CARDIFF BMX RACING CLUB
RIVERSIDE PARK, LLANRUMNEY
PRE-APPLICATION CONSULTATION REPORT
DEVELOPMENT COMPRISING OF A NATIONAL STANDARD BMX RACE-TRACK AND ASSOCIATED WORKS
MAY 2021
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CONTENTS
Chapter 1 Introduction
Chapter 2 Planning Policy Context
Chapter 3 Declaration
Chapter 4 Summary of Representations
Chapter 5 Summary and Conclusions
APPENDICES
Appendix A Notice under Schedule 1D
Appendix B Notice under Schedule 1C
Appendix C Neighbour Responses Table
Appendix D Specialist Consultee Responses
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1.0 INTRODUCTION
Background
1.1 This Pre-Application Consultation (PAC) Report has been prepared in support of a planning application, submitted on behalf of the applicant, Cardiff BMX Racing Club and the Welsh Cycling Union, in relation to the following development proposal on Land at Riverside Park, Llanrumney:
‘FULL PLANNING APPLICATION FOR A NATIONAL STANDARD BMX RACE-TRACK AND ASSOCIATED WORKS’.
Information Submitted in Support of the Application
1.2 The following information was consulted upon as part of the PAC process in support of the planning application:
Document Consultant Planning Application Forms Geraint John Planning Site Location Plan Cardiff Council Property Planning, Design and Access Statement Geraint John Planning Flood Consequence Assessment Hydrogeo Soil Resource Survey Tim O’Hare Associates Plans and Drawings: PM Consultants, EDP, Signify Lighting UK Ltd. • Cardiff BMX Track Layout; • Topography Plan; • Soft Landscaping Plan; • Flood Lighting Proposal.
Purpose and Structure of this Report
1.3 The Report documents the Pre-Application Consultation exercise undertaken by the applicant in light of the introduction on 1st August 2016 of the PAC process by the National Assembly of Wales, under Article 1 of the Town and Country Planning (Development Management) (Wales) (Amendment) Order 2016.
1.4 This report meets the specified content requirements, as outlined within Paragraph 44 of the Welsh Government’s Guidance on Pre-Application Consultation document http://gov.wales/docs/desh/publications/160129annex-1-pre-application-consultation-en.pdf. It also meets the requirements of an Amendment Order to the Town and Country Planning (Development Management Procedure) (Wales) Order 2012, which came into force at midnight on 19th May 2020.
1.5 This is documented within the following table:
Ref. Minimum Requirement Report Reference A A copy of the site notice (Notice 1D) for emergency period Appendix A B A declaration that the site notice was displayed in accordance with Section 3 the statutory requirements, i.e. in at least one place on or near the development site for no less than 28 days C A copy of the notice given to owners and occupiers of adjoining land Appendix A to be given during emergency period D Copies of notices provided to councillors, town and community Appendix B councils, and specialist consultees (1C Notice) E A summary of all issues raised in response to the statutory publicity Section 4 (i.e. site notice and letters to owners, occupiers) – the developer
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Ref. Minimum Requirement Report Reference must confirm whether the issues raised have been addressed and, if so, how they have been addressed F Copies of all responses received from specialist consultees with an Appendix C explanation of how each response has been addressed by the developer.
1.6 The Report is structured as follows:
• Section 2 provides planning policy context on the PAC process; • Section 3 provides a declaration that the site notice was displayed accordingly; • Section 4 provides a summary of the representations received; and • Section 5 sets out our conclusions.
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2.0 PLANNING POLICY CONTEXT
2.1 From 1st August 2016, the requirement to undertake PAC is applicable to all ‘major’ (as defined in article 2 of the Town and Country Planning (Development Management Procedure) (Wales) Order 2012) planning applications (full or outline) and applications for Development of National Significance (DNS).
2.2 In a letter sent from the Welsh Minister for Housing and Local Government to Local Authority Heads of Planning in Wales on 15th May 2020, some changes were outlined to the protocol for pre-application consultations for major development before submitting a planning application. This is outlined below, as stated in the letter:
‘developers must make all the information available on a website and send hard copies of the documents to any person who requests it. If hard copies are requested, an application must not be submitted before the period of 14 days beginning with the day on which the last document is sent’
2.3 Therefore, and as set out in Article 4 Part 1A of The Town and Country Planning DMPWO (Amendment) 2016, AND the Planning Applications (Temporary Modifications and Disapplication) (Wales) (Coronavirus) Order 2020 (The Amendment Order), the applicant must for a period of no less than 28 days before an application is submitted:
• Display a site notice in at least one place on or near the land to which the proposed application relates for a period of no less than 28 days before submitting an application for the proposed development; • Write to any owner or occupier of land adjoining the land to which the proposed application relates; • Make the draft planning application information available publicly; • Make all draft planning application documents available on a website and send hard copies of the documents to any person who requests it, and if hard copies are requested, an application must not be submitted before the period of 14 days beginning with the day on which the last document is sent; • Consult community and specialist consultees before applying for planning permission; • Consider if an Environmental Impact Assessment (EIA) is required for the project; • Submit a PAC report as part of the planning application.
2.4 This document confirms to Cardiff Council that the above requirements have been met within the pre-application consultations exercise for the proposed development.
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3.0 DECLARATION
3.1 This section provides, in line with article 2C(1)(a)(i) of the Town and Country Planning (Development Management Procedure) (Wales) (Amendment) Order 2016, a declaration that the applicant has publicised the proposed application by bilingual (English and Welsh) site display in various locations surrounding the site, as noted and identified in the map below:
• One at the southern access point to the park, in a prominent location for visitors and passers-by; • One in the central shrub area slightly south of the development to inform passers-by; • One at the request of the residents, erected at a later date, on the low knee rails of the Rugby Club car park.
Location of displayed site notices (identified by yellow circles)
3.2 The site notices were erected on 31st March 2021. Photographs of the displayed site notices are provided overleaf:
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Notice display locations
3.3 The site notices were on display from 31st March 2021 until 5th May 2021. On receipt of information from local residents regarding the notice in the shrub area’s removal and request for this to be replaced with a notice in the car park, this was actioned on 13th April 2021.
3.4 The site notice (Schedule 1D), included in Appendix A, advises that Cardiff BMX Racing Club is applying for ‘FULL PLANNING APPLICATION FOR A NATIONAL STANDARD BMX RACE-TRACK AND ASSOCIATED WORKS’ at Riverside Park, Llanrumney.
3.5 Copies of the proposed application including, but not limited to, the plans and other supporting documents, were available online at Full Planning Application For a National Standard BMX Race-Track and Associated Works. – Geraint John Planning. The information was made available on the website from 31st March 2021 to 5th May 2021.
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3.6 As per The Planning Applications (Temporary Modifications and Disapplication) (Wales) (Coronavirus) Order 2020 (“the Amendment Order”), plans and documents were made available on the website, and the site notice and Notice 1D document confirmed that hard copies were available to be sent upon request, in accordance with The Amendment Order.
3.7 Representations on the proposed development were directed to the agent, Geraint John Planning Ltd, either by email (to [email protected]) or by post (to Office 16, House 1, 2nd Floor, The Maltings, East Tyndall Street, Cardiff) within 28 days of the initial site notice, quoting the scheme name: Riverside Park, Hartland Road, Llanrumney, Cardiff.
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4.0 SUMMARY OF REPRESENTATIONS
4.1 In line with article 2F(2)(d) of the Town and Country Planning (Development Management Procedure) (Wales) (Amendment) Order 2016, Appendix A contains a copy of the Schedule 1D notice given to community consultees, whilst Appendix B contains a copy of the notice 1C given to specialist consultees.
Community / Adjoining Owner/ Occupier Notices
4.2 Bilingual Schedule 1D notices were posted to surrounding occupiers / owners of land adjoining the development on 31st March and were sent to the local ward Councillors – Councillor Bridgeman, Councillor Jones and Councillor Joyce via email on the same day. The extent of neighbourhood consultation, as illustrated in the image below, was carefully considered and discussed with planning officers at Cardiff Council to ensure the exercise was robust and productive.
Extent of Community Consultation
4.3 The letters informed them of the applicant’s intention to submit an application. The notices also identified where the associated plans and reports could be viewed and how to provide feedback concerning these. They also outlined where and how hard copy plans could be obtained, if required. Please also note that the below adjoining landowners were consulted via first-class post due to inability to physically post a notice.
Adjoining Land Owners
Cardiff University Sports Fields, Mendip Road, Llanrumney, By letter addressed to the owner and/or occupier CF3 4JN
Ysgol Gymraeg Bro Eirwg, CF3 4AD By letter addressed to the owner and/or occupier
Cylch Meithrin Pili Pala (Nursey at Rhymney Football Club), By letter addressed to the owner and/or occupier CF3 4JL
Rumney Rugby Football Club, CF3 4JL By letter addressed to the owner and/or occupier
Adjoining Landowners consulted via letter
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4.4 In total, 19 responses were received from local residents regarding the proposed development. The recurring themes of these responses are summarised and addressed in Section 4.7.
4.5 No comments were received from the Local Councillors. However, it must be noted that Councillor Jones has publicly declared his support for the scheme in a Wales Online Article published on 14th April 2021. In this piece, Councillor Jones notes ‘As a Llanrumney boy myself I know, now serving as a Llanrumney Labour councillor, that it is vital we offer constructive opportunities for Llanrumney’s children. The proposed facility will not only benefit them but the entirety of our capital city. The Cardiff BMX Racing club are an enthusiastic club that is going places. That they seek to call Llanrumney home fills us with excitement and pride.’
4.6 Appendix C provides a summary of all issues raised by the neighbours and, if required, a response to the points raised to demonstrate how these have been addressed.
4.7 In terms of recurring themes arising from the neighbour consultation, these can be summarised as follows:
• The area being (incorrectly) perceived as a greenbelt by residents thus leading to resistance to the proposals; • Perception of noise pollution; • Perception of flood risk; • Perception of littering and antisocial behaviour; • Concerns that scooters and motor vehicles will be allowed on the track; • Concerns relating to wildlife; • Clarification required with regards to the Pre-Application Consultation (PAC) exercise; • Concerns relating to parking and highways.
Land Designation
4.8 With regards to the comments raised by local neighbours, the planning application submission has been refined to provide clarification and address the issues raised. For clarity, it must be noted that land at Riverside Park Llanrumney does not fall under a green belt designation, as stated by the residents, and, whilst its uses are noted, its description of unallocated recreational land continues to be appropriate.
Perception of Noise Pollution
4.9 With regards to noise pollution, the applicant has addressed the issues raised by the Pollution Officer to provide further clarification and, in addition to this, it must be noted that the applicant is forthcoming with regards to engaging in discussions relating to hours of use and type of bikes allowed on the track to minimise disturbance to the local community and in the interest of the safety and amenity of the track users too.
Perception of Flood Risk
4.10 With regards to Flood Risk, please note that the submission is accompanied by a Flood Consequences Assessment (Document Reference: HYG861), as requested by the Local Planning Authority during pre-application discussions. In addition to this, it must be noted that the PAC response from Natural Resources Wales confirms the nature of the use as ‘less vulnerable development’ . Similarly, the lack of objection from Natural Resources Wales and their advice noting how the decision must be taken by the planning authority further
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demonstrates that there are no material concerns relating to flood risk which would impact the development.
Perception of Littering and Anti-social behaviour
4.11 The concerns relating to littering and anti-social behaviour are noted. However, as outlined in the Planning, Design and Access Statement which accompanies the submission, research shows that when recreational facilities of this kind are provided for young people, ‘a drop in vandalism and petty crime’ is experienced in the area in question. Similarly, a footfall of athletes into the area would provide natural surveillance and, in fact, decrease the likelihood of anti-social behaviour, whether actual or perceived. In this way, while concerns are noted, and the applicant is happy to engage in discussions and find solutions to alleviate these, it must be noted that as outlined by the research, these concerns are ‘normally groundless’. With regards to litter, the applicant is forthcoming with regards to litter-picking and is committed to keeping the site tidy.
Concerns relating to the type of bicycle allowed on the track
4.12 In the interest of health and safety, as well as to protect the amenity of existing users and avoid the risk of noise pollution, the applicant confirms that the track is not intended for the use of scooters or motorcycles. For the avoidance of doubt, and to ensure this notion is enforceable, this point can be tied to a planning condition linked to the planning permission at the appropriate stage.
