PLANNING STATEMENT

Land Off Heron Drive, Swansea Vale, Swansea

May 2021

Summary

Proposal: Full planning application for car sales dealership and associated works

Location: Land Off Heron Drive, Swansea Vale, Swansea

Date: May 2021

Project Reference: S21.119

Client: Sinclair Garages Port Talbot Limited

Product of: Asbri Planning Limited

Prepared by: Liam Griffiths | Planner

Approved by: Phil Baxter | Director

Disclaimer: This report has been prepared for the sole and exclusive use of client whom it was commissioned and has been prepared in response to their particular requirements and brief. This report may not be relied upon by any other party.

The Contracts (Rights of Third Parties) Act 1999 shall not apply to this report and the provisions of the said Act are expressly excluded from this report. This report may not be used for any purpose other than that for which it was commissioned. This report may not be reproduced and/or made public by print, photocopy, microfilm or any other means without the prior written permission of Asbri Planning Ltd. The conclusions resulting from this study and contained in this report are not necessarily indicative of future conditions or operating practices at or adjacent to the Site. Much of the information presented in this report is based on information provided by others. That information has neither been checked nor verified by Asbri Planning Ltd.

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 2 Contents

Section 1 Introduction 4

Section 2 Site description and context 6

Section 3 Proposals 12

Section 4 Supporting documents 14

Section 5 Planning policy context 19

Section 6 Appraisal 26

Section 7 Conclusion 33

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 3 Introduction

1.1 This planning application has been prepared on behalf of Sinclair Garages Port Talbot Limited for the proposed full planning application for a car sales dealership and associated works at Land Off Heron Drive, Swansea Vale, Swansea.

1.2 Pre-application discussions have taken place with Swansea LPA within which it was confirmed that it is considered in principle that the proposed use would have some merit and would not conflict with the general thrust of LDP Policies which seek to retain employment land for appropriate uses. While the proposed car dealership use (Unique Use Class) does not fall within the B1 or B2 use classes it is a business/commercial regional employment opportunity in the Riverside Business Park.

1.3 The planning application comprises the following set of drawings:

Drawing name Drawing reference Site Location Plan 5989_001 Proposed Site Plan 5989_101 Existing Site Plan 5989_100 Proposed Ground Floor Plan 5989_200 Proposed Roof Plan 5989_201 Proposed Elevations 5989_300 Proposed External Details 5989_401 Proposed Visuals 5989_402 Proposed Drainage Strategy C1755 C-001 Soft Landscape Proposal 1121.01

1.4 In addition, the following supporting documents are submitted.

Document Prepared by Planning application forms (1APP) Asbri Planning Design and Access Statement Taylor Design Architects Planning Statement Asbri Planning Ecology Report Bay Ecology Tree Report Treescene SI Report Integral Geotechnique Energy Statement Transport Statement Corun Road Safety Audit J Bartlett Amenity Statement and GI Strategy DP Landscape Architecture Landscape Management Plan DP Landscape

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 4 Architecture FCA JBA Runoff Rates Micro Drainage Surface Water Calculations Micro Drainage

1.5 The statement takes the format of an overview of the site and its surroundings at section 2. Section 3 discusses the proposals and section 4 provides a summary of the supporting documents. Section 5 includes a full review of relevant planning policy with this then used to appraise the development proposal at section 6 with the document concluding at section 7.

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 5 Site description

General location 2.1 The application site is located within Swansea Vale an area approximately 5km to the north east of Swansea City Centre. The area is predominantly characterised by industrial and light industrial uses. The site is located to the east of the A4067 adjacent the River Tawe which sits to the west. The site is centred on grid coordinates E: 267734, N: 198640.

The site 2.2 The site is comprised of undeveloped land that is largely characterised by scrub. The site has been partially cleared to facilitate the development in accordance with the ‘Sensitive Vegetation Clearance Strategy’ prepared by Bay Ecology. The site contains a range of existing landscape features including groups of trees and scrub along the north and west boundaries and areas of scrub and rough grassland along the east and south boundaries. The development area within the site has been largely cleared but 4 groups of trees & scrub remain. The northern boundary is formed by the highway Swansea Vale, eastern boundary by Heron Drive and southern boundary by Moorhen Close. The western boundary comprises national cycle route 43. This route provides a green strip through the industrial section of the Swansea Valley to Swansea City Centre.

2.3 The NRW development advice maps show the site is located within flood zone C1 as such is served by significant infrastructure, including flood defences.

