avenue at the rear of the ASDA store.

Kinmel Bay and its neighbour are urban areas that are larger than a village but smaller than a city. Unless both grow to a size where it is elevated to a higher administrative status it is effectively a community but to differentiate between the two at the turn of the last century, both towns were granted the right to allow their elected representatives call themselves a "Town Council" and to, from their number, elect a Mayor. Other than that they have the same legal rights and responsibilities as a Community Council.

1.2 The Site – The rectangular site measures approximately 217m (w) x 100m (d) is bounded by St. Asaph Avenue to the east, Cader Avenue to the south/west and smaller scale business premises to the north. The site is known within the area as the former Elizabeth Anne Factory. Within the application site, a right of way passes alongside the eastern boundary to serve access to the rear commercial premises. This access with be kept clear at all times. The land is superbly situated for businesses that require a high quality environment and modern high tech buildings, and combine corporate image and practicality. Kinmel Bay has established itself as one of the most prominent towns in the area for business. The site is not within a conservation area, nor an Area of Outstanding Natural Beauty, however it lies within a flood risk zone. There are no listed buildings within the vicinity of the site and consequently there are no special designations to be accounted for. The site is currently not in use but has been approved for varying useages and the land under consideration equates to 20,183 m2. The building is currently derelict, external walls are insitu but the roof has been stripped of asbestos. 1.3 Relevant Planning History- The site has an extensive planning history. The applications which are most relevant are as follows: 0/37061 Demolition of existing offices, sub division of industrial unit from 2 units into 3 separate units and use of land for siting 20no. storage containers. Approved subject to conditions on 23 rd November 2010. 0/45493 Certificate of lawfulness for the proposed demolition of part of building, subdivision to self-contained units, creation of means of access to a highway, creation of means of access to a highway, creation of access way and change of use from Class B2 to Class B1.

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Split decision issued on 8 th October 2018, determining that the following are lawful: i) The demolition of the outbuilding identified by a dashed line on drawing no. 714-51-201P, received by the local authority on 22 nd August 2018, subject to conditions in Part 31 of the Second Schedule to the Town and Country Planning (General permitted Development) Order 1995; ii) The creation of an access as shown by the annotation ‘line of new access road way’ on drawing no. 714- 51-201P, received by the local planning authority on 22 nd August 2018, iii) The formation of a crossover onto the private road along the eastern boundary of the application site, identified on drawing no. 714-51-201P, received by the local planning authority on 22 nd August 2018; And that the following are unlawful: i) The change of use of the main building from Class B2 to Class B1 of the Schedule to the Town and Country Planning (Use Classes) Order 1987; ii) The demolition of parts of the main building identified on drawing no. 714-51-201P, received by the local planning authority on 22 nd August 2018; iii) The alterations to the main building identified on drawing no.714-51-201P, received by the local planning authority on 22 nd August 2018; 0/45968- relates only to the buildings identified therein, and not to the external areas Certificate of Lawfulness for existing use of Unit A for B8, Unit B for B8, Unit C for use Class B1/B2/B8 and Unit D for B1/B8 use. Replacement of existing roof. Split decision issued on 14 th June 2019, determining that the following are lawful: i) The use of the area identified as Unit B on Plan 2 within Class B8 of the Schedule to The Town and Country Planning (Use Classes) Order 1987; ii) The use of the area identified as Unit C on Plan 2 within Class B1 of the Schedule to The Town and Country Planning (Use Classes) Order 1987; iii) The use of the area identified as Unit D on Plan 2 within Class B1 of the Schedule to The Town and Country Planning (Use Classes) Order 1987; iv) The reroofing operations identified on drawing nos. 714-51-330P and 714-51-311P received by the local planning authority on 13 th February 2019; And that the following are unlawful: i) The use of the area identified as Unit A on plan 2 within Class B8 of the Schedule to The Town and Country Planning (Use Classes) Order 1987; ii) The use of the area identified as Unit C on plan 2 within Class B2 and B8 of the Schedule to The Town and Country Planning (Use Classes) Order 1987; iii) The use of the area identified as Unit D on plan 2 within Class B8 of the Schedule to The Town and Country Planning (Use Classes) Order 1987; The units deemed A, B, C and D are as per the plan above:

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1.4 Proposals The current use has been established by Council by virtue of a certificate of lawfulness (0/45968) for B8 and B1 useage. The site measures 18700 m2 (excluding right of way) and the existing building some 10600 m2.