Concerns relating to wildlife
4.13 The issues raised with regards to wildlife are noted. However, it must be noted that, following discussions with the Local Planning Authority, the development has been shifted 100m northwards to avoid disturbance on the SINC designation. Similarly, as the development proposes no built form, the planning authority has confirmed that no ecology issues are pertinent and has not requested for any ecological surveys to be submitted in support of the application.
4.14 In addition to this, the landscape strategy submitted as part of the proposals provides various measures including amenity grass and hedgerow planting, where possible, to enhance the proposals from an ecological and visual perspective.
Clarification requested with regards to the PAC exercise
4.15 With regards to the PAC exercise and the clarification requested, it must be noted that the applicant has gone above and beyond to engage in a productive and robust pre-application exercise.
4.16 The erected notice at the entrance to the park, in a prominent location has been on-site throughout the entire exercise (the duration of which has been extended in the interest of good practice). The notice on the tree in a central location between the site and the entrance was firmly pinned to the tree – despite the fact that this notice was removed, the applicant has been forthcoming in replacing this notice with one in the carpark, at the request of the local community despite a notice already being present thus satisfying the legislative requirements. This approach is testament to the applicant’s commitment to good practice and meaningful consultation.
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4.17 The comments relating to the perceived ambiguity of the plans are noted yet these have been produced by Cardiff Council and to the adequate scale, in line with the statutory guidance on the submission of planning application. Finally, appropriate clarification has been provided when requested throughout the entire exercise and, in the interest of transparency, local residents have been encouraged to write in with their views so these could be included and addressed through the medium of this report.
Concerns relating to parking and highways
4.18 With regards to highway concerns, it must be noted that the scale of the development (a 400m track) is not substantial in transport terms to warrant material concerns relating to highway safety. Similarly, it is considered that the parking provision at the site and surrounding roads can safely accommodate the limited number of trips which may be created through the medium of the development.
4.19 Finally, it must be noted that no objection has been received from Cardiff Council Highways and that, at pre-application stage, no technical information related to transport has been requested by the Local Planning Authority demonstrating that the proposals pose no concerns in highway terms.
Specialist Consultee Notices
4.20 Bilingual Schedule 1C notices were sent via email on 31st March 2021 to the following parties so as to inform them of the Applicant’s intention to submit an application and also where and how they could view the associated plans and reports and provide feedback concerning these:
• Cadw; • Cardiff Council Drainage; • Cardiff Council Ecology; • Cardiff Council Estates; • Cardiff Council Highways; • Cardiff Council Parks and Green Spaces; • Cardiff Council Planning; • Cardiff Council Pollution Control; • Coal Authority; • DCWW; • GGAT; and • NRW.
4.21 In line with article 2F(2)(f) of the Town and Country Planning (Development Management Procedure) (Wales) (Amendment) Order 2016, Appendix D contains a copy of all of the responses received from specialist consultees. Table 2 provides a summary of all issues raised by the specialist consultees and a response to how they have been addressed. It must also be noted that, in the interest of good practice, reminders were sent to statutory consultees halfway through the process to ensure the exercise was robustness of the consultation exercise.
Table 2 – Summary of representations received from specialist consultees
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Date Consultee Representation Response 06/04/2021 The Thank you for your notification of 31 March No response required. Coal Authority 2021 seeking the pre-application views of the Coal Authority on the above.
I have checked the site location plan against the information held by the Coal Authority and can confirm that the proposed development site is located outside of the defined coalfield.
Accordingly, there is no requirement for the applicant to consider coal mining legacy as part of any formal planning application for this site, or for the Local Planning Authority to consult the Coal Authority.
Please do not hesitate to contact me if you would like to discuss this matter further.
12/04/2021 Cadw The following comments are based on Comments noted. information made available to us as part of the pre-application consultation and we will review our comments when we are consulted on the final planning application. Our assessment of the pre-application is given below.
Our records show that there are no scheduled monuments or registered historic parks and gardens that would be affected by the proposed development.
We therefore have no comments to make on the proposed development.
The national policy and Cadw’s role in the planning process is set out in Annex A.
Assessment
This planning application is for a National Standard BMX Race-track at Riverside Park, Hartland Road, Llanrumney, Cardiff, CF3 4JL.
Located within a 3km buffer of the application area are:
Scheduled Monuments
GM216 Caer Castell Camp
GM474 Relict Seawall on Rumney Great Wharf
Registered Parks and Gardens
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Date Consultee Representation Response PGW (Gm) 19(CDF) Cathays Cemetery (grade II*)
PGW (Gm) 24(CDF) Roath Park (grade I)
PGW (Gm) 29(CDF) Waterloo Gardens and Roath Mill Gardens (grade II)
Intervening topography, buildings and vegetation mean it is unlikely that the proposal will be inter-visible with the scheduled monuments or the registered park and gardens. Therefore it is unlikely that there will be any effect on the settings of the scheduled monuments or the registered park and gardens.
Finally, there may also be undesignated historic assets that could be affected by the proposed development and, if you have not already done so, we would advise that you consult the Historic Environment Record held by the Glamorgan-Gwent Archaeological Trust www.ggat.org.uk
16/04/2021 DCWW I refer to your pre-planning enquiry received No response required, and relating to the above site, seeking our views statutory advice is noted. on the capacity of our network of assets and infrastructure to accommodate your proposed development. Having reviewed the details submitted I can provide the following comments which should be taken into account within any future planning application for the development.
I refer to the Schedule 1C - Article 2D notice received and your formal request for a pre-application consultation response before applying for planning permission from Dwr Cymru Welsh Water as a ‘Specialist Consultee’ as defined by Paragraph (y) of Schedule 4 of the Town & Country Planning (Development Management Procedure) (Wales) (Amendment) Order 2016. It is acknowledged that the consultation request relates to a major development site and thus seeks a substantive response within 28 days from the date of the notice, as per the requirements of Article 2E. This request includes our views on the capacity of our network of assets and infrastructure to accommodate your proposed development. Having reviewed the details submitted I would advise there is no objection to the proposed development and offer the following standing advice
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Date Consultee Representation Response which should be taken into account within any future planning application for the development.
SEWERAGE It appears the application does not propose to connect to the public sewer, and therefore Dwr Cymru Welsh Water has no further comments. However, should circumstances change and a connection to the public sewerage system/public sewage treatment works is preferred we must be re-consulted on this application. The applicant is also advised that some public sewers and lateral drains may not be recorded on our maps of public sewers because they were originally privately owned and were transferred into public ownership by nature of the Water Industry (Schemes for Adoption of Private Sewers) Regulations 2011. The presence of such assets may affect the proposal. In order to assist us in dealing with the proposal the applicant may contact Dwr Cymru Welsh Water on 0800 085 3968 to establish the location and status of the apparatus. Under the Water Industry Act 1991 Dwr Cymru Welsh Water has rights of access to its apparatus at all times.
SEWAGE TREATMENT
No problems are envisaged with the Waste Water Treatment Works for the treatment of domestic discharges from this site.
WATER SUPPLY
A water supply can be made available to service this proposed development.
I trust the above information is helpful and will assist you in forming water and drainage strategies that should accompany any future planning application. I also attach copies of our water and sewer extract plans for the area, and a copy of our Planning Guidance Note which provides further information on our approach to the planning process, making connections to our systems and ensuring any existing public assets or infrastructure located within new development sites are protected.
Please note that our response is based on the information provided in your enquiry
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Date Consultee Representation Response and should the information change we reserve the right to make a new representation. Should you have any queries or wish to discuss any aspect of our response please do not hesitate to contact our dedicated team of planning officers, either on 0800 917 2652 or via email at [email protected]. Please quote our reference number in all communications and correspondence.
23/04/2021 GGAT Many thanks for your pre-planning enquiry. No response required. We have consulted the regional Historic Environment Record (HER) and note there are no known archaeological sites within the proposed development area.
Archaeological material is known from the wider area, including a Bronze Age palstave, a mill race, d-shaped cropmark and the projected line of a Roman road. A review of historic Ordnance Survey mapping shows no archaeologically significant features or structures in the application area.
The current proposal is for a BMX track and associated works. The requisite ground works are relatively limited in scale, with the majority of the track being built-up. As a result it is unlikely that significant archaeological material will be encountered during the course of the works.
Therefore, should a similar application to the one you have outlined be submitted, we would be unlikely to recommend any pre-determination works, or that any archaeological conditions are attached to any consent.
26/04/2021 NRW Based on the information provided, we No response required, and would have no objection to the proposed statutory advice is noted. development and provide the following advice. Flood Risk The planning application proposes the retention of less vulnerable development. Our Flood Risk Map confirms the application site to be entirely within Zone C1 of the Development Advice Map (DAM) as contained in TAN15. Our records show the site previously flooded during the December 1979 flood event. Section 6 of TAN15 requires the Local Planning Authority (LPA) to determine whether the development at this location is justified.
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Date Consultee Representation Response Therefore, we would refer the LPA to the tests set out in Section 6.2 of TAN15. If the LPA consider the proposal meets the tests set out in criteria (i) to (iii), then the final test (iv) is for the Applicant to demonstrate, through the submission of an FCA, that the potential consequences of flooding can be managed to an acceptable level.
We have reviewed the FCA prepared by Hydrogeo, reference HYG861 R 210326 CB Cardiff BMX Track_FCA, version 1, dated 26th March 2021. Whilst our advice below shows the FCA has not demonstrated that the risks and consequences of flooding can be managed to an acceptable level, recognising the nature of the application (the retention of less vulnerable development) in this instance we would have no objection to the application as submitted. Section 4.12 of the FCA identifies there will be no major alternations to the existing site ground levels, therefore flood conveyance and storage will not be affected. The FCA states the existing site ground levels range between 6.71–7.22m AOD. Based on these site ground levels, the FCA shows:
• During a 1% (1 in 100 year) plus 20% for climate change annual probability fluvial flood event, the development is predicted to flood to a depth between 1000 - 1500mm.
• During a 0.1% (1 in 1000 year) annual probability fluvial flood event, the development is predicted to flood to maximum depths between 1000 – 1740mm.
• During a 0.5% (1 in 200 year) plus climate change (2115) annual probability tidal flood event, the development is predicted to flood a depth of 2600mm.
• During a 0.5% (1 in 1000 year) annual probability tidal flood event for the current day, the development is predicted to flood to a depth of 2500mm. The FCA has proposed the management of flood risk by recommending: the preparation of a Flood Plan; the appointment of a Flood Warden; the site owner/operator sign up to the flood warning service; and, an access/egress route. We also recommend
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Date Consultee Representation Response signage is erected to inform users of the potential flood risk to this area.
The above shows the proposed development does not meet the requirements of A1.14 of TAN15 and exceeds the tolerable limits of A1.15 of TAN15. Furthermore, the FCA has not used the appropriate climate change allowances (CCAs) for this type of development. However, given the nature of the proposed development and that flood conveyance and storage will not be affected, in this instance we would have no objection to the application as submitted. We would advise the LPA that no information has been provided on the rate of rise and speed of inundation as per A1.15 of TAN15 and the Welsh Government’s CPO Letter (Planning Policy on Flood Risk and Insurance Industry Changes) on 9 January 2014. If the LPA are minded to request this information from the Applicant, we would be happy to provide further advice.
Cardiff Council Awaiting Response. Drainage
Cardiff Council Awaiting Response. Ecology
Cardiff Council Awaiting Response. Estates
Cardiff Council Awaiting Response. Highways.
Cardiff Council Awaiting Response. Parks and Green Spaces.
Cardiff Council Awaiting Response. Planning.
23.04.2021 Cardiff Council - Proposed operating hours, any No response required however Pollution seasonal changes, any weekend all the points raised are noted Control variations. There is obviously and have been addressed in the intention for flood lighting, but is submission. this for the winter periods with earlier sunsets, is it envisaged Please note, the small scale use will extend into most nature of the proposals has evenings irrespective of the been clarified to the Pollution season. Knowing the operating Control officer and the applicant hours are “day time into earlier does not foresee large scale evening, say 1900 hrs – may events taking place or the alleviate noise concerns as erection of commercial stands background levels are still likely taking place. high with prevailing noise from
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Date Consultee Representation Response the A48. After this time you expect background noise levels to drop, and so the expectation for residential amenity that no site specific noise remains dominant;
- In regards to the lighting can it be made clear how this will not impact residential amenity, as this teams other core consideration;
- In terms of safety, what is the maximum number of riders envisaged to be using the park at one time. This will aid with any noise issues if numbers are naturally low for safety reasons. Similar to this, how many different attendees do you expect to see over the duration of a busy day. Assuming 9-5 opening, is it may 6 “races” around the track per hour. The more experienced riders I’m sure will finish very quickly as is the intention.