2.4 CADW mapping identifies there are no listed buildings within the site boundary or adjoining and none within close proximity to the site.

2.5 The Coal Authority maps show the site is located within a Coal Mining Reporting Area.

2.6 A review of the Swansea Local Development Plan proposals map shows the site is designated as Strategic Development Area (SD I). The LDP constraints map shows the site is located within flood zone 2 and 3.

Access 2.7 Whilst the site is currently undeveloped and as such has no formal vehicular access a bell mouth is located along the southern boundary off Moorhen Close.

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 6 2.8 The nearest bus stop to the site is located on the western side of the River Tawe along Sway Road approximately 600m from the site.

2.9 As discussed above the national cycle route 43 runs along the sites western boundary providing travel northbound to Clydach and southbound to Swansea City Centre.

Surrounding Area 2.10 The site is located within a strategic development area as defined by the LDP. The land to the east and south is comprised of employment uses and is predominantly offices.

Planning History 2.11 A Planning History search has been undertaken via the Council’s online planning explorer. The search highlighted two historic applications on the site comprising:

Application No. Description of Development Decision Date

92/0090 Mixed development for residen- Withdrawn 03 Feb tial, leisure, commercial, indus- 1995 trial, hotel and community usage (outline)

2008/0152 Construction of 8 no. two storey Withdrawn 27 Feb office blocks (Class B1) compris- 2013 ing of 19 separate units, associ- ated car parking and works

2.12 In accordance with the above, the site does not benefit from an extant consent. Accordingly, the forthcoming application should be determined in accordance with prevailing planning policy at a local and national level.

Pre-application Response 2.13 A pre-application enquiry was submitted to the authority on the 21st August 2020 and a response was received on the 8th October 2020 following a Microsoft teams meeting. The response is summarised in the relevant sections below:

The principle of the proposed use 2.14 LDP Policy PS4 sets out the Council's strategy for employment areas which includes retaining land for employment that is in active viable employment use and forms part of the employment land bank, including existing employment estates and business parks. This is supported by Policy RC10 which states that land in active, viable employment use is considered part of the County's employment land

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 7 bank and will be protected for B Class employment generating uses. The site is located within the Swansea Enterprise Park and is allocated within the LDP as part of a of a mixed-use strategic site – SD I: Swansea Vale.

2.15 LDP Policy SD I allocates land at Swansea Vale as a Strategic Development area for a comprehensive, residential led, mixed use development of circa 410 homes during the Plan period, and the completion of the Swansea Vale business park for commercial and employment use with 4 hectares of potential development areas that could accommodate appropriate B1 and B2 uses, with appropriate leisure uses. This site is designated as employment land in the LDP Concept Plan for Swansea Vale. One of the key placemaking principles set out in the policy is to provide regional employment opportunities within the existing Riverside and Central Business Park areas. While the proposed car dealership use (Unique Use Class) does not fall within the B1 or B2 use classes identified in Policy SD I, it is a business/commercial regional employment opportunity in the Riverside Business Park which Policy SD I seeks to support, subject to other planning considerations being satisfactory.

2.16 Having regard to the above factors, therefore, it is considered in principle that the proposed use would have some merit and would not conflict with the general thrust of LDP Policies which seek to retain employment land for appropriate uses.

Place Making and Visual Amenity 2.17 Within the Swansea Vale Development Strategy one of the aims for the Riverside Business Park is “To develop as a high-quality business park, capitalising on the strategic waterside location and new business-district hub”. The Strategy also includes a “Mood Board” for industrial units that could provide assistance when designing the buildings.

2.18 While this arrangement would accord with the requirement within the SD I concept plan to include active frontages onto the main spine street, it is clear from streetview images that the spine street is heavily landscaped including structural tree planting that, together with the lower level of the site, would effectively screen the development from Swansea Vale/Blawdd Road. On this basis it is recommended that the orientation of the building should be turned through 90 degrees to have its main frontage onto Heron Drive. The SD I concept plan also indicates that an outward facing edge onto the protected open space should be included and this requirement should also be incorporated into the scheme.

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 8 2.19 The layout of the development is also a significant concern with the site covered in extensive areas of hard landscaping with very little soft landscaping and the SuDS features pushed to the periphery of the site. As it stands the indicative layout would not be in accordance with the Council’s placemaking and green infrastructure policies. It is also noteworthy that the council’s drainage engineer indicated that the indicative layout may not accord with SAB requirement.