The client is CL Jones Builders Merchants and they are seeking to demolish approx. 4065m2 of the footprint (38%) for yard storage, and within a portion of the existing building install a trade counter, secure warehousing and offices/showroom. The remainder of the site will be subdivided to form 6 smaller, self-contained units.

Thankfully, the asbestos roof has all been stripped and all that remains are the external walls, portal frame bays, roof sheeting rails and some internal division walls. The scheme is mainly cosmetic, new roof and some aesthetically pleasing elevations changes, and the creation of the self-contained units within the same envelope. The proposals formally constitute the: • Demolition of outbuildings, currently deemed of unlawful use and erection of sand/aggregate bays • Demolition of 4065m2 of B8, B1 and partially unlawful superstructures to form yard ancillary to the use of a builders merchants. Floor slabs will be retained • Subdivision and change of use of 2660m2 floorpsace of B1 useage to B1/B8. These will be 6 smaller lettable units • Change of use of the remaining 3380m2 B1 use to form 680m2 of trade counter (B8) and 2700m2 of builders merchants (sui generis) • 572m2 of office space (over two floors) to remain as B1 use • The use of section of land adjacent to the right of way serving the rear units, to be laid out as hard standing for overflow parking Fundamentally we propose no changes to: Sewerage or surface water drainage Access or egress locations Ground conditions or pose contamination problems as the floor slab of the demolished building will form the external hardstanding area for the yard. Only the superstructure will be removed, substructures will be retained. THE DESIGN STATEMENT 2.1 Client & Design Brief – The two hectare site was purchased by CL Jones Holdings to provide yard storage area, with the potential to subdivide the remaining floor area to allow for sub-letting to provide additional revenue. C.L.Jones is a family run timber & builders merchants established in 1982 which has grown to have 6 sites in Gwynedd, Anglesey and Conwy areas- Bethesda, Caernarfon, , Mynytho and Llangefni with a Retail outlet in the centre of Llanrwst.

All branches have their own delivery vehicles all with crane off-loading capability and the deliveries are organized within each branch and normally delivered next day; the same ethos will be applied at Cader House. Citing the merchants in Kinmel Bay is perfect for the area as the closest facility is in Meliden (Thorncliffe’s), (Travis Perkins, Huws Grey and Jewson), then geographically within the Conwy border the nearest is Mochdre, some 12 miles west.

All branches stock timber, Sand & Aggregates, Cements, Plasters, Sheet Materials, Roofing Slate, Kitchens & Bathrooms, Heating & Plumbing, Building Chemicals and paints, Tools, Decorating, Workwear The new development, which will ultimately provide around 3950 sq m of floor space for the builder’s merchants, with approx 440m2 sub lettable spaces offered as an opportunity for businesses and organisations to create offices tailored and built to their own specific requirements. This will provide flexible units with mix of office and workshop areas in order to be attractive for organisations to re-locate to the area. Currently, the Tir Llwyd Enterprise offers no new opportunity for companies which have the need for smaller scale storage and workshop facilities, yet need corporate images in which to flagship their excellence. 4 | 1 4

Prior to establishing the design brief, and indeed purchase of the land, meetings with both planning and Building Control Departments were held for their informal comments and a pre application made.

2.2 Physical: Character & Appearance –

Details of the design and appearance form part of this application and for clarification; the facades we have chosen for the merchants, office building and the six individual plots maintain a business/trading park aesthetic using insulated metal composite panels, for their cleanliness and ease of maintenance and to produce a contemporary aesthetic. The existing brickwork will be cleaned down and repointed where necessary. The choice of materials will ensure the buildings are modern yet possess a quality that will not date the facades in years to come. The nature of the end users business is currently unknown for the smaller units however we have considered non illuminated advertisements during the design process.

We are aware of the need to advertise the individuality of each business and the need to guide their clients to their place of work once occupied, and for this, we have designed the frontages to be able to incorporate signage which is well related to the façade.

Signage will also be positioned at the entrance to the site and at low level, within raised shrub pockets to ensure an uncluttered appearance and avoid creating a highway safety hazard. The signage will ensure road safety for vehicles and pedestrians at all times. By placing the signage within foliage, they will integrate into their surroundings and enhance the development rather than detract from the units as a whole.