- I assume there will be some of sort of public address systems used for safety announcements, inviting riders to take position etc? what volumes with these be at, is can it be limited, will it be audible at residential amenity?
- I’m not sure how loud the starting position “gate” is when its dropped, but on my research they have to use hydraulic systems according to the UCI Track Building Guidelines (again, I’m not expert but have had a read through). Even with the distance, that short “spike” in noise with a low background multiple times has potential for issues;
- Looking at other big BMX tracks (Birmingham, Cornwall, Rhyl they do attract a large gathering, in some instances national events and festivals. With that come associated noise from crowds gathered, cheering etc. Something like this may be controlled by way of conditioning to any approval (pending advice
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Date Consultee Representation Response from the LPA) such as the need to provide a specific noise management plan for larger events being hosted – that comes with risks though and may be harder to mitigate, leading to complaint and enforcement form this team which I wish to limit the risk off.
- A condition that seemed to crop up other places read on the lines “not be used by any motorised cycles at any time” – in any permission granted we would seek something similar as the noise from such vehicles is far greater and travels extremely well. I’m sure the aim to mitigate intruders anyway has already been considered, by way of fencing etc – but also professionals may seek to book on, (if the same standard of track is applicable for such use?)
- Stepping aside from residential amenity, who have a duty to protect the school from unharmful noise (BB93 is the document for school building acoustics) so some reference to how this will be managed. It is not uncommon for schools to complain to this team for matters outside of our control causing impact, so it will be better to manage this as planning stage.
- Is there going to be any dust produced from the use, where the area is not cemented. How is this managed?
4.22 In addition to the minimum statutory requirements, officers at the Local Planning Authority were sent a location plan and description of development prior to the start of the pre-application period and asked to confirm the appropriate consultees and provide guidance as to whether the proposed extent of neighbour consultation was acceptable. This was done to ensure that the PAC exercise was as extensive as possible and to mimic any consultation that the Local Planning Authority may carry out following receipt of this report and the associated planning application. On receipt of an email from David Braund dated 11th March 2021 confirming that the consultation list appeared to generally accord with PAC requirements and communicating the relevant departments to contact within the Local Authority, we utilised the planning officer’s advice to inform our exercise and ensure its scope was as robust as possible.
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Interim Summary
4.23 As a result of the Pre-Application Consultation dialogue with members of the local community, local councillors and statutory consultees, the proposals are considered to respond to comments and advice provided by statutory consultees who were consulted as part of this pre- application consultation exercise. Indeed, no concerns or objections have been raised by any community or specialist consulted party at this stage, and, to provide further clarity on the issues raised by neighbours, the submission has been amended to include commentary on the comments addressed in section 4.7 of this report. Therefore, in light of the above, it is reasonably considered that the application can proceed to be submitted without major amendment, or further information.
4.24 The below sets out the summary and conclusions of this PAC Report and the exercise.
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5.0 SUMMARY AND CONCLUSIONS
Purpose of this Report
5.1 This PAC report provides a copy of the relevant notices, a summary of responses from consultees including neighbours, community consultees and specialist consultees and how the PAC process (i.e the receipt of consultee input) has informed amendments or the inclusion of additional information to the planning application.
5.2 The pre-application consultation undertaken by the applicant has met and exceeded the requirements of the Town and Country Planning (Development Management Procedure) (Wales) (Amendment) Order 2016 AND The Planning Applications (Temporary Modifications and Disapplication) (Wales) (Coronavirus) Order 2020 (“the Amendment Order”).
5.3 The local community, local members and statutory consultees have had the opportunity to be involved in the pre-application process and through this consultation process we have helped the community to understand the benefits and impacts of the proposed development. This is further emphasised by the fact that halfway through the process, reminders were sent to statutory and community consultees to remind them of the PAC and their opportunity to issue commentary.
5.4 The applicant’s forthcoming approach and commitment to good practice is further emphasised by the decision to extend the consultation period to the 5th May to allow late representations to still be included.
5.5 This report sets out the feedback received and how the comments have been considered and responded to. Where appropriate, we have sought to respond directly to comments raised or directed people to the relevant documentation provided as part of the consultation. This process has helped us understand and address any relevant concerns and has resulted in amendments to the final submission. This meaningful consultation has, we believe, improved the quality of our proposal.
5.6 All comments have been duly noted.
5.7 No objections to the proposals have been received from either community or statutory consultees.
5.8 In conclusion, this report documents the way in which the Applicant has addressed and met the PAC requirements outlined within the Town and Country Planning (Development Management Procedure) (Wales) (Amendment) Order 2016 and The Planning Applications (Temporary Modifications and Disapplication) (Wales) (Coronavirus) Order 2020 (“the Amendment Order”).
5.9 It is accordingly requested that the Local Planning Authority consider the content of this report in the processing, validation and assessment of the planning application.
Riverside Park, Llanrumney May 2021 Proposed Development PAC Report Page 23 of 23
APPENDIX A – NOTICE UNDER SCHEDULE 1D
SCHEDULE 1 Article 4 (4)
Pre-application notices
SCHEDULE 1D Article 2G
PUBLICITY AND CONSULTATION BEFORE APPLYING FOR PLANNING PERMISSION
Town and Country Planning (Development Management Procedure) (Wales) Order 2012
PUBLICITY AND CONSULTATION BEFORE APPLYING FOR PLANNING PERMISSION NOTICE UNDER ARTICLES 2C AND 2D AS MODIFIED BY ARTICLE 2G
Purpose of this notice: this notice provides the opportunity to comment directly to the developer on a proposed development prior to the submission of a planning application to the local planning authority (LPA). Any subsequent planning application will be publicised by the relevant LPA; any comments provided in response to this notice will not prejudice your ability to make representations to the LPA on any related planning application. You should note that any comments submitted may be placed on the public file.
Proposed development at Riverside Park, Hartland Road, Llanrumney, Cardiff, CF3 4JL.
I give notice that Cardiff BMX Racing Club is intending to apply for Planning Permission for:
“Full Planning Application for a National Standard BMX Race-track and associated works.”
You may inspect copies of:
- The proposed application - The plans; and - Other supporting documents
Online at http://www.geraintjohnplanning.co.uk/current-consultations/ OR, in accordance with the Welsh Government’s Amendment Order to Article 2C (1) on 17th December 2020, hard copies can be sent via post on request.
If you are unable to access the documents electronically you may request copies of this information by emailing [email protected] or by telephoning the applicant on 02920 105360.
Anyone who wishes to make representations about this proposed development must write to the applicant/agent at [email protected] or Geraint John Planning Ltd, Office 16 (House 1, 2nd Floor), The Maltings, East Tyndall Street, Cardiff, CF24 5EA. All correspondence should quote the scheme name: Riverside Park, Hartland Road, Llanrumney, Cardiff.
By: 28th April 2021
Signed:
Date: 31/03/2021
ATODLEN 1 Erthygl 4 (4)
Hysbysiadau cyn-ymgeisio
ATODLEN 1D Erthygl 2G
CYHOEDDUSRWYDD AC YMGYNGHORI CYN GWNEUD CAIS AM GANIATÂD CYNLLUNIO
Gorchymyn Cynllunio Gwlad a Thref (Gweithdrefn Rheoli Datblygu) (Cymru) 2012
CYHOEDDUSRWYDD AC YMGYNGHORI CYN GWNEUD CAIS AM GANIATÂD CYNLLUNIO HYSBYSIAD O DAN ERTHYGLAU 2C A 2D FEL EI ADDASU GAN ERTHYGL 2G
Diben yr hysbysiad hwn: mae’r hysbysiad hwn yn rhoi cyfle i wneud sylwadau yn uniongyrchol i’r datblygwr ynglŷn â datblygiad arfaethedig cyn cyflwyno cais am ganiatâd cynllunio i’r awdurdod cynllunio lleol (“ACLl”). Bydd unrhyw gais cynllunio dilynol yn cael ei hysbysebu gan yr ACLl perthnasol; ni fydd unrhyw sylwadau a ddarperir gennych wrth ymateb i’r hysbysiad hwn yn lleihau dim ar eich gallu I gyflwyno sylwadau i’r ACLl ar unrhyw gais cynllunio cysylltiedig. Dylech nodi y gellir gosod unrhyw sylwadau a gyflwynir gennych yn y ffeil gyhoeddus.
Datblygiad Arfaethedig yn Parc Glan yr Afon, Ffordd Hartland, Llanrumney, Caerdydd, CF3 4JL.
Rwyf yn hysbysu bod Cardiff BMX Racing Club yn bwriadu gwneud cais am ganiatâd cynllunio ar gyfer:
"Cais Cynllunio Llawn ar gyfer Trac Rasio BMX Safon Genedlaethol a gwaith cysylltiedig."
Gallwch archwilio copïau o’r canlynol:
- y cais arfaethedig; - y cynlluniau; a - dogfennau ategol eraill
Ar-lein http://www.geraintjohnplanning.co.uk/current-consultations/ NEU, yn unol â Gorchymyn Diwygio Llywodraeth Cymru i Erthygl 2C (1) ar 17eg o Ragfyr 2020, gellir anfon copïau caled trwy'r post ar gais.
Dylid gwneud cais am gopïau caled trwy gysylltu â [email protected] neu ffonio 02920 105360.
Mae’n rhaid i unrhyw un sy’n dymuno gwneud sylwadau ynglŷn â’r datblygiad arfaethedig hwn ysgrifennu at y ceisydd/yr asiant [email protected] neu Geraint John Planning Ltd, Office 16 (House 1, 2nd Floor), The Maltings, East Tyndall Street, Cardiff, CF24 5EA. Dylai pob gohebiaeth defynddio enw'r cynllun: Parc Glan yr Afon, Fford Hartland, Llanrumney, Caerdydd.
Erbyn: 28eg Ebrill 2021
Llofnod:
Dyddiad: 31/03/2021
APPENDIX B – NOTICE UNDER SCHEDULE 1C
SCHEDULE 1C Article 2D
CONSULTATION BEFORE APPLYING FOR PLANNING PERMISSION
Town and Country Planning (Development Management Procedure) (Wales) Order 2012
CONSULTATION BEFORE APPLYING FOR PLANNING PERMISSION
NOTICE UNDER ARTICLE 2D
Purpose of this notice: this notice comprises a formal request for a pre-application consultation response under article 2D of the Town and Country Planning (Development Management Procedure) (Wales) Order 2012.
Proposed development at Riverside Park, Hartland Road, Llanrumney, Cardiff, CF3 4JL.
I give notice that Cardiff BMX Racing Club are intending to apply for Planning Permission for: “Full Planning Application for a National Standard BMX Race-track and associated works.”
A copy of the proposed application; plans; and other supporting documents are attached/can be viewed online at www.geraintjohnplanning.co.uk/current-consultations/
In accordance with the requirements of article 2E of the Town and Country Planning (Development Management Procedure) (Wales) Order 2012, a consultation response must be sent to [email protected] by 28th April 2021. All correspondence should quote the scheme name: Riverside Park, Hartland Road, Llanrumney, Cardiff.
Signed:
Date: 31/03/2021
ATODLEN 1C Erthygl 2D
YMGYNGHORI CYN GWNEUD CAIS AM GANIATÂD CYNLLUNIO
Gorchymyn Cynllunio Gwlad a Thref (Gweithdrefn Rheoli Datblygu) (Cymru) 2012
YMGYNGHORI CYN GWNEUD CAIS AM GANIATÂD CYNLLUNIO
HYSBYSIAD O DAN ERTHYGL 2D
Diben yr hysbysiad hwn: mae’r hysbysiad hwn yn ddeisyfiad ffurfiol am ymateb i ymgynghoriad cynymgeisio o dan erthygl 2D o Orchymyn Cynllunio Gwlad a Thref (Gweithdrefn Rheoli Datblygu) (Cymru) 2012.
Datblygiad arfaethedig yn Parc Glan yr Afon, Ffordd Hartland, Llanrumney, Caerdydd, CF3 4JL.
Rwyf yn hysbysu bod Cardiff BMX Racing Club yn bwriadu gwneud cais am ganiatâd cynllunio ar gyfer:
"Cais Cynllunio Llawn ar gyfer Trac Rasio BMX Safon Genedlaethol a gwaith cysylltiedig."