2.20 In order to address these concerns there needs to be an integrated landscaping and drainage strategy for the site. Good quality landscaping is an integral part of the vision for the Business Park and, given the site adjoins the River Tawe, it will be necessary to retain and enhance both the river corridor and provide connectivity to landscaped areas outside of the site and well as within the site itself.

Residential Amenity 2.21 There are no residential properties in proximity to the site that would be materially affected by the proposed development as such the proposals would not raise any significant concerns in this respect.

Access and Highway Safety 2.22 The introduction of a new vehicular access on Heron Drive would need to be accompanied by a stage 1 Road Safety audit undertaken by an appropriate third party. Highways have further advised that the size of the development is such that a full Transport Assessment (TA) should be provided. The access works would need to be undertaken under agreement by the Highways Authority and as part of that agreement a Construction Traffic Management Plan would be requested. A Construction Method Statement would also be required. In principle, Highways consider the site may be suitable for the proposed car dealership subject to the above comments being positively addressed.

Land Instability 2.23 The Coal Authority have advised that part of the site falls within the defined Development High Risk Area. In accordance with the approach agreed with the Local Planning Authority, the applicant will need to provide a Coal Mining Risk Assessment Report to accompany any formal planning application for the above development.

Flood Risk 2.24 The site is located within a C1 flood zone within the Development Advice Maps produced by NRW. The proposed use would be regarded as less vulnerable development under TAN 15: Development and Flood Risk. Notwithstanding this, in order to fully understand and address the potential flood risk to the site and any associated increase in flood risk elsewhere arising from the proposed

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 9 development, any planning application would need to be accompanied by a flooding consequences assessment (FCA) to be completed in accordance with the advice provided within TAN 15.

Drainage 2.25 The pre-application has been accompanied by a drainage strategy and, as indicated above, this strategy is unlikely to comply with SAB requirements. It is understood that you are seeking pre-application advice from the SAB in order to address these concerns. You are reminded that SuDS must form an integral part of the landscape and green infrastructure strategy at the site in order to comply with LDP Policies.

Ecology 2.26 In terms of ecology, this extensive site is covered in scrub vegetation and is located adjacent to the Tawe Corridor SINC, therefore, any planning application would need to be accompanied by a Preliminary Ecological Assessment (PEA). This should include an assessment of the potential of the proposal to impact on protected species and determine the need for any further surveys. The PEA should be carried out by a qualified and experienced ecologist with the relevant protected species licenses. In addition, mitigation measures and ecological enhancement proposals must be included in the PEA.

2.27 The tree officer has advised that the site appears to be covered in scrub and pioneer species. Any significant trees would need plotting on a plan in accordance with BS5837:2012. To mitigate tree loss the proposed site should look to integrate tree planting into the required SuDS measures.

S106 2.28 Appendix 3 to the LDP ‘Allocated Site Requirements and Informatives’ sets out the likely requirements for developments within SD I. A review of these requirements indicates that on and off- site transport measures may be required to facilitate the development, potentially including, but not limited to, the following:

- Transport Measures Priority Schedule Measures: RM20 and RM27. - Active Travel Priority Schedule Measures: AT30, AT31, AT32, AT33, AT34 and AT35. - Public Transport Priority Schedule Measures: Llansamlet Park and Ride. - Issues highlighted in Policy SD I Swansea Vale. - Small scale measures highlighted in the Swansea Strategic Transport and Development Study (ARUP study) include: - Peniel Green Roundabout (Jn 44). - Clase Road/A4067 Roundabout.

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 10 - Bethel Road/Peniel Green Road.

Documents required to support any subsequent application 2.29 List of documents:

- Completed application forms; plan, elevation and section drawings with accurate levels - Preliminary Ecological Assessment - Phase 1 Site Investigation - Coal Mining Risk Assessment - Transport assessment - Tree Survey - Energy Statement - Waste Management Strategy - Green Infrastructure Strategy - Design and Access Statement - Statutory Pre-application Consultation Report

Conclusion 2.30 In conclusion, while the principle of the proposed development is considered to be acceptable, there is a significant concern that the indicative proposals fall short of the placemaking and green infrastructure requirement set out within LDP Policies and PPW. Moreover, there are a number of technical constraints that will need to be considered further including flooding, land instability, ecology, drainage and highway safety. These technical constraints will require the submission of further information as set out above.