2.3 Physical: Site Layout –

56% of the site is currently covered in a built form and useable space, despite the usage and condition. Demolition of 4000m2+ of this will ensure that the site can accommodate the prospective business adequately ensure vehicles can turn freely within the site and exit in a forward gear. The proposals take advantage of the rectangular form of the site and separate points of access. These access points from Cader Avenue are fixed by the previous approvals and will creating a pleasing approach into the site. The boundary fences and security are all fixed. The surplus land which includes the right of way and the land up to St. Asaph Avenue will be cleaned of all surplus vehicles and a hard standing will be provided for the rear garage to allow the business to store vehicles whilst being fixed, freeing up the Cader Avenue frontage. This will vastly improve visibility for vehicles and pedestrians navigating the junction, and ensure the road less obstructed. Cader Avenue has recently been the subject of an Order under Sections 1 and 2 and Part IV of Schedule 9 of the Road Traffic Regulation Act 1984, served by Conwy County Borough Council, the effect of which will –

1. Prohibit the waiting of vehicles at any time in the lengths of road. Both sides; from a point 25 metres south-west of its junction with St Asaph Avenue for a distance of 15 metres in a south-westerly direction. 2. Prohibit the waiting of vehicles during the hours 8am-4pm in the lengths of road specified. North-western side; from a point 40 metres south-west of its junction with St Asaph Avenue to point 10 metres north east of its junction with Llys Branwen. South-Eastern ; from a point 40 metres south-west of its junction with St Asaph Avenue to point 11 metres north east of its junction with Dulas Avenue AND from a point 10 metres south-west of its junction with Dulas Avenue to point 10 metres north east of its junction with Llys Branwen. 3. Revoke the restriction in the length of road specified South-Eastern; from a point 10 metres south- west of its junction with Dulas Avenue to point 10 metres north east of its junction with Llys Branwen

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Exceptions will be provided in the proposed Order to permit waiting for the purposes of alighting, boarding, loading, unloading and works of maintenance, repair and the like.

Exceptions will also be provided in the proposed Order for vehicles displaying both a disabled person's badge and a disabled person's parking disc.

2.4 Physical: Amount & Density – Not applicable 2.5 Physical: Scale – Scale does not form part of this application as the buildings height is predetermined by its existing built form. For clarification, the buildings on the development plots maintain the commercial approach of providing relatively low single and two storey buildings in a commercial setting. The proposal site lies entirely within Zone C1 as defined by the Development Advice Maps referred to in TAN15. Natural Resources Wales (NRW) advises that the site has previously flooded in 1990.

In response to the consultation on the pre-application enquiry, NRW sought clarification from the local planning authority on the lawful planning status of the site. The local planning authority has advised NRW of this position, and that Certificate of Lawfulness 0/45968 does not include any limitation on the intensity of the uses. On this basis, NRW considers that the proposal should consider flood risk in making the building’s structure and fittings flood resilient and resistant.

As such, NRW advised that the proposal should be supported by a limited Flood Consequence Assessment, which details flood resistant/resilience measures along with a suitable flood action plan based on flood warning and/or local conditions. A Flood Management Plan has been prepared for this effect.

This application proposes no change to the finished floor levels and the emergency evacuation procedure, should a maximum flood event ever occur, would be the same regardless of whichever measures would be implemented.

The site at Cader Avenue has taken a long time to bring a positive and proactive buyer and has suffered many setbacks problems over the years due to the uplift in costs.

The flood waters would still be allowed to enter the building through opened doors. We will also ensure that all incoming services terminate at high level, to safeguard against potential damage. We will be providing a proposed flood evacuation plan prior to the building being occupied, which will include details of linking up with an early warning flood system (which can be approved by the planning department). 2.6 Physical: Landscaping – The site possesses some landscaping to the site frontage and alongside the right of way access. To promote a greener Conwy, we propose to plant two additional silver birch trees to the frontages. The current trees have been pruned back to encourage growth

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2.7 Physical: External Space –

The collection of units will be read as a whole rather than individual designs competing against each other. Car parking is shown to the units’ frontages and sides that will be easily identifiable for each business and achieve the local authority’s current guidelines for parking standards without compromising landscaping and visual amenity. It must be noted that this meets the current parking legislation with a high level of demolition, the building has an existing designated and lawful use and could trade accordingly. These parameters are above and beyond the site’s scope as its stands and therefore should be deemed favourably.