Mae copi o’r cais arfaethedig; cynlluniau; a dogfennau ategol eraill wedi eu hatodi/ar gael i’w harchwilio ar lein yn http://www.geraintjohnplanning.co.uk/current-consultations/
Yn unol â gofynion erthygl 2E o Orchymyn Cynllunio Gwlad a Thref (Gweithdrefn Rheoli Datblygu) (Cymru) 2012, rhaid anfon ymateb i’r ymgynghoriad at [email protected] yn erbyn y 28eg Ebrill 2021. Dylai pob gohebiaeth defynddio’r enw'r cynllun: Parc Glan yr Afon, Ffordd Hartland, Llanrumney, Caerdydd.
Llofnod:
Dyddiad: 31/03/2021
APPENDIX C – NEIGHBOUR RESPONSE TABLE
Riverside Park, Llanrumney Pre-Application Consultation (PAC) Responses Table Page 1 of 40
Neighbour Comments Date Name Comments 10/04/2021 Public OBJECTS Comment 01 To clarify the compliance of the exercise, the following response was issued. I'd like to object the the current planning application for National Standard BMX race-track and associated works at riverside park Hartland road Llanrumney, CF3 4JL for many reasons: ‘Thank you for your email.
- the area is continually used by people for recreational activities The pre-application notices have been erected by us in - the area is used by a large amount of people walking their prominent locations on and adjacent to the site, in line with dogs on a daily basis the statutory guidance.
- the area is a non-broken green belt that is enjoyed by many We have been informed one of the notices has been removed - the majority of the time there is peace and tranquillity in and, in light of this, we will replace it as soon as possible. this area and I believe this should be protected not broken Notwithstanding this, a site notice is currently still up – this is by a site continually used compliant with the legislation.
- the car park is continually used by people who need access to the field. Some of these people require close With regards to the number of properties who have received parking due to mobility issues notice of the Pre-Application Consultation, I can confirm no -I live in Tiverton Drive and I am concerned about the level properties have been omitted. The legislation states that all of noise associated with the development and the facility adjoining neighbours and landowners to the development site (should this go ahead) must be notified – we have complied with this. For further ease of mind, please note that our extent of neighbourhood - I am concerned that the application sign has not been consultation has been double checked with planning officers at visible to those who use this area. Today I have walked the Cardiff Council.
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area and have not seen any signage to this proposal -I understand that people from Patchway Crescent have Your objections are noted - if you have any other questions at not received any notification of this proposal; I am unsure this point, please do not hesitate to let us know. whether other areas have been omitted. -As the sound travels far with activities in this area I would have understood a larger area of proposal awareness should Similarly, if you haven’t already, you can view the application plans and reports on the below link: be considered -This would remove an area of land that I personally utilize at a minimum twice weekly; many others will be adversely affected also. Full Planning Application For a National Standard BMX Race- Track and Associated Works. – Geraint John Planning’
On request of a contact from Cardiff Council to raise her concerns to, we informed the local resident that a planning application had not yet been submitted and thus not allocated to a case officer. Notwithstanding this, the local resident was assured that the objection had been received and of our responsibility under the legislation to include her submission in our PAC report.
The issues raised are addressed in the PAC report.
10/04/2021 Public why is there no planning notice on the carpark ? To clarify the compliance of the exercise, the following Comment 02 response was issued Firstly there was a planning notice in the "long grass " nature area , this is now removed, now there is a small notice on entrance to park, far away from areas & on a
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place that you can not park to read. ‘Thank you for your email.
there needs to be planning notice"S ". on the carpark fence The pre-application notices have been erected by us in boundary , so users of this area are actually aware, hiding prominent locations on and adjacent to the site, in line with these plans away where no one can read are corrupt . the statutory guidance.
Also PLEASE state on notices if the track will go in the wild Thank you for informing us that one of the notices has been area or football area. this is very important on peoples removed – we will replace it as soon as possible. opinions.and isn’t clear on the map. please indicate the wild Notwithstanding this, a site notice is currently still up – this is grass on map compliant with the legislation.
please email me response urgently With regards to the extent of the application site, please note that you can view the application plans and reports on the below link:
Full Planning Application For a National Standard BMX Race- Track and Associated Works. – Geraint John Planning
If you have any further questions at this point, please do not hesitate to get in touch.’
Riverside Park, Llanrumney Pre-Application Consultation (PAC) Responses Table Page 4 of 40
01/04/2021 Public OBJECTS The objection is noted and no response is required. Comment 03
I would like it to be known that I object to the planning of a The issues raised are addressed in the PAC report. BMX park in the Riverside Park , Llanrumney.
This is a beautiful woodland area full of wildlife and used by many dog walkers,
We already get enough quad bikes driving through and this will only add to the problem
03/04/2021 Public OBJECTS The objection is noted and no response is required. Comment 04
Hello, The issues raised are addressed in the PAC report.
I object to the planning proposals. There are many broken field sites across Cardiff where this would be much more appropriate to develop. Instead this is a greenfield site used by walkers and dog walkers. The Rugby club has restricted access to dog walkers, and therefore this is the last location in the area to safely allow dogs to be safely walked.
In addition this is a site teeming of natural wildlife the eco
Riverside Park, Llanrumney Pre-Application Consultation (PAC) Responses Table Page 5 of 40
system of which would be destroyed by the bulldozers this would invite into the area. This location does not need more concrete.
Best Regards
M
02/04/2021 Public My only concern as a local resident is access by cars/vans The response, both in terms of concerns and support, is noted. Comment 05 Your proposal refers to easy access by walking, cycling and No response is required. public transport. But we know most people will use vehicles. You don’t use your BMX bike to get to a location. There is only one road in and out. With the Cardiff City development The issues raised are addressed in the PAC report. the increase in volume of traffic will have consequences. You only have to see the congestion and subsequent frustrations on school pick up rimes and when there are matches on the playing fields. Cars park anywhere and everywhere. On grass verges along access road and outside residents home preventing access. I have personally experienced this to the point where I had to develop my drive to accommodate out parking needs.
When parking along access road on grass verge there is nowhere to walk safely. I use this part everyday to walk my dog and we have a few incidents where we have nowhere to go with cars parked car arriving and leaving at the same time. You have to see it to believe it.
Your proposals do not address this sufficiently
No issue with the development I love sport. One other thing
Riverside Park, Llanrumney Pre-Application Consultation (PAC) Responses Table Page 6 of 40
you will need to improve security as the scrambler bikes and 4 wheelers that currently run fly pass you will find a way.
16/04/2021 Public Dear Sir, The notice by the access to the car park has been present for Comment 06 the entire Pre-Application Consultation Process. It has come to my attention that a proposal for the above has been put forward. There are several points I would like to submit in opposition to the proposal. The notice which has been removed has been replaced with one in the car park at the residents’ request.
1. Notification of the proposal has been totally inadequate consisting of 1x A4 laminated sheet attached to the 2 foot The response is noted and no response is required. fence at the car park adjacent to the football changing rooms and held by a piece of fragile string .( The said notice had disappeared this morning). The issues raised are addressed in the PAC report. 2. You seem to be under the misapprehension that flooding of this area has not occurred for some time. I have dated photographic evidence that proves substantial flooding took place in February 2020 to a depth of several feet when the River Rhymney burst its banks. The river dyke banks paths have still not been repaired . The photographs and videos show the depth of water close to the height of the rugby post cross bar.
3 This year February 2021 a significant area where the proposed Track is to be built was again for a period of a month flooded beyond the current soccer pitch in places over a wellington depth.
4.The soccer club until the Covid 19 outbreak was regularly used for practices and games and when the Covid outbreak
Riverside Park, Llanrumney Pre-Application Consultation (PAC) Responses Table Page 7 of 40
has reduced effect and W.A.G. give permission I am sure activity will once more commence. These members have worked hard to create a suitable area for the players and supporters and this facility should not be stolen away from the club and supporters.
5. Your proposal falsely claims the area is underutilised and the supporting photographs for this claim is derisory having been taken approx. 7 years ago according to one of the many dog walkers that use the car park and area to exercise their dogs. If anything during the Covid period the area is used even more intensely by local people as an area to walk their dogs walk themselves, relax and picnic when weather is kind, run, jog, train, practice golf, fly drones and aircraft practice surf casting. When Covid circumstances ease many junior football practices will once again be able to use the area.
6. This area and its environs to the river and its wetlands is also a wonderful habitat for wildlife. Many bird species use the area for feeding and procreation. The effects of pouring concrete will further jeopardise the attempts of Cardiff council to establish wildlife corridors in the area and would oppose environmental biodiversity.
7 In conclusion I feel disgusted at this attempt to take away a much valued and utilised green area from the eastern district of the city which has already been deprived of much green space. The development proposals for the old LLanrumney High School should be enough without trying to impose more erosion of the green belt. This area is our Llandaff fields for the eastern part of the city. I wonder would this proposal have even been tabled had it been
Riverside Park, Llanrumney Pre-Application Consultation (PAC) Responses Table Page 8 of 40
directed at the Llandaff fields area?
21/04/2021 Public OBJECTS The objection is noted – no response is required. Comment 07
Dear Sir/Madam The issues raised are addressed in the PAC report.
I am writing to you to strongly object and voice my opinion to the planning permission proposals with Geraint John Planning for a BMX track at riverside park, Rumney, Cardiff.
This area is a very well utilised by walkers, runners, dog walkers, cyclists and more. It is used daily by myself and many others who are local to the area by all of the above whether it be for family group outings, walkers, runners, cyclists, dog walkers etc etc for physical and mental well- being, and even more so since lockdowns had been introduced. The pitch area is used by many users including golf, model plane and drone flying, dog training, walking area. The pitch is rarely used for rugby or football team games as it is very prone to water logging and would most likely the surface would be destroyed if attempted.
Riverside Park, Llanrumney Pre-Application Consultation (PAC) Responses Table Page 9 of 40
The area is also prone to flooding. It floods more regular than the planning suggests, especially in autumn to spring rains. I will attach photos and videos of the flood from Feb 2020 when the river did indeed burst its banks and the whole pitch was flooded from river to rugby club and people actually had canoes rowing across it. it was very deep. It is worth bearing in mind the Rhymney river at this section is close to the mouth of the river with the severn estuary, which has among the strongest tidal currents in the world. This section of river is tidal and the water levels vary usually twice a day depending on the tide. When you get high tides coinciding with heavy rains, this is when the river usually bursts its banks and I have witnessed this on many occasions over the last 11 years since living in the area.
The access lane and car park is less than adequate for such a proposal. The car park is regularly full with people out walking or utilising the pitch for hobbies or sport. When the local school (next to rugby club) day is starting or finishing each day the car park and lane is rammed and very busy. There is also a play group at the rugby club. I would be concerned about having to get an ambulance or fire truck down there if it was busy. The proposal planning has used an old photo of the car park which is not accurate of today's usage and a part of the current car park is included in the area for the new development, so it would mean less parking space overall.
Riverside Park, Llanrumney Pre-Application Consultation (PAC) Responses Table Page 10 of 40
There is already a significant amount of drug use and paraphernalia dumped in the area, particularly laughing gas cannisters and balloons, broken glass and other litter and feel such a proposal would only increase the amount of litter there.
There will be a huge impact on wildlife there, I have seen myself on lots of occasions the different type of wildlife with inhabit the area. There are jays, buzzards, herons, owls, many other native birds and foxes. The subsequent building works and noise from race nights as well as flood lights would seriously disturb their habitat.
By taking a large green area away from this part of the city would leave local residents at a huge disadvantage of being able to go to an open space for exercise. I cannot think of many open spaces in the east of Cardiff such as this one. Would such a proposal be considered for Llandaff fields? There would be massive uproar and it being in a middle to upper class area. Why is it considered acceptable to make such a proposal in a working class/low-income area? People are already disadvantaged in this part of Cardiff and this would be another disadvantage to the local residents of this open area used recreationally by many people on a daily basis. Conservation of public open spaces is important and this area is not under used or wasted land. The proposal is not being built to benefit local residents. It is a private
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enterprise and not a council run build for locals.
I have copied in Stephen Doughty MP for the area and Vaughan Gething MS for the area.
22/04/2021 Public OBJECTS The objection is noted – no response is required. Comment 08
I wish to object to the planned BMX Tracking at Rumney The issues raised are addressed in the PAC report. Rugby club fields Cardiff.
I believe this would affect the natural habitat in the area also preventing local people using this wonderful green space.