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 11 Proposals

3.1 The proposal comprises a car sales showroom to operate as a flagship Jaguar / Land Rover dealership. The existing Jaguar / Land Rover dealership, located at Enterprise Park, Valley Way is no longer fit for purpose. With no realistic opportunities to expand. Accordingly, a larger site is sought in order to provide a flagship dealership to serve Swansea and West Wales.

3.2 In recent years, under the previous ownership, the site was one of the worst performing Jaguar Land Rover businesses in the UK. Whilst the site has improved since the group’s purchase, it is still the worst performing business in the Sinclair group. This is significantly down to the difficulties operating on the current site and as such presents ongoing risks for the long-term viability of the brand and the future employment on that site.

Layout 3.3 The proposals are shown on the proposed site plan and largely comprise:

▪ Erection of main showroom ▪ New valet facility and service centre / workshop. ▪ Outdoor car display area ▪ Feature display of vehicles area. ▪ Customer parking ▪ Staff, Demonstrator, Compound and Group Storage parking ▪ Cycle Parking ▪ Refuse areas and soft landscaping including SUDS features

3.4 The site will be utilised for the purposes of car sales. Accordingly, a sui generis use is required. Vehicular and pedestrian access is proposed via two points, Moorhen close and Heron Drive.

Site Operation 3.6 Once operational, the dealership will result in the creation of circa 100 jobs. It is acknowledged that the proposed use would not comprise a traditional B Class employment use, however, the economic benefits in the form of job creation far outweigh the majority of Class B operations which could utilise the site within the boundaries of its policy allocation.

3.7 There are around 65 members of staff within the present facility and these are jobs that would be lost if the facility closes. The proposed facility is likely to employ in the region of 100 members of staff. The

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 12 project is therefore vital in safeguarding existing positions and the creation of 35 additional jobs.

3.8 Though a large number of vehicles will be displayed at the site, it should be noted that the majority will be delivered on large scale car transporters. Actual vehicle movements to and from the site on a day-to-day basis will be limited.

3.9 The parking levels proposed are based on the extensive experience of Sinclair Group and the existing Jaguar / Land Rover operations within the City.

Green Infrastructure 3.10 As part of the landscape scheme, a series of swales and detention basins are proposed. The landscape proposals embrace the inclusion of these SUDS features and aims to maximise their potential amenity benefits. Areas of long grass and wildflower meadow are also proposed as part of the SUDS system. The proposed mixes contain a range of flowering species which add to the amenity and attract endangered species such as bees and butterflies.

3.11 Due to the nature of the proposed development, a large amount of parking and hardstanding is required. Therefore, the remaining soft landscaped areas will need to work very hard in order to meet the GI objectives. The site benefits from its location adjacent to 2 existing wildlife corridors with the densely vegetated Swansea Vale route immediately to the north and the ecologically rich River Tawe corridor to the west. These will be retained, enhanced and protected with new buffer zones, where possible so that new Green Infrastructure can connect directly with the wider ecological network. This will be achieved by introducing enhanced landscape areas and a series of GI links though the site and along the Heron Drive and Moorhen Close boundaries.

3.12 The landscape design includes a range of GI features for the benefit of people and wildlife. These include native tree planting to improve amenity as well as providing summer shade and a food source for wildlife. Native hedging is proposed along the west boundary. This will soften the appearance of security measures and provide ecological habitat and nesting opportunities for birds. Consideration has been given to green roofs, however this has been discounted due to the space on the roof being required for photovoltaics [PV].

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 13 Supporting documents

4.1 The following section intends to provide a brief overview of the supporting documents and reports which have been prepared to accompany the planning application for the proposed development.

Amenity Statement & GI Strategy 4.2 DP Landscape architecture have completed an amenity statement and GI strategy for the proposed development. This provides a summary of how the sites GI is interconnected and developed within the proposal. Due to the nature of the proposed development, a large amount of parking and hardstanding is required. Therefore, the remaining soft landscaped areas will need to work very hard in order to meet the GI objectives. The five principles of Green Infrastructure have been used as a guide to inform the landscape design to ensure the landscape maximises the benefits to people and wildlife.

▪ Multi-functional ▪ Adapted for Climate Change ▪ Healthy ▪ Biodiverse ▪ Smart & Sustainable

4.3 Each principle is discussed within the report and overall it is concluded that the successful establishment of the landscape design for the site will provide a network of healthy, multi-functional and biodiverse green spaces, capable of delivering a wide range of environmental and quality of life benefits for people and wildlife.