2.8 Social - Granting approval to the scheme will ensure a planning objective of providing new and good quality business units within the area marked for B1, B2 and B8 redevelopment, simultaneously ensuring the future economic wellbeing of the wider business community. 2.9 Economic Principles – In determining the application, there are the major employment benefits to consider for the construction and future maintenance of these individual units.

2.10 Policy Context – We have collaborated with the client to develop a series of key objectives, for these units in general and for the appearance of the premises as a whole, sustaining the business character and establishing a successful relationship between public and private space.

The proposal aims to comply substantially with Conwy County Borough Council’s guidelines in the following policy respects, and for the reasons articulated–

The adopted Development Plan consists of the Conwy Local Development Plan (2013) which is currently undergoing review. The policies in the adopted plan which are most relevant to the proposals are as follows: DP/1 Sustainable Development Principles DP/2 Overarching Strategic Approach DP/3 Promoting Design Quality and reducing Crime DP/4 Development Criteria DP/5 Infrastructure and New Developments DP/6 National Planning Policy and Guidance EMP/1 Meeting B1, B2 & B8 Office and Industrial Employment Needs EMP/3 New B1, B2 & B8 Office and Industrial Development on Non-allocated Sites. EMP/4 Safeguarding B1, B2 & B8 Office and Industrial Sites. EMP/5 Office and Industrial Employment Improvement Areas NTE/3 Biodiversity NTE/8 Sustainable Drainage Systems NTE/9 Foul drainage CTH/5 The STR/1 Sustainable Transport, Development and Accessibility STR/2 Parking Standards STR/3 Mitigating Travel Impact

Supplementary Planning Guidance (SPG)

The Council has adopted the following SPG which are relevant to the proposal LDP2 Parking standards 7 | 1 4

LDP5 Biodiversity LDP27 Trees and Development LDP35 Safeguarding B1, B2 and B8 Office and Industrial Sites.

Other Material Considerations

The following national planning policy documents are relevant to the proposal Planning Policy Wales (10 th edition) TAN5 Biodiversity TAN12 Design TAN11 Noise TAN15 Development and Flood Risk TAN18 Transport TAN23 Economic Development Welsh Government Circular 008/2018

The site forms an allocated employment site in the LDP. As noted previously, the site has a lawful use for Part B1 and Part B8 activities.

Paragraph 1 of Policy EMP/4 states that:

“Existing B1, B2 and B8 office and industrial employment sites as designated on the Proposals Map, are safeguarded for the purposes of B1, B2 and B8 uses only. Development that would lead to the loss of existing B1, B2 and B8 employment sites on designated land will not be permitted. Proposals for changes of use between the B1, B2 and B8 use classes on existing designated land will be permitted provided the proposed development does not prejudice the strategic employment land requirement, is compatible with the amenity of occupiers of neighbouring properties and the environment in general and subject to being acceptable in terms of other Local Development Plan Policies”

The proposed development would comply with the above policy.

3.1 Landscape –

It is considered that the proposal respects its natural and built environment setting adjacent to the existing residential dwellings and our proposals for new hard and soft landscaping are slight interventions, for the better. The scheme will ensure that the requirement for maintenance will be minimal which will lead to a better overall appearance.

3.2. Habitats – No protection measures required. 3.3. Energy – Good practice will be adhered to in respect of limiting thermal bridging and all doors/windows will be double- glazed and draught sealed. 3.4 Waste / Water Management – The property will rely on trade waste / recycling collection and will be a subject to a separate management company. DRAINAGE STRATEGY STATEMENT. The Council’s Environment, Roads and Facilities Department advised that the proposal does not exceed the threshold for requiring approval from the SuDS Approving Body (SAB) under Schedule 3 of the Flood Water and Management Act 2010.

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Policy NTE/8 of the Local Development Plan notes:

1- The use of Sustainable Drainage systems will be required wherever reasonably practicable with preference for on site disposal and where satisfactory arrangements can be put in place for the long term maintenance of those systems. Where this is not proposed a developer will need to justify that discharge is necessary and is adequately controlled. 2- Subsequent preference for surface water drainage will be for: a- Drainage to a surface water body (river, lake etc) subject to appropriate treatment and attenuation b- Drainage to surface water sewer c- Drainage to a combined sewer 3- The developer must demonstrate that higher preference drainage options are unfeasible before proposing less sustainable options.