26/04/2021 Public OBJECTS The objection is noted – no response is required. Comment 09
I wish to express my objection to this planning. I don’t The issues raised are addressed in the PAC report. believe this is a good site for this track, the car park you mention in the planning is chocker block especially at weekend just for rugby use, I also would like to know more about the those using the track cycling here. How do you know this? From living in this area BMX bikes are not all that’s popular so those wanting to use this club would be coming from other parts of the city.
Riverside Park, Llanrumney Pre-Application Consultation (PAC) Responses Table Page 12 of 40
The exits out of this estate are already an issue. I know there are plans for a much needed 3rd exit but I think we are away off this.
There are also plans currently for a new sports facility very nearby which will add pressure to this end of the estate it would be wise to see the affects of this before another facility is added so close by.
We are losing field space at the Llanrumney hall site to housing. We already lost some space at the clevedon rd and Braunton crescent sites due to housing we need to protect what is left.
Thank you for logging my objections
26.04.2021 Public OBJECTS The objection is noted – no response is required. Comment 10
We are residents of Ridgeway Road & users of Riverside The issues raised are addressed in the PAC report. Park for recreation. While we live further along Ridgeway road than the proposed site of the track we already suffer much inconvenience from cars using the road as a car park and a short cut to get on to Ball Road & thus gain access to the lower level where the track will be sited. We know that car parking fears are valid because of the problems already
Riverside Park, Llanrumney Pre-Application Consultation (PAC) Responses Table Page 13 of 40
being suffered by existing sites there.
Most of our neighbours are retired pensioners & find the above ( car parking) a sufficient cause of distress already.
Our son (response below) has already submitted an objection to you and sets out the objection in greater detail. We wish to be associated with all he has said.
26.04.2021 Public OBJECTS With regards to location, a notice at the entrance of the park Comment 11 has been present throughout the entire consultation exercise.
I first wish to state that there is very poor publicity in this application. I use this location daily and was unaware until The removed notice has been replaced with one in the car I was talking to one of the other users of the park. park at the request of the local residents.
Having read the plans this will be hugely impacting on the The objection is noted – no response is required. local area. It would appear that none of the regular users have been spoken to, As stated I use this area daily and my views or The issues raised are addressed in the PAC report. considerations have not been asked for by anyone.
I further notice in your summary of the application that the area is underutilised. This is incorrect. Every morning there are numerous dog walkers, runners, regular walkers, people physically training.
These are regular users on a daily basis on this is only a
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snapshot of one hour in the morning.
I have numerous issues and will outline each one as follows.
1. Flood risk - As you know this area is low lying and is frequently subject to flooding after prolonged rainfall. The addition of this track will only add to the flooding issues as water will be clearly displaced by the inclusion of the concrete track as the water will have to go somewhere. At the moment the whole area gets used for the displacement of water. The track will therefore reduce this area and increase the water level in the rest of the field.
2. Access to the site. The site at this moment will not accommodate the potential parking issues. My daughter attends Ysgol Bro Eirwg which is the school adjacent to this proposed site and access for children in the morning for 'drop off' and the afternoon for collection is utilised by the school for these purposes. At these times the area is very busy with parents and parking at these times is at a premium. With the added car park use of this site, I feel the area will become a hazard for children due to the movement and parking of vehicles. Furthermore it would appear viewing the plans that some of this existing car park is to be removed to accommodate the park and its facilities, therefore adding to this issue. Additionally the park is used by attendees to the rugby club again having this site at this
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location will add additional congestion at these times.
3. Additional users always increase rubbish. There are regular issues with rubbish including broken glass. This is extremely hazardous to both children attending the school and dog walkers as injuries have occured in the past. It is strongly believed that a site of this nature will increase rubbish dumped or left at the site.
4. I have major concern over its close proximity to the area which you have marked on your application on page 19 of 31 showing area 146.
This being marked on the plans as ' SITE OF IMPORTANCE FOR NATURE CONSERVATION'. Having this site so close to the area will clearly have a huge impact on wildlife both during construction and on completion by being used. Regularly seen in this area are herons, buzzards, foxes, field-mice, to none just a few, all of which are a pleasure to observe during a walk in this area.
5. Impact of local community. This appears to be a privately run enterprise, with profit clearly at the heart of the business. It will, I am sure, benefit some local users but I feel that many users will be from outside the area. I can assume that the majority, if not all, of these users from outside the area will be driving there.
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Besides the parking issues and congestion, the local businesses will not benefit as many users may have already purchased their snacks etc elsewhere and I am sure will be encouraged to purchase anything else from the site itself. As a keen cyclist I welcome the thought of projecting cycling further, but in my experience many of these sites are not used by cyclists attending by bike. Many attend by car.
Examples are Maindy track, Newport Velodrome, Mountain Lakes cycle tracks. It is clear therefore that the only thing that will increase in this area is congestion.
I submit this as a formal objection to the plans.
26.04.2021 Public OBJECTS The objection is noted – no response is required. Comment 12
Regarding the the building of a national standard BMX track The issues raised are addressed in the PAC report. next to the Rhumney river, I am writing to express my opposition to these plans.
The site is on green land next to a SSI where many birds, insects and fungus grow. The development including floodlighting would be very detrimental to local wildlife.
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The site and surrounding area is heavily used by families, dog walkers and is valuable green space to be used to help escape and re charge. It is a green oasis beneficial for mental wellbeing which is so very important especially as we have been confined to our local areas for so long and could also face Something similar in the future.
The suggestion that the area doesn’t flood is incorrect, anyone that uses the space regularly knows that the area is covered in water during the winter, the ground becomes highly saturated regardless of big storms. Building on the land would displace rain water and would collect somewhere else causing other parts of the field to flood.
There is not sufficient parking and to suggest everyone will bike to the site is completely misleading and untrue. It could cause accidents to school children in ysgol Bro Eirwg.
With the developments of housing and 3G football pitches on adjoining fields the area is undergoing major changes that will impact biodiversity in the area we can’t afford this BMX track to be built as well.
The track is a good idea but should be built on a brown site not on green land next to a big river. This site is unsuitable
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and would ruin an area that should really be turned into a nature reserve.
26.04.2021 Public OBJECTS The comment is noted – no response is required. Comment 13
I am writing to object to the proposed BMX track planning application as detailed. The parking at the current location is frequently full of parents dropping off or picking up children from the school (a highly thought of Welsh language school that caters for a wide area given the scarcity of such provision) and the large numbers of professional dog walkers who use the fields to exercise their clients dogs. The proposed site is one of the few flat locations in the surrounding area that is safe to walk dogs that is easy to access on level ground, and I personally know of three older dog owners who rely on this area due to the ease of access that would be restricted by the proposal. I have not been able to find in the documents any proposal for how the site will be protected from certain antisocial local groups who frequently damage and vandalise local parks. I am also unable to determine how this benefits local residents, who given the socio-economic status of the local area, will not be able to afford access to the facilities. And what about the residents who live along the access route, given the total lack of capacity for parking (which as previously noted is frequently full), what provision is being made to ensure their ability to park near their own homes is
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not affected? What provision will be made to ensure the safety of local residents and children needing to cross the access roads if the traffic levels increase, given that local residents will almost certainly not have access to the facilities so those that will be using it will drive in? What steps are being taken to ensure there is provision for female participation in this location, given that the majority of those who BMX are male? What impact will a large group of men on bikes in an area where most dog walkers are female have? What assessment has been done around this impact? What provision is there to ensure that this doesn’t become a hub of antisocial behaviour? Thank you for your consideration.
26.04.2021 Public Further to my previous contact, I have looked more closely The comment is noted – no response is required. Comment 14 at the proposed plans, and I can find no proposal for toilets? Where will these facilities be? Are the visitors to the location expected to be there for such a short time that they will not need the toilet? What provision is there for participation of disabled persons wishing to access the site who may not be able to wait until they get home to go to the toilet? And again, how does having no toilet facilities enable female participation (girls and women require secure toilet provision for safety and privacy for dealing with periods etc)? If no toilets are going to be put in, how will visitors be prevented from urinating in the local vicinity, bearing in mind the close proximity of the primary school?
26.04.2021 Public OBJECTS The objection is noted – no response is required. Comment 15
To whom it may concern, I hereby strongly object to the The perceived planning failures are inexistent as the applicant
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Building of a large BMX track on the PUBLIC GREEN SPACE has been compliant with the process. at Riverside Park,
1. Planning failures The local resident has been informed both via email and in 2. Destruction of Natural Habitat & Green Space . person as to where the proposed development is and she has Environmental Issues. been invited to view the plans online and submit her views.
3. Noise & disruption to locals & users
4. Parking , Access, Disruption
5. Alternatives
1. PLANNING FAILURES.
Notification Firstly the planning department, put the Planning Notice in the middle of the long grass ( not the correct area & well off the beaten track ( ie not by the path ), attached loosely to a post with drawing pins . When i connected the planning to say the notice was removed , & to ask them to clarify where the track would be,I got no Clarification of area . Why was this ? A few days later someone from office arrived at the field, & struggled to put a A5 planning sign on carpark fence ( under knee height ) with inadequate equipment ( string ). When asked why they didn’t attach planning to the pitch fence , the representative SAID that it wasn’t there ( pitch ) and on the long grass nature area.This lead me to think that the plans are very ambiguous, or the office actually have no
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idea where the actual area is .Which is very unprofessional & in fact embarrassing, how can they not accurately give facts when asked. The positioning of the signs makes you think that they do not want people to know about the planning. Doing the minimum requirement when it is a public area at risk is unethical, they should be doing the upmost to inform people not the bare minimum. This second notice fell off within 24 hours . Id suggest that the company has not made the planning notice to the field users easy to access, & poor for such a important planning issue. (photos on request )
Use of photo of the carpark. In the planning there is a photo of the Carpark, Mid morning at least 5 years old. The use of the photo implies that the carpark has plenty of space & is under used. It would be more Honest to use a Photo of a Sunday morning , Or mid afternoon on a weekend , to show the current carpark situation. Using a photo from 5 years ago , is very misleading and unprofessional as gives a completely false impression of the area. ( Photos of current day situation on request . Also my van is in the photo, hence my suprise & horror at use of such a out of date photo which appears to have been used to mislead people that do not know the area)
Ambiguous plans
Being myself a daily user of the area, i know the park like the back of my hand . I believe the plans are Ambiguous & misleading . I will list these issues below. Bearing in mind
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im a normal member of the public. I do believe that planning should produce plans that are easy to read & understand .
. Planning Application .
6. Existing Use . Please describe the current use of the site Recreation Ground/Sports Fields Is the site currently vacant? Yes/ No
6. Existing Use. If Yes, please describe the last use of the site: Recreation Ground/Sports Field . When did this use end (if known)? (left blank )
*This is UNTRUE.How can the site be Vacant? It’s in daily use. Misleading. OPEN GREEN SPACE for public use. That’s like saying Llandaff fields is Vacant . MISLEADING & INCORRECT.
8. Pedestrian and Vehicle Access, Roads and Rights of Way
Is a new or altered vehicle or pedestrian access proposed to or from the public highway? Yes /No
*This is incorrect the lane is to be shut to traffic at school drop off & pickup Times
9. Vehicle Parking Is vehicle parking relevant to this proposal? Yes No
*Id suggest strongly that it is relevant & will be required,
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as is currently inadequate for present use , & the plans are taking a proportion of carpark for their “area” so reducing the space available
11. Assessment of flood risk
If the proposed development is within an area at risk of flooding you will need to consider whether it is appropriate to submit a flood consequences assessment. Refer to Section 6 and 7 and Appendix 1 of Technical Advice Note 15: Development and Flood Risk.
Is your proposal within 20 metres of a watercourse (e.g. river, stream or beck)? Yes /No
Will the proposal increase the flood risk elsewhere? Yes/ No
*Although not a watercourse the Track is planned adjacent to the ditch which floods regularly over the footpath.( this area is included in the proposed area )
Although the track may be over 20 meters away from the tidal river that regularly bursts its banks, it is going to be only a meter or so away from a area , which floods to about a meter high in the winter & holds the water & field in water logged state.
I also believe that the weight & size of the Track will push the waterlogged field under more water, making the other
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green spaces pitches flooded for most of the autumn /winter /spring.
12. Biodiversity and Geological Conservation
To assist in answering the following questions refer to the help text. The help text provides further information on when there is a reasonable likelihood that any important biodiversity or geological conservation features may be present or nearby and whether they are likely to be affected by your proposals.
