Plas Carew, Uned 5/7 Cefn Coed Plas Carew, Unit 5/7 Cefn Coed Parc Nantgarw, Caerdydd CF15 7QQ Parc Nantgarw, Cardiff CF15 7QQ Ffôn 01443 336000 Ffacs 01443 336001 Tel 01443 336000 Fax 01443 336001 Ebost cadw@.gsi.gov.uk Email [email protected] Gwefan www.cadw.wales.gov.uk Web www.cadw.wales.gov.uk

Mrs D Hier Eich cyfeirnod P/12/0219 Your reference County Borough Council Ein cyfeirnod

Ty Keir Hardie Our reference Riverside Court Dyddiad 15 November 2012 Avenue De Clichy Date Merthyr Tydfil Llinell uniongyrchol CF47 8XF Direct line Ebost

Email:

Dear Mrs Hier

TOWN AND COUNTRY PLANNING ACT 1990 PLANNING APPLICATION NO: P/12/0219

PROPOSED DEVELOPMENT: DEMOLITION OF EXISTING B & Q BUILDING AND ERECTION OF 6 RETAIL UNITS (NO 12-17) WITHIN CYFARTHA RETAIL PARK (USE CLASS A1) WITH CAFÉ IN UNIT 17 AND ASSOCIATED ALTERATIONS TO EXISTING CAR PARK SERVING CYFARTHA RETAIL PARK, ERCTION OF 3 RETAIL UNITS (USE CLASS A1) ON LAND AT FORMER THORN ELECTRICAL SITE TOGETHER WITH THE CREATION OF CAR PARKING AREAS, SERVICE/COMPOUND AREAS AND ASSOCIATED LANDSCAPING WORKS, HIGHWAY WORKS TO THE A470 (T) AND SWANSEA ROAD (FULL)

LOCATION: LAND AT FORMER THORNS ELECTRICAL SITE AND CYFARTHA RETAIL PARK, INCLUDING PART OF THE A470 (T) AND SWANSEA ROAD MERTHYR TYDFIL

Thank you for your letter of 3 September 2012 inviting Cadw’s comments on the planning application for the proposed development as described above. I apologise for the delay in responding.

The advice set out below relates only to those aspects of the proposal, which fall within Cadw’s remit as a consultee on planning applications – the impact of developments on scheduled monuments or Registered Historic Landscapes, Parks and Gardens. Our comments do not address any potential impact on the setting of any listed building, which is properly a matter for your authority. These views are provided without prejudice to the Welsh Government’s consideration of the matter, should it come before it formally for determination.

Scheduled Monuments

Cadw’s records show that three scheduled monuments of national importance are located in close proximity to the proposed development site. The scheduled monument known as Remains of Iron Furnaces, Ironworks (GM425) is located adjacent to the northern part of the proposed development site. The great east-facing furnace bank at Cyfarthfa and its charging ramp approaching from the south probably constitute the single most impressive monument to the Industrial Revolution in Wales. In their heyday in the late eighteenth century, the furnaces lay at the centre of the largest ironworks in the world. The western boundary of the scheduled area is co-located with the eastern

Cadw yw gwasanaeth amgylchedd hanesyddol Llywodraeth Cymru. Ein nod yw hyrwyddo gwaith cadwraeth ar gyfer amgylchedd hanesyddol Cymru a gwerthfawrogiad ohono.

Cadw is the Welsh Government’s historic environment service. Our aim is to promote the conservation and appreciation of Wales’s historic environment. boundary of the development area located to the north of the A4102. The scheduled monument known as Pont y Cafnau Tramroad Bridge (GM424) is located c. 250m north of the northern edge of the proposed development area. The scheduled monument known as Iron Canal Bridge from Rhydycar (GM486) is located c. 275m east of the eastern boundary of the proposed development area. The scheduled areas of these monuments are shown outlined in red on the attached plan. The application has the potential to affect the monument in two ways – either a direct, physical impact on the site itself, or an impact on the setting of the site.

Physical impact

From the information given, it appears that no works will take place within the scheduled areas. However, it must be stressed that ‘works’ are not restricted to building works, but can also include ancillary features like drainage, landscaping, hard-standing etc. Provided that none of these take place within the scheduled area of GM425, there should be no physical impact on the monument itself and scheduled monument consent (SMC) will not be required on this occasion. If physical works will take place within the scheduled area, SMC will be required from Cadw.

Evaluation work undertaken by GGAT Contracts has demonstrated that the proposed development site has the potential to affect archaeological remains which are not scheduled, but are, nonetheless, important and probably associated with the scheduled site.

Setting

Planning Policy Wales (Edition 4, February 2011, paragraph 6.5.1) states that the desirability of preserving the setting of an ancient monument should be “a material consideration in determining a planning application”.

The setting of a monument is the surroundings in which a heritage asset is experienced and can be described as being the way in which the monument is seen, understood and appreciated. It is often primarily visual, but can also include other features like tranquillity or remoteness. Its extent is not fixed and may change as the asset and its surroundings evolve. Setting includes views from, of and across a monument.