SuDS cannot be implemented on the site as there is no surplus land in which to install any alternative drainage strategies such as attenuation tanks. Also with the possibility of any ground contamination the ground areas will remain undisturbed. All areas of main roof will discharge as per existing surface water sewer. There are no changes proposed to the surface water drainage system or any additional discharge to it.

Map, ref 298858,379882 below, annotates the foul and surface water runs in Cader Avenue. The building is situated within a row of established properties. Despite an element of demolition within the proposals, the land within the applicant’s ownership is to be fully used and there is no scope in which to install any alternative drainage strategies.

The existing drainage connection will be used on site and nominal 1:40 gradients will be provided on the internal drainage systems.

3.5 Sustainability Our client will be committed to ensuring that the scheme will not carry out activities that adversely affect the environment, ensuring the wise use of materials and resources within a framework in which economic and environmental are integrated and balanced.

Building Carbon Emissions have been considered during the progression of the scheme and have steered decisions such as material choices. The whole life carbon methodology for the project is ideal as the building is being re-used rather than developing greenfield sites.

Localism has been the key for the whole scheme and the ethos of the project is to deliver quality business units hereby retaining the key workers in this locality.

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The embodied carbon has also been carefully considered and materials have been chosen for their source and extraction. Natural resources will be specified, timber, stone etc. A building that is hard to heat is more likely to cause health problems. We aim to assist the thermal efficiency of the units by specifying elements which focuses on ‘fabric first’ which will ensure the walls, floor and roof will be insulated to their maximum and PV cells will be installed on the roofs- see site plan.

The most important step for recycling of construction waste is on-site separation and CL Jones will be actively installing extra effort and training of their personnel. CL Jones have been members of Recycle Wales for many years and a current certificate can be supplied.

3.6 Contamination

The pre-application response noted ‘the site has been used as general engineering works and later a factory development including the storage of products associated with the manufacturing process. The Principal Environment Officer advises that these historical activities are potentially contaminating former land uses. The breakout of the site surface has the potential to encounter remains of former structures used for the storage of process chemicals and potentially impacted ground which could have occurred over the long term duration of use. As this could result in the creation of potential contaminant linkages with the proposed site use, the principal Environment Officer advises that further investigation is undertaken, to include site investigation and risk assessments’.

Categorically the ground conditions will not be disturbed in the vicinity of the demolition area. The floor areas within this footprint are of reinforced concrete and this is an ideal base in which to site yard storage. It is not of economic sense, not time essence, to remove any sub-structural work only to then replace with a like for like basis, (although a tarmac finish would be of a lesser standard than the durable condition of the current floors ).

We therefore question the need for a contamination report on this basis as it is not applicable.

4. Community Safety The proposal is not considered to have any significant adverse effect on community safety. The public realm is not materially affected. In addition:

• There will be no discharge of obnoxious or dangerous omissions form the sitye • Security will be maintained as existing • Working traffic from the site will generally cease at 6pm

THE ACCESS STATEMENT

5. Movement to and from the development 5.1 The Site – There are four main vehicular entrances to the site from Cader Avenue, one of which is the right of way as noted previously. Running east to west the remaining three access points will provide access to pedestrians, vehicles and bicycles to serve: Builders merchants and offices Offices and Unit 1 Units 2-6 The site features good pedestrian and cycle links from St Asaph Avenue, which is in easy walking distance and links costal towns to the A55. Regular bus services run along the nearby. The County Highways Department issued a memo in response to the pre-application consultation to the Planning Department and we clarify the following:

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1. The site plan indicates the movement and car parking proposals for the site as a whole. The end use of Units 1-6 which are to be the smaller sub-divisional units for revenue is currently unknown, however we have provided approx. staffing levels in accordance with the guideline Employment Density as cited in LDP2 being 35-45m2 per employee (figure of 40m2 used for mid-level numbers as potentially the units could be used for storage purposes requiring no staffing levels)

Parking requirements will be as follows, and for this purpose we have deemed Kinmel Bay to be Zone 3 – Urban.