Having referred to the help text, is there a reasonable likelihood of the following being affected adversely or conserved and enhanced within the application site, or on land adjacent to or near the application site? a) Protected and priority species / on the development site / on land adjacent to or near the proposed development No
Designated sites, important habitats or other biodiversity features/, on the development site / , on land adjacent to or near the proposed development No
Features of geological conservation importance / on the development site / on land adjacent to or near the proposed development No
*These 3 points were all answered “ NO” ...... The long grass area which is next to the site, Hosts a wide variety Of wild life & birds , nesting Herons, a breeding pair of buzzards & Jays. The site is adjacent to the Rumney Trail/
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Rhumney river trail. Which includes 500 species , including rare & vulnerable ones. Id suggest that the answer to these questions are looked into with more depth.
14. Waste Storage and Collection
Do the plans incorporate areas to store and aid the collection of waste and have arrangements been made for the separate storage and collection of recyclable waste? Yes /No
*Excuse me ? How will your club be disposing of the litter? This area is already badly littered, Yet the club will be taking no responsibility for collecting theirs? This is not responsible or environmentally sound.
19. Hours of Opening
Are Hours of Opening relevant to this proposal? Yes/ No
*I think the residents on Ridgeway Road would Disagree with regards to Race Nights & Competition days
2.4 Ariel map
This is accurate Please take note of Trees / Natural landmarks . Hedges . Nature area. River.
I question the use of a circle to mark out the area . Why not use the square from the plans so it’s clear to see. How much of the field it uses? This makes for ambigious interpretation of the space required. Please note the Big
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tree in middle
2.9/2.10/2.11. Junction
Fails to show the junction to the lane to access safety & issues. There is often Right of way issues here. The lane shown is frequently Grid locked
3.10. they state “3.10 The site is also served by an existing, spacious car park to the east of the development site, as shown in the extract overleaf. This provides ample parking opportunity for any users accessing the site by private car and is deemed sufficient because, as previously discussed, it is envisaged that most users will be accessing the site by bicycle.”
Using a 5 year old photo , taken at late morning on a weekday. Misleading. Im also confused as this will be promoting nationwide competition & race nights, how that ties in with folk arriving on their “bicycle”
4.29, Diagrams, Removal Of natural landmarks to show how small the intended area is , Rellevant for the first diagram , please note the distance in diagram 2 from the 146 conservation area. I would suggest that the site will be alot closer, Considering my Knowledge of area. Also the river floods both sides. This map needs looking at & scrutinising in great detail.
6.6 The planners here , kindly show us where other green areas are. These aren’t safe & not fit for purpose. Hilly/
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Parking/ residential/ unsafe areas/ unfenced. It is somewhat patronising.
6.8 they state” The Technical Guidance note outlines how a ‘quality value assessment tool is in use by the Parks Service to assess the comparative condition and value of existing open spaces within their type.’ In line with the guidance, ‘proposals that affect open spaces of high quality and /or high value will be opposed.’ As the proposals relate to a small, under-utilised area within Riverside Park “
How rude. It is a green space first, it is high quality , Natural & peaceful environment . SAVE OUR GREEN SPACES. It is not poor quality at all.
2. Destruction of Natural Habitat & Open Green Space . Environmental Issues.
Environmentally we must protect our open green space . Development in Cardiff atm is shocking. This area Floods, Its home to a variety of Wildlife & species , as part of the Rhumney River Trail walk, The planning contains no plans for litter control, Alternatives offered for space is not of similar Quality or can provide the same usage. To get rid of this area to introduce a very large Structure or dirt/ stone is absolutely disgusting & does not fit in with a Green City that cares for environment. (please see above for Environmental Concerns )
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3. Noise & disruption to locals & users. This is a busy area , How will the users be affected when this is being built? Im concerned about not being able to use the carpark during this time. Also concerned about how much of the land Adjacent will be damaged & out of action before during & after use. Residents & park users will have to put up with alot of Noise & distruption in a area that is for relaxation . This is not acceptable, & does not fit in with the type of park. Also environmentally damaging to wildlife, natural nesting habitat.
4. Parking , Access, Disruption The lane is not adequate for heavy use of Building Vehicles, This will cause disruption to local users. The lane can often be gridlocked , I assume BMX may require Ambulances etc which would not have easy access at all. In mornings, Afternoons & weekends , the carpark is gridlocked. The lane Is closed in school hours so not free access.
5. Public Usage : This area is currently Used for :
WALKING, Especially For the older generation , as land is
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flat
Dog Walking. A lovely safe fenced area , with space to stay away from other users
Personal sport type training. Circuits , weights, fitness
School use social games
Playgroup use nature walks & exercise
Dog Training Training for completion
Ball Games/ team sports / training both formal & informal
Picnics
Family get togethers
Drone Flying & Model Aircraft Flying
Golf & Angling/ casting Practise
Photography
Bird Watching
By taking away this area, All these people, Local people , will lose out. The BMX track will not be free to use & by the size of it looks like to actually be more focused on bringing in people from outside the area , rather than for local users, So everyone will lose out . It will also squash up the current users onto a much reduced sized area, this will cause
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conflict & overcrowding on other areas, especially when Rugby is on. Throughout Covid times the area has become really popular, which should be encouraged. Although some local children may enjoy the facility , there will be many many more that will LOSE OUT as the area will lose valuable space , for free activities, it is a poor area, & Free activities should be encouraged not stopped. This needs to be taken into consideration
6. Other thoughts.
The pitches on this area are numerous & packed close together. Leaving the field open for pitches, will allow for pitch rotation & improvement of waterlogged land. That would also allow for space for other users to use the park safely when matches are on, without conflict.
On greenway Road park there is already a track , Free of charge , for locals to use. I believe this sort of development would be better suited to industrial type land –not our precious green open spaces & nature areas, or for example On the land adjacent to Rover Way, making the most of the motocross facility, or nearby. This would be much easier for Transport links, as you know access in & out of Llanrumney is terrible & this would put it under more stress & be frustrating for out of area users. Local residents & users are already talking about Protests & petitions theres is such bad
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feeling about this . Media attention etc to protect our environment
I strongly OBJECT TO THIS PROPOSAL .It should not happen at Riverside Park
26/04/2021 Public OBJECTS The objection is noted – no response is required. Comment 16
I reject the plans for a Nation standard BMX track at Llanrumney fields for the following reasons.
• Green space is slowly going in Llanrumney, more houses, more people, less open space.
• Llanrumney has a motorbike problem, what's stopping them from using it.
• Across the river from the planned BMX track, they are planning to develop on the motorbike track and paths, BMX track will be a hotspot for motorbikes unless it's fenced off.
• Very popular dog-walking spot for paid dog walkers as well, Rumney Trail path is not big enough should it become well used by the extra bikes.
• Ebike and E-scooters are currently a lot more used than BMX around Llanrumney, will they be let on the BMX track? they already zoom around the Trail
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path and grass causing problems.
• Far-left of the proposed BMX track gets flooded every year, turns into a small river which you can see from google maps.
• Autumn/winter times of year always a big flood and mud problem, If Ebike/E-scooters are allowed on BMX track, fields will be in more of a mess.
• like most areas the youth will not look after the BMX track, take a walk around Llanrumney yourselves, parks, benches, bins, Astroturf pitches, burnt woodlands.
• Soon to be a Horse problem, they are making their way over when the river is low
• Busy days already have traffic problems
• BMX track doesn't fit the area, the last big open peaceful green space area in Llanrumney untouched.
27/04/2021 Public My general observations: The objection is noted – no response is required. Comment 17 LOSS OF OPEN SPACE
It is misleading to suggest that Riverside Park is a single entity seemingly with easy access for all. The University Playing Fields are clearly to be seen as a separate facility as demonstrated by fencing/hedging to prevent open access; the main rugby pitch for Rumney RFC is again clearly enclosed. Both areas are effectively membership only facilities with restricted access. The rest of the Park area
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enjoys easy access to all parts for the wider general public.
The proposed track will require permanent structures that will require specific boundary protection. Currently the area has no physical barrier. That would no longer be the case as open access will be denied. It is a false assertion to highlight Howardian Local Nature Reserve as offering some measure of compensation for the loss of 1.3 hectares that the track will require. The Nature Reserve is not within walking distance of Riverside Park, ignoring also the fact that access to the Reserve requires crossing the river, a dual carriage way and where there is no direct public crossing.
FLOOD RISK AND SURFACE WATER DRAINAGE
The proposed site was flooded to a depth of 1 metre in February 2020. This is acknowledged in the consultant’s report but not in the Planning Application Form - and on the latter it is incorrect to state that the proposed site is not within 20 metres of a watercourse (see the Site Location document).
More importantly, the proposed site has an existing realistic problem with surface water flooding and surface water retention. During the winter months and after any period of sustained rainfall, the ground becomes saturated and surface water inundation is a highly visible problem. It is clear that in the absence of dedicated surface water drainage system, the drying out process is subject to the vagaries of the weather and of nature. It is highly misleading to suggest that the track proposal will enable rainwater to run off as it does currently. Simply not the case.
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SOUTH WALES FACILITY OR LOCAL COMMUNITY FACILITY
The planning documents highlight the current absence of a high quality BMX track facility for S Wales. This suggests the proposed track would attract users from the wider community across S Wales yet the documents underplay the potential for increased traffic. Instead there is reference to the majority users accessing the track by bicycle. This despite there being no dedicated cycle lanes locally, that BMX cycles are not designed for road usage (invariably only a rear brake provision and no facility for a bicycle lamp etc). Outside of the local area, cyclists face a difficult journey by road, invariably having to travel along Newport Road.
There is no evidence presented to support the assertion that “most members will access and egress the site by bike”. The track will be a member only facility but where non-members can have access subject to paying a fee.
The main highway access is off from Hartland Road, for cyclists this will be hazardous during the darker winter months given the almost total absence of street lighting
The existing car park is not spacious . The site location document makes clear that the track development will encroach into the car park, actually reducing the level of parking provision. Related to this, the car parks used regularly by a wide range of interests (football, rugby, walkers, family strolls etc). A BMX track that has a catchments area across South Wales is more than likely to attract additional pressure on the car park. It would have been useful if the documentation had made an effort to more properly address potential traffic management difficulties in the area and in particular what alternative
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parking measures would be envisaged. To my reading, the applicant is deliberately avoiding the traffic management issues through an oversimplification that an overwhelming majority will travel to the track by bicycle.
SUSTAINABILTY
It is inconceivable that the users of the proposed track will not generate waste material and recyclable material. Given the broader sustainable development agenda, it is entirely shocking that there would appear to be no effort on the part of the applicant to acknowledge a need to make provision for the election of both waste and recyclable materials
SITE LOCATION
From the documentation, it is unclear whether the proposed track will encroach on the existing rugby pitch (south of the river) and on the junior football pitches alongside the proposal.
Furthermore, it is incorrect to suggest that the proposed site of the track is unallocated recreational land - it is the home pitch for Llanrumney United AFC.
Finally, the photograph portraying the carpark is very much out of date. A new tarmac surface was laid some 3 years ago.
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27/04/2021 Public OBJECTS The objection is noted – no response is required. Comment 18
I am writing to object very strongly to the proposed planning permission to the above area for a BMX Track and associated works. Firstly I have lived in Patchway Crescent for over 30 years. On myside of the street our houses are elevated and the lounge is at the back of the house, the windows are big picture windows and the view is the field, the trees and beyond. Most people who live on my side of the street bought these houses for the VIEW. About 15 years ago I had a conservatory built two storeys high to appreciate the open green spaces. This BMX track will take that all away and will encourage noise and anti-social behaviour. Why were the residents of Patchway Crescent not informed of this Planning Proposal as it will have a negative impact on them and their lives?
Below are my objections to your proposals:-
The area is under-utilised This area is used by many dog-walkers (including myself for the last 30 years), many people use it for walking, fitness exercising, families out with their children, picnics, (model plane and droneflying when the weather is appropriate) Ball games, competition dog training, training and exercising guide dogs. People walk here for their own mental and physical wellbeing especially in this Covid-19 crisis.
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The area is not a Flood Risk I have seen the effects of Flooding over the years that I have been walking my dogs. The field in Winter is very water logged especially in the middle, it is like a pond. Over the years the floodinghas got worse. The River now overflows the bank and has on the left-hand side for some distance washed the stones away from the walkway. The field last year was completely submerged in water, it looked like a lake no grass showing. This is the effects of being on a flood plain and climate-change as we all know and will only get worse.
That the access lane and car park are more than adequate The lane is frequently used and the car park (after being extended a number of years ago). Normally there are around 15 – 20 cars but at weekends and rugby matches the car park is full, the access road is congested and cars have to park on the grass. Recently the Rugby club has extended their car park and built a new access with a bridge over connecting the two car parks. The School also has buses coming up the existing access way to the Rugby club, letting off children, turning in the car park and leaving. We in Patchway Crescent also experience difficulty during the school travelling periods with limited access, congestion and parking difficulties. This would be made worse with the extra car volume expected at
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weekends, competitions and ‘race nights’ apart from the extra noise, rubbish left and anti-social behaviour. People will not cycle orwalk to these events they will put their cycle in their car and drive here. The picture on your website of the car park is very old not an up- to-date picture?
Effects on the Wildlife and Nature This world stadium and so called associated works will have a massive impact on the wildlife andbird population in the long grass, along the river and in the fields. It will take away their green space and their habitance. The herons in the long grass, cormorants and various species of ducks on the river, mink along the river, king fishers who have been nesting here for years, woodpeckers, buzzards and kestrels who live here in the air space with various other species of birds. The bats who live in the bat house towards Hartland Road (I thought these were a protected species what would the building works and noise do to them?). These would all leavethis area.
Conservation of our ‘Green Area’ and Parkland This protection of our ‘green area’ is very important as it is not wasted land and it is not under-used. By taking a large area of our field you will be impacting on our privacy when we are walking, the amount of rubbish left will impact on the environment and the Stadium will encourage anti-social behaviour and
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gatherings of youths vandalising the buildings and impacting our lives as residents. We would have BMX’s parking in our streets causing congestion.
These are my objections to this project, I would like to live here and be able to enjoy the countryside and the open spaces.
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27/04/2021 Public OBJECTS The objection is noted – no response required. Comment 19 I write to object to the proposed development as I believe it will have a significant and detrimental impact upon a number of neighbours, and also the local wildlife.
Hartland Road will have to bear all the extra traffic generated. What is the evidence for your claim that most users will arrive at the facility by bicycle?
Local wildlife will suffer disturbance and litter from the extra visitors along the narrow lane to the track. Parc Coed y Cwar, known locally as Bluebell Wood is an SSSI, one of the few remaining fragments of ancient woodland in the area. Noise produced by the track users, particularly when the floodlights are used may drive away all kinds of animals.
I would be obliged if you could also please clarify if any trees are to be felled, it would appear from the plans that at least one veteran oak tree will be in the way.
Put briefly, developing this site to such an extent will lead to the loss of a quiet, multi-purpose area that the whole community can now enjoy - all for some BMX enthusiasts to dominate instead.
I would be grateful if you could acknowledge and respond to this message.
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APPENDIX D – SPECIALIST CONSULTEE RESPONSES
PlasWelsh Carew, Government UnitUned 5/7 5/7 Cefn Cefn Coed Coed ParcTy’r Afon, Nantgarw, CardiffCaerdydd CF15 CF15 7QQ 7Q Q Parc Nantgarw, CardiffCaerdydd CF15 CF15 7QQ 7QQ Parc Nantgarw, Cardiff CF15 7QQ Parc Nantgarw, Cardiff CF15 7QQ TelFfônHeol 0300 0300Bedwas/ 025 025 6000 Bedwas 6000 Road TelFfôn 0300030 03000 025 025 6000 6000 Tel 0300 025 6000 Tel 0300 025 6000 EmailEbostCaerffili/ [email protected]@llyw.cymru Caerphilly EmailEbost [email protected]@llyw.cymru Email [email protected]@gov.wales Email [email protected] cadw.gov.walesCF83 8WT cadw.gov.wales cadw.gov.wales cadw.gov.wales 0300 025 6000
[email protected]/[email protected] www.cadw.gov.wales
Eich cyfeirnod Geraint John Planning Ltd Your reference
Ein cyfeirnod By email: [email protected] Our reference LC
Dyddiad Date 12 April 2021
Llinell uniongyrchol Direct line 0300 0256004
Ebost [email protected] Email:
Dear Sir/Madam
Pre-Planning Application - Full Planning Application for a National Standard BMX Race-track and associated works, Riverside Park, Hartland Road, Llanrumney, Cardiff, CF3 4JL
Thank you for your letter of 31 March inviting our comments on the pre-planning application consultation for the proposed development described above.
Advice
The following comments are based on information made available to us as part of the pre-application consultation and we will review our comments when we are consulted on the final planning application. Our assessment of the pre-application is given below.
Our records show that there are no scheduled monuments or registered historic parks and gardens that would be affected by the proposed development.
We therefore have no comments to make on the proposed development.
The national policy and Cadw’s role in the planning process is set out in Annex A.
Assessment
This planning application is for a National Standard BMX Race-track at Riverside Park, Hartland Road, Llanrumney, Cardiff, CF3 4JL.
Located within a 3km buffer of the application area are:
Scheduled Monuments
GM216 Caer Castell Camp GM474 Relict Seawall on Rumney Great Wharf
Mae Gwasanaeth Amgylchedd Hanesyddol Llywodraeth Cymru (Cadw) yn hyrwyddo gwaith cadwraeth ar gyfer amgylchedd hanesyddol Cymru a gwerthfawrogiad ohono.
The Welsh Government Historic Environment Service (Cadw) promotes the conservation and appreciation of Wales’s historic environment.
Rydym yn croesawu gohebiaeth yn Gymraeg ac yn Saesneg. We welcome correspondence in both English and Welsh.
Registered Parks and Gardens
PGW (Gm) 19(CDF) Cathays Cemetery (grade II*) PGW (Gm) 24(CDF) Roath Park (grade I) PGW (Gm) 29(CDF) Waterloo Gardens and Roath Mill Gardens (grade II)
Intervening topography, buildings and vegetation mean it is unlikely that the proposal will be inter-visible with the scheduled monuments or the registered park and gardens. Therefore it is unlikely that there will be any effect on the settings of the scheduled monuments or the registered park and gardens.
Finally, there may also be undesignated historic assets that could be affected by the proposed development and, if you have not already done so, we would advise that you consult the Historic Environment Record held by the Glamorgan-Gwent Archaeological Trust www.ggat.org.uk
Yours sincerely,
Laura Cooper Diogelu a Pholisi / Protection and Policy
Annex A
Our role
Our statutory role in the planning process is to provide the local planning authority with an assessment concerned with the likely impact that the proposal will have on scheduled monuments, registered historic parks and gardens, registered historic landscapes where an Environmental Impact Assessment is required and development likely to have an impact on the outstanding universal value of a World Heritage Site. We do not provide an assessment of the likely impact of the development on listed buildings or conservation areas, as these are matters for the local authority.
It is for the local planning authority to weigh our assessment against all the other material considerations in determining whether to approve planning permission.
National Policy
Applications for planning permission are considered in light of the Welsh Government’s land use planning policy and guidance contained in Planning Policy Wales (PPW), Technical Advice Notes and related guidance.
PPW planning-policy-wales-edition-11.pdf explains that it is important that the planning system looks to protect, conserve and enhance the significance of historic assets. This will include consideration of the setting of an historic asset which might extend beyond its curtilage. Any change that impacts on an historic asset or its setting should be managed in a sensitive and sustainable way.
The conservation of archaeological remains and their settings is a material consideration in determining a planning application, whether those remains are a scheduled monument or not. Where nationally important archaeological remains are likely to be affected by proposed development, there should be a presumption in favour of their physical protection in situ. It will only be in exceptional circumstances that planning permission will be granted if development would result in a direct adverse impact on a scheduled monument (or an archaeological site shown to be of national importance)
Technical Advice Note 24: The Historic Environment elaborates by explaining that when considering development proposals that affect scheduled monuments or other nationally important archaeological remains, there should be a presumption in favour of their physical preservation in situ, i.e. a presumption against proposals which would involve significant alteration or cause damage, or would have a significant adverse impact causing harm within the setting of the remains.
Historic Parks and Gardens
PPW also explains that local authorities should value, protect, conserve and enhance the special interests of parks and gardens and their settings included on the register of historic parks and gardens in Wales and that the effect of a proposed development on a registered park or garden or its setting should be a material consideration in the determination of a planning application.
Re: Full Planning Application for a National Standard BMX Race-Track and associated works.
I cannot see that this team were consulted on the initial pre-application consultation, but I shall treat it as any other pre-app type consultation.
As discussed, an application for a BMX Track is not something I have come across before and have struggled to find any other documents online where similar applications have undergone acoustic assessment. The only similar development would be a MUGA, where the existing use sports grounds are intensified. I have spent some time reading around BMX parks to get best understanding, but if you or indeed Justin are aware of any others where noise has been considered and an acoustic assessment completed, I will be happy to review and compare. I have reached out to a number of other Pollution teams across England who have this in train (Ealing for example) to see how these were viewed and for other reports – if anything critical comes back in time I’ll send more comments on.
The matters I think that concern me at the moment, and should be addressed as part of the full application:
- Proposed operating hours, any seasonal changes, any weekend variations. There is obviously intention for flood lighting, but is this for the winter periods with earlier sunsets, is it envisaged use will extend into most evenings irrespective of the season. Knowing the operating hours are “day time into earlier evening, say 1900 hrs – may alleviate noise concerns as background levels are still likely high with prevailing noise from the A48. After this time you expect background noise levels to drop, and so the expectation for residential amenity that no site specific noise remains dominant;
- In regards to the lighting can it be made clear how this will not impact residential amenity, as this teams other core consideration;
- In terms of safety, what is the maximum number of riders envisaged to be using the park at one time. This will aid with any noise issues if numbers are naturally low for safety reasons. Similar to this, how many different attendees do you expect to see over the duration of a busy day. Assuming 9-5 opening, is it may 6 “races” around the track per hour. The more experienced riders I’m sure will finish very quickly as is the intention.
- I assume there will be some of sort of public address systems used for safety announcements, inviting riders to take position etc? what volumes with these be at, is can it be limited, will it be audible at residential amenity?
- I’m not sure how loud the starting position “gate” is when its dropped, but on my research they have to use hydraulic systems according to the UCI Track Building Guidelines (again, I’m not expert but have had a read through). Even with the distance, that short “spike” in noise with a low background multiple times has potential for issues;
- Looking at other big BMX tracks (Birmingham, Cornwall, Rhyl they do attract a large gathering, in some instances national events and festivals. With that come associated noise from crowds gathered, cheering etc. Something like this may be controlled by way of conditioning to any approval (pending advice from the LPA) such as the need to provide a specific noise mannagmet plan for larger events being hosted – that comes with risks though and may be harder to mitigate, leading to complaint and enforcement form this team which I wish to limit the risk off.
- A condition that seemed to crop up other places read on the lines “not be used by any motorised cycles at any time” – in any permission granted we would seek something similar as the noise from such vehicles is far greater and travels extremely well. I’m sure the aim to mitigate intruders anyway has already been considered, by way of fencing etc – but also professionals may seek to book on, (if the same standard of track is applicable for such use?)
- Stepping aside from residential amenity, who have a duty to protect the school from unharmful noise (BB93 is a the document for school building acoustics) so some reference to how this will be managed. It is not uncommon for schools to complain to this team for matters outside of our control causing impact, so it will be better to manage this as planning stage.
- Is there going to be any dust produced from the use, where the area is not cemented. How is this managed?
Will – just for info as we touched it this yesterday.
Any questions let me know.
Kind regards
Mr Tomos Jenkins Neighbourhood Services Officer / Swyddog Gwasanaethau Cymdogaeth Shared Regulatory Services / Gwasanaethau Rheoliadol a Rennir Bridgend, Cardiff and the Vale of Glamorgan Pen-y-bont ar Ogwr, Caerdydd a Bro Morgannwg
e-mail / e-bost: [email protected]
Developer Services Gwasanaethau Datblygu PO Box 3146 Blwch Post 3146 Cardiff Caerdydd CF30 0EH CF30 0EH
Tel: +44 (0)800 917 2652 Ffôn: +44 (0)800 917 2652 Fax: +44 (0)2920 740472 Ffacs: +44 (0)2920 740472 E.mail: [email protected] E.bost: [email protected]
Mr Geraint John Geraint John Planning Office 16 The Maltings, East Tyndall Street, Cardiff Cardiff CF24 5EA Date: 16/04/2021 Our Ref: PPA0005631
Dear Mr John
Grid Ref: 321088 179793 Site Address: Riverside Park, Hartland Road, Llanrumney, Cardiff Development: Schedule 1C Article 2D - Full Planning Application for a National Standard BMX Race- track and associated works
I refer to your pre-planning enquiry received relating to the above site, seeking our views on the capacity of our network of assets and infrastructure to accommodate your proposed development. Having reviewed the details submitted I can provide the following comments which should be taken into account within any future planning application for the development.
I refer to the Schedule 1C - Article 2D notice received and your formal request for a pre-application consultation response before applying for planning permission from Dwr Cymru Welsh Water as a ‘Specialist Consultee’ as defined by Paragraph (y) of Schedule 4 of the Town & Country Planning (Development Management Procedure) (Wales) (Amendment) Order 2016. It is acknowledged that the consultation request relates to a major development site and thus seeks a substantive response within 28 days from the date of the notice, as per the requirements of Article 2E. This request includes our views on the capacity of our network of assets and infrastructure to accommodate your proposed development. Having reviewed the details submitted I would advise there is no objection to the proposed development and offer the following standing advice which should be taken into account within any future planning application for the development.
SEWERAGE It appears the application does not propose to connect to the public sewer, and therefore Dwr Cymru Welsh Water has no further comments. However, should circumstances change and a connection to the public sewerage system/public sewage treatment works is preferred we must be re-consulted on this application.
We welcome correspondence in Rydym yn croesawu gohebiaeth yn y Welsh and English Gymraeg neu yn Saesneg
Dŵr Cymru Cyf, a limited company registered in Dŵr Cymru Cyf, cwmni cyfyngedig wedi’i gofrestru yng
Wales no 2366777. Registered office: Pentwyn Road, Nghymru rhif 2366777. Swyddfa gofrestredig: Heol Pentwyn Welsh Water is owned by Glas Cymru – a ‘not-for-profit’ company. Nelson, Treharris, Mid Glamorgan CF46 6LY Nelson, Treharris, Morgannwg Ganol CF46 6LY. Mae Dŵr Cymru yn eiddo i Glas Cymru – cwmni ‘nid-er-elw’.
The applicant is also advised that some public sewers and lateral drains may not be recorded on our maps of public sewers because they were originally privately owned and were transferred into public ownership by nature of the Water Industry (Schemes for Adoption of Private Sewers) Regulations 2011. The presence of such assets may affect the proposal. In order to assist us in dealing with the proposal the applicant may contact Dwr Cymru Welsh Water on 0800 085 3968 to establish the location and status of the apparatus. Under the Water Industry Act 1991 Dwr Cymru Welsh Water has rights of access to its apparatus at all times.
SEWAGE TREATMENT
No problems are envisaged with the Waste Water Treatment Works for the treatment of domestic discharges from this site.
WATER SUPPLY
A water supply can be made available to service this proposed development.
I trust the above information is helpful and will assist you in forming water and drainage strategies that should accompany any future planning application. I also attach copies of our water and sewer extract plans for the area, and a copy of our Planning Guidance Note which provides further information on our approach to the planning process, making connections to our systems and ensuring any existing public assets or infrastructure located within new development sites are protected.
Please note that our response is based on the information provided in your enquiry and should the information change we reserve the right to make a new representation. Should you have any queries or wish to discuss any aspect of our response please do not hesitate to contact our dedicated team of planning officers, either on 0800 917 2652 or via email at [email protected]. Please quote our reference number in all communications and correspondence.
Yours faithfully,
Owain George Planning Liaison Manager Developer Services
Please Note that demands upon the water and sewerage systems change continually; consequently the information given above should be regarded as reliable for a maximum period of 12 months from the date of this letter.
We welcome correspondence in Rydym yn croesawu gohebiaeth yn y Welsh and English Gymraeg neu yn Saesneg
Dŵr Cymru Cyf, a limited company registered in Dŵr Cymru Cyf, cwmni cyfyngedig wedi’i gofrestru yng
Wales no 2366777. Registered office: Pentwyn Road, Nghymru rhif 2366777. Swyddfa gofrestredig: Heol Pentwyn Welsh Water is owned by Glas Cymru – a ‘not-for-profit’ company. Nelson, Treharris, Mid Glamorgan CF46 6LY Nelson, Treharris, Morgannwg Ganol CF46 6LY. Mae Dŵr Cymru yn eiddo i Glas Cymru – cwmni ‘nid-er-elw’.
Ein cyf/Our ref: CAS-143161-Q9G4
Rivers House, St Mellons Business Park, St Mellons, Cardiff, CF3 0EY
FAO: Annamaria Sgueglia ebost/email: Geraint John Planning Ltd. [email protected] Office 16 (House 1, 2nd Floor), Ffôn/Phone: 03000 65 3114 The Maltings, East Tyndall Street, Cardiff, CF24 5EA
26/04/2021
Annwyl Syr/Madam / Dear Sir/Madam,
STATUTORY PRE-APPLICATION CONSULTATION – TOWN AND COUNTRY PLANNING (DEVELOPMENT MANAGEMENT PROCEDURE) (WALES) ORDER 2012 AS AMENDED.
BWRIAD / PROPOSAL: FULL PLANNING APPLICATION FOR A NATIONAL STANDARD BMX RACE-TRACK AND ASSOCIATED WORKS.
LLEOLIAD / LOCATION: RIVERSIDE PARK, HARTLAND ROAD, LLANRUMNEY, CARDIFF, CF3 4JL.
Thank you for providing a requisite notice to us under Article 2D of the above Order. We received a copy of your proposed application on 1 April 2021.
Based on the information provided, we would have no objection to the proposed development and provide the following advice.
Flood Risk The planning application proposes the retention of less vulnerable development. Our Flood Risk Map confirms the application site to be entirely within Zone C1 of the Development Advice Map (DAM) as contained in TAN15. Our records show the site previously flooded during the December 1979 flood event.
Section 6 of TAN15 requires the Local Planning Authority (LPA) to determine whether the development at this location is justified. Therefore, we would refer the LPA to the tests set out in Section 6.2 of TAN15. If the LPA consider the proposal meets the tests set out in criteria (i) to (iii), then the final test (iv) is for the Applicant to demonstrate, through the submission of an FCA, that the potential consequences of flooding can be managed to an acceptable level.
Croesewir gohebiaeth yn y Gymraeg a’r Saesneg Correspondence welcomed in Welsh and English
We have reviewed the FCA prepared by Hydrogeo, reference HYG861 R 210326 CB Cardiff BMX Track_FCA, version 1, dated 26th March 2021. Whilst our advice below shows the FCA has not demonstrated that the risks and consequences of flooding can be managed to an acceptable level, recognising the nature of the application (the retention of less vulnerable development) in this instance we would have no objection to the application as submitted.
Section 4.12 of the FCA identifies there will be no major alternations to the existing site ground levels, therefore flood conveyance and storage will not be affected. The FCA states the existing site ground levels range between 6.71–7.22m AOD. Based on these site ground levels, the FCA shows:
• During a 1% (1 in 100 year) plus 20% for climate change annual probability fluvial flood event, the development is predicted to flood to a depth between 1000 - 1500mm.
• During a 0.1% (1 in 1000 year) annual probability fluvial flood event, the development is predicted to flood to maximum depths between 1000 – 1740mm.
• During a 0.5% (1 in 200 year) plus climate change (2115) annual probability tidal flood event, the development is predicted to flood a depth of 2600mm.
• During a 0.5% (1 in 1000 year) annual probability tidal flood event for the current day, the development is predicted to flood to a depth of 2500mm.
The FCA has proposed the management of flood risk by recommending: the preparation of a Flood Plan; the appointment of a Flood Warden; the site owner/operator sign up to the flood warning service; and, an access/egress route. We also recommend signage is erected to inform users of the potential flood risk to this area.
The above shows the proposed development does not meet the requirements of A1.14 of TAN15 and exceeds the tolerable limits of A1.15 of TAN15. Furthermore, the FCA has not used the appropriate climate change allowances (CCAs) for this type of development. However, given the nature of the proposed development and that flood conveyance and storage will not be affected, in this instance we would have no objection to the application as submitted.
We would advise the LPA that no information has been provided on the rate of rise and speed of inundation as per A1.15 of TAN15 and the Welsh Government’s CPO Letter (Planning Policy on Flood Risk and Insurance Industry Changes) on 9 January 2014. If the LPA are minded to request this information from the Applicant, we would be happy to provide further advice.
Further Advice It is for the Planning Authority to determine whether the risks and consequences of flooding can be managed in accordance with TAN15. We cannot advise them on matters such as emergency plans, procedures and measures to address structural damage that may result from flooding. Please note, we do not normally comment on or grant the adequacy of flood emergency response plans and procedures accompanying development proposals, as we
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do not carry out these roles during a flood. Our involvement during a flood emergency would be limited to delivering flood warnings to occupants/users.
We recommend you consider the future insurability of this development now. Although we have no involvement in this matter we would advise you to review the Association of British Insurers published paper ‘Climate Adaptation: Guidance on Insurance Issues for New Developments’, to help you ensure any properties are as flood proof as possible and insurable.
Flood Risk Activity Permit Please be advised that the Environmental Permitting Regulations (2016) require the Applicant/Developer to obtain a bespoke Flood Risk Activity Permit for any works or structures located in, under, over or within 8 metres of the bank top of the River Rhymney, a designated “main river”. Further advice and guidance is available on our website.
European Protected Species We recommend you seek the advice of the Local Authority’s ecologist to determine if there is a reasonable likelihood of bats, a European Protected Species, being present within the application site. If so, in accordance with Technical Advice Note 5: Nature Conservation and Planning (paragraph 6.2.2) a bat survey may be required.
The survey should be carried out in accordance with ‘Bat Surveys; Good Practice Guidelines 3rd Edition’ published by the Bat Conservation Trust 2016.
The LPA will consult us if any survey undertaken finds that bats are present at the site and they require further advice from us.
Other Matters Please note, if further information is prepared to support an application, it may be necessary for us to change our advice in line with the new information.
Our comments above only relate specifically to matters included on our checklist, Development Planning Advisory Service: Consultation Topics (September 2018), which is published on our website. We have not considered potential effects on other matters and do not rule out the potential for the proposed development to affect other interests.
In addition to planning permission, you are advised to ensure all other permits/consents/licences relevant to the development are secured. Please refer to our website for further details.
Further advice on the above matters could be provided prior to your planning application being submitted, however there would be a charge for this service. Additional details are available on our website.
If you have any queries on the above, please do not hesitate to contact us.
Yn gywir / Yours faithfully
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Paige Minahan Cynghorydd - Cynllunio Datblygu / Advisor - Development Planning Cyfoeth Naturiol Cymru / Natural Resources Wales
www.naturalresourceswales.gov.uk www.cyfoethnaturiolcymru.gov.uk Page 4 of 4
200 Lichfield Lane Mansfield Nottinghamshire NG18 4RG T: 01623 637 119 E: planningconsultation@coal,gov.uk www.gov.uk/coalauthority
For the attention of Annamaria Sgueglia - Planner Geraint John Planning Ltd
[By email: [email protected]]
06 April 2021
Dear Ms Sgueglia
Schedule 1C Article 2D - Consultation before applying for planning permission
Town and Country Planning (Development Management Procedure) (Wales) Order 2012 as amended by The Planning Applications (Temporary Modifications and Disapplication) (Wales) (Coronavirus) Order 2020
Full Planning Application for a National Standard BMX Race-Track and Associated Works at Riverside Park, Llanrumney
Thank you for your notification of 31 March 2021 seeking the pre-application views of the Coal Authority on the above.
I have checked the site location plan against the information held by the Coal Authority and can confirm that the proposed development site is located outside of the defined coalfield.
Accordingly, there is no requirement for the applicant to consider coal mining legacy as part of any formal planning application for this site, or for the Local Planning Authority to consult the Coal Authority.
Please do not hesitate to contact me if you would like to discuss this matter further.
Yours sincerely
D Roberts
Deb Roberts M.Sc. MRTPI Planning & Development Manager
Disclaimer
The above consultation response is provided by The Coal Authority as a Statutory Consultee and is based upon the latest available data on the date of the response, and electronic consultation records held by The Coal Authority since 1 April 2013. The comments made are also based upon only the information provided to The Coal Authority by the Local Planning Authority and/or has been published on the Council's website for consultation purposes in relation to this specific planning application. The views and conclusions contained in this response may be subject to review and amendment by The Coal Authority if additional or new data/information (such as a revised Coal Mining Risk Assessment) is provided by the Local Planning Authority or the Applicant for consultation purposes.