Development of retail buildings adjacent to scheduled monuments can often affect their setting. Cadw’s Regional Inspector of ancient monuments undertook a site visit on 7 November and viewed the proposed development site and scheduled monuments from different locations around Merthyr Tydfil. There is no inter-visibility between the proposed development site and either Pont y Cafnau Tramroad Bridge (GM424) or Iron Canal Bridge from Rhydycar (GM486). In the opinion of Cadw, the proposed development will, therefore, have a neutral impact on the setting of these scheduled monuments.

Given the shared boundary between the proposed development and the Remains of Iron Furnaces, Cyfarthfa Ironworks (GM425), the proposed development has the potential to impact significantly on the setting of the scheduled monument. The setting of this scheduled monument should be considered as a key planning issue. The demolition and construction of new units on the existing retail site to the south of the A4102 road is largely a like-for-like replacement; in Cadw’s opinion this aspect of the proposed development has a neutral impact on the setting of the scheduled monument.

The situation is more complex for the new proposed development to the north of the A4102 road. Given the scale of the proposed development and the size and character of the scheduled monument, the impact on the setting of the monument must be considered in the light of views across the site, as well as close and medium distance views of the scheduled monument.

The scheduled part of the top of the furnace bank comprises of grassland and trees. Views across the site are open, with intermittent screening from trees. There is an existing line of close set trees that acts as a partial screen between the development site and the scheduled area. The scheduled monument area is long, thin and curvilinear in shape being aligned roughly N-S. The close proximity of the proposed development to the scheduled monument on the western side would create an unfortunate visual juxtaposition between the monument and the development when viewing across the monument from either the south end northwards or vice versa. The applicant has endeavoured to mitigate the visual impact of the development by locating the buildings along the western edge of the development area away from the scheduled monument and by the introduction of wooden cladding and grass-covered roofs. However, the building range, car park and additional ancillary features such as street lights would represent a significant visual intrusion alongside the scheduled monument. It is Cadw’s opinion that more could be done to reduce the visual impact of this part of the development on the scheduled monument; a reduction of the visual impact on views across the scheduled monument would make the proposed development more acceptable.

In terms of close distance views, there is a significant difference in level between the (upper) development site and the (lower) ground to the east of the scheduled area (that part formally occupied by foundries and casting houses etc.). As indicated in the supporting Environment Statement the proposed development would not be visible from the Taff Trail below the monument as the sheer, tall, face of the furnace wall would block the view. Similarly, the close distance view of the scheduled monument from the northern part of the proposed development site would not be significantly affected, as the furnace bank wall is east-facing and views across the site eastwards would not be obscured.

In Cadw’s opinion, the principal medium distance view that requires close attention is that from the terrace of and Park. This presents a critical view of the scheduled monument. From here the great elevation of the furnace bank is visible, together with horizontal bands of vegetation and domestic dwellings above. The construction of the new B&Q building range would be readily visible from this location and the building range’s large form and bulk would dominate the view, much as the existing retail development dominates the view of the charging ramp, despite efforts to screen it with trees. The large glazed entrance, with a potential for reflected glare, presence of illuminated signage and glare from lamp posts are also of concern here.

The scheduled monument is not readily visible in the medium distance views from the west ( and Gellideg). Similarly, the medium distance views from the south and east are either obscured or viewed against an existing urban landscape.

Given these facts, it is the opinion of Cadw that the proposed development would have a significant negative visual impact on the setting of the scheduled monument, particularly in terms of medium distance views across the monument and from Cyfarthfa Castle. This impact should be treated as a material consideration and one on which Cadw has significant concerns. These concerns could be mitigated by adopting a more concerted and thoughtful effort to reduce the visual impact of the east- facing elevation of the proposed new B&Q building range on the setting of the scheduled monument.

Cyfarthfa Castle registered historic park and garden

The proposed development is located on the west side of Merthyr Tydfil, in two areas separated by Swansea Road. To the south is the Cyfarthfa Retail Park. Here the existing east range of retail units (chiefly B & Q) would be demolished and replaced by six new retail units. There would be some reconfiguration of the adjacent car park and associated new landscaping. To the north of Swansea Road is a level area of rough grass, scrub and some boundary trees. This is the second area of development, the former Thorn Electricals site, to which a new B & Q would be relocated, together with two other retail units. Associated development would include car parking, landscaping and a heritage trail.

It is the view of Cadw that the redevelopment of part of the Cyfarthfa Retail Park, to the south of Swansea Road, would be neutral in terms of its direct and indirect impact on the setting of and significant view from the park and garden of Cyfarthfa Castle. Cadw therefore has no concerns about this part of the development.