Unit/name Use class Floor Anticipated number of Parking Parking proposed area staff requirements in standards (m2) accordance with LDP2 CL Jones Sui generis 2700 Initially 15 to be 3 commercial 3 VAN Builders trained in the vehicle spaces + SPACES Merchants and company, expected to 1 space per AND 42 warehouse rise to 20 after 12 80m2 = 42 SPACES months of trading spaces CL Jones B8 680 Builders trade counter CL Jones B1 572 1 space per 16 Offices 35m2 = 16 associated with merchants and trade counter Unit 1 B1/B2/B8 450 10 PER UNIT TO TOTAL Unit 2 B1/B2/B8 440 10 BE CREATED REQUIRED Unit 3 B1/B2/B8 440 10 we anticipate SPLIT FOR Unit 4 B1/B2/B8 440 10 50% B1 and OFFICE/ 50% B8 use INDUSTRY Unit 5 B1/B2/B8 440 10 thus: – Unit 6 B1/B2/B8 450 10 B1-1 space per 6 VAN 35m2 SPACES x50%(worst AND 47 case) 6 = 36 SPACES

Industry – 1 van space + 1 space per 120m2 x 50% = 6 van spaces and 11 spaces

Total 80 105 & 9 van spaces The site scores exceptionally well in sustainability points score for a development other than residential in the county as it is within 400m of a school and a shop (1 x 2pts = 2pts), within 300m of a bus stop (3pts) and having a service frequency of every 5 minutes but only between 7am and 7 pm (3 pts). Over 7 sustainability points allows a 20% parking reduction for the scheme TOTAL PARKING REQUIRED 84 & 9 VAN SPACES Disable parking requirement 2% of total car park capacity 2

All parking bays will be laid out 4.8x2.6 in accordance with LDP2: Parking Standards.

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2. For waste and recycling CL Jones Ltd uses a skip for waste and a second skip for recyclable which is marked on the site plan adjacent to the aggregate and sand bays, as they will be collected and emptied by trucks. CL Jones are members of Recycle Wales and have been for many years; a current certificate can be supplied. CL Jones will also manage the waste collection of the additional units

3. The existing speed cushions will not be moved as we intend to use the 3 existing vehicular and 1 pedestrian entrances from Cader Avenue, along with 1 pedestrian and 1 vehicular within the application site.

4. In terms of storm water discharging onto the highway, the dilenage of the site is to remain unchanged as it is an existing developed site and we are only applying for a change in use and will not be extending or building on the site, but merely replacing a worn out roof and external façade to improve the visual aspect of the site for our benefit and that of the local residents and community. Furthermore by offering this service we should be able to reduce the number of car / van journeys within the locality helping to reduce congestion and pollution as all traffic must currently cross the from Abergele / Pensarn / Towyn / Kinmel Bay communities to source the service we will offer.

5. Planting will not be located in the VSL- existing planting on the site has just recently been managed along the Cader Avenue boundary fence line. For the purposes of clarity we have indicated the achievable VSL’s from the site from the existing access points and we do not intend to create any new access arrangements.

6. This is an existing building which borders other properties on all sides except the Cader Avenue boundary which has a pedestrian pavement and with a local primary school at the opposite end of Cader Avenue therefore the standards are already at their highest. The development will however seek to address the unauthorised parking at the site frontage; this long and linear stretch along Cader Avenue is regularly cluttered with vehicles, obscuring visibility and is unsightly. A section of land has been identified as being available, within the site boundary for the parking of these vehicles but this will be separate to a separate agreement with adjoining owners.

7. A suitable location has been identified on the plan for a sheltered staff/visitor cycle storage.

8. Alterations to the adopted highway are not proposed as we re-iterate that the intention is to use the 3 existing vehicular and 1 pedestrian entrances off Cader Avenue, along with 1 pedestrian and 1 vehicular within the site.

9. The client expects that all delivery traffic and movement of materials on and off the site to access the site from the A55 via J24 at Abergele taking the Rhuddlan Road to St Asaph Avenue, accessing the site through the westerly gate for materials being delivered for the construction phase and the easterly gate for the demolition muck shift work. All parking to be within the site perimeter fence. All plant / materials / equipment will be stored within the site throughout the development. All vehicles used will be of a standards size and weight for UK roads i.e. Articulated trucks & Trailer and 8 wheeler tipper trucks. The client is happy to undertake a construction management plan as part of a planning condition.

10. A non-illuminated bilingual signage board shall be erected at the South east corner of the site. As a welsh company with all directors being welsh speakers, CL Jones trade bilingually from their logo – to their delivery fleet livery, branding and documentation & from their current 5 sites in North Wales. Within their employment they we have a mix of Welsh and Non Welsh speakers. Non illuminated signage will be wall mounted above the individual units with potentially a totem at the entrance to the smaller units for identification.

11. We do not envisage any need to utilise the highway for storage except for any utility services works that may be required, and this would involve a street work contractor. Approval for any works outside the boundary is not applied for as part of this current scheme.

12. All access points are existing and no additional ones are intended, therefore stipulation of a bound surface within 10m of the edge of the carriageway is not applicable in this instance.

13. An additional tactile crossing point on the Cader Avenue junction has been added as requested by the Highways Department. We note that the tactile crossings on St. Asaph Avenue adequately serve the families

12 | 1 4 walking to school as this delivers the pedestrians to a safe point on the correct side of Cader Avenue and further on to the school.

It must be re-iterated that the building has an existing designated and lawful use and could trade accordingly with no parking changes.

5.3 Building Regulations – As noted previously, a pre-application consultation has been held with the Authority and their response was as follows: ·The building is currently of industrial / commercial use and its usage is not due to change. ·Building regulations should be consulted over the proposed addition of new units and the alterations made to the existing parts of the building. ·Consideration should be given to the maximum travel distances in the new units. Typically we would expect a maximum distance of 25m (normal hazard) to be achieved for industrial use and 18m in commercial use. If it is anticipated that a higher hazard usage is designated for the units then the travel distance is reduced to 12m. Consideration should be given to fire separation and fire spread between the new units. · We would expect to see details of the new drainage connections. ·Confirmation is required on the usage of the units and whether or not they are designated to be heated or cooled. These may be subject to a thermal upgrade in compliance with Approved Document L2b – Section 3 – Conversions.

A building regulation application will be submitted in due course and the general approach for each unit will be: New front entrances will be designed to distinguish the access and provide shelter. Doors will be controlled manually by push pad, card swipe, coded entry or remote control. Any new manual doors to have max opening force at leading edge of 20N & the ironmongery will be carefully chosen so an operative may open the door with closed fist and be visually apparent from the frame and glazed insert. The handle shall be of contrasting colour and not cold to touch. Entrances will allow operatives to access the units directly and car parking has been positioned to decrease the distance from the car parking area to the units and through careful lighting and signage the front door shall be apparent. Any glass entrance doors will have a manifestation at two levels 850-1000mm and 1400-1600 above floor contrasting visually with background seen through glass (inside & out) in all lighting conditions. The manifestation may take form of logo or sign 150mm high or decorative feature such as lines or bands 50mm high to differentiate whether door is open or closed. New internal doors to be 926mm wide, min 800mm clear, with lever handle of contrasting colour and vision panels shall be sited within 500 and 1500mm from the floor. All self-closing fire doors to be fitted with hold open devices or free swing devices and linked to fire detection system in order to close on activation of the fire alarm. Washroom Facilities Each new unit will provide a wheelchair accessible wc and wash hand basin taps & door opening furniture to wc to be capable of opening with closed fist (lever action handles). 5.4 Planning Policy – This scheme was developed during the initial application to consider the relevant planning policies within Conwy County Borough Council. 5.5 General – There are no specific or unusual access issues. 13 | 1 4

6. Development Issues 6.1 Flooding – See flood management plan 6.2 Mining - No known issues 6.3 Archaeology - No known issues 6.4 Ecology – No known issues. 6.5 Utility services – No known issues 6.6 Arboriculture Issues- No known issues

7. Planning Policy Framework The proposal is considered to be substantially compliant with the framework of national and local planning policies and guidance.

8. Further Particulars. We strongly believe this development will add a significant contribution to the area whilst also giving the required planning permission to enhance the site for the company. The building is well established in its locality, thus appropriate in its scale and relates well with its surroundings. The proposal to demolish a third of the footprint will also significantly reduce the massing, open up views and daylight.

The proposals do not impact significantly on the surrounding buildings in regards to privacy, sunlight and micro- climate as this is a mainly a residential area with an existing commercial use.

Overall the proposal for this site is a well-designed solution to the opportunities and challenges of the location, and will provide additional space to the applicant which can easily be adapted to meet the more specific needs of those with mobility, visual or aural impairments.

For these reasons we believe this scheme should be considered favourably. Signed: -……Kathryn Gratton………………………………….. Pp Parry Davies Architects RIBA Chartered Architects

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