The Cyfarthfa Retail Park is situated to the south-south-west of Cyfarthfa Castle, on the opposite (west) side of the Taf valley, to the south of the former ironworks site. The east side of the retail park is visible from parts of the park and garden, although mature trees within the park and garden screen it from most areas. It is partially visible from the terrace in front of the castle and the garden to its east. These are the most sensitive parts of the garden in terms of their setting and views from them. However, the retail park, although unsympathetic in form and massing to the setting and views, appears as a distant feature that does not visually dominate.

The proposed retail units would more or less occupy the footprint of the present units, along the east side of the retail park, visible from parts of the park and garden of Cyfarthfa Castle. In terms of design and massing the new units would be very similar to the present ones. The only significant difference would be the additional height of the southernmost unit (Marks & Spencer). However, when viewed from the park and garden of Cyfarthfa Castle this would be a relatively minor change in the distant view. It is Cadw’s view that so long as the new units, and particularly the higher southern end, are designed so as to be visually recessive in views from Cyfarthfa Castle, they would not adversely affect the park and garden's setting and views as they now stand. New car parking arrangements and landscaping would not be visible from the park and garden.

The second part of the development, the former Thorn Electricals site to the north of Swansea Road, is a similar distance from Cyfarthfa Park and at a similar height to the Retail Park development site. However, it is further north and lies exactly on the designated Significant View south-westwards from the castle terrace. It therefore has potential to have an adverse indirect effect on the designated historic park and garden. The Significant View is the most important view from the park and garden. It establishes the strong, historic visual link between Cyfarthfa Castle and the ironworks which lie immediately to the north-east of the former Thorn Electricals site. This important visual link remains today, even though the ironworks are long since abandoned. There are no large-scale, unsympathetic modern intrusions into the view, in which the ironworks do and should remain dominant. The developer's Environmental Impact Assessment (EIA) assesses the visual receptors at Cyfarthfa Castle as 'high' and Cadw would agree with this assessment.

The proposed development of the former Thorn Electricals site would introduce a large, modern, warehouse-type building into this view. This would be situated along the western side of the site, with the car park to the east and screening planting and a Heritage Trail on the east boundary. This layout is a sensitive approach to minimising the visual impact of a large-scale building into a visually significant area.

The visual effect on the view from Cyfarthfa Castle is analysed in section 7.6.129 and photomontage 3 of the EIA. Photoviewpoint 3 shows that intervening vegetation, both within the park and on the east boundary of the site, would screen and filter all but the upper part of the building from view from most of the park and garden. Mitigating planting on the east boundary of the site, together with the planting of the lower parts of the roof slopes as 'green' roofs, would help to minimise the potential adverse impact of the development on the Significant View from Cyfarthfa Castle. Cadw agrees with the conclusion of the EIA that the long-term impact would be 'low to moderate adverse'. Cadw therefore suggests that were this application to be recommended for approval conditions be attached to ensure that these two mitigating measures are adopted, that Cadw is consulted over the details of the proposed landscaping scheme and that a landscape management plan, as suggested by the EIA (section 7.6.136) be required.

The associated elements of the development of the former Thorn Electricals site would have no impact on the setting or views as they would not be visible from Cyfarthfa Castle's park and garden.

Merthyr Tydfil registered historic landscape.

The proposed development lies within the registered historic landscape of Merthyr Tydfil. This is largely a heavily industrialised landscape, most of whose development took place in the 19th century. The most important industrial features to remain from this era are the ironworks, situated to the south- west of Cyfarthfa Castle, with which they are strongly associated, both historically and visually (see park and garden section).

The redevelopment of the east side of the Cyfarthfa Retail Park would have a neutral effect on the historic landscape, as it would replace like for like, in terms of location, scale and design. Cadw therefore has no concerns with this part of the development.

The redevelopment of the former Thorn Electricals site, to the north, would introduce a large, warehouse-style building, car park and access road into a site that is at present open grassland, scrub and some boundary trees. It is Cadw’s view that so long as archaeological investigation of the area is undertaken prior to any development, the adverse effect on the historic landscape can be minimised.

The ASIDOHL2 analysis has calculated the direct impact of the development on the historic landscape as 'moderate' and Cadw would concur that the introduction of a large industrial building into this area would not have a significant adverse effect on the character of the historic landscape. This is an area that has long been industrialised, with buildings and industrial infrastructure on it. The new building would continue this historical use and would fit within the industrialised built envelope of Merthyr Tydfil.

Summary

The comments above outline Cadw’s advice on the impact of the development on designated historic assets which fall within Cadw’s remit as a consultee. The key issue for Cadw is the impact of the development on the historically significant view from Cyfarthfa Castle and Park to the scheduled Iron Furnaces of Cyfarthfa Ironworks. In this assessment greater weight is given to the impact of the development on the scheduled monument reflecting the clear policy on the protection of the setting of a scheduled monument in paragraph 6.5.1 of Planning Policy Wales compared to the less specific policy on the protection of Historic Parks and Gardens set out in paragraph 6.5.24.

Yours sincerely

R W KEVERN Arweinydd Tîm Gwaith Achosion / Casework Team Leader Diogelu a Pholisi/Protection and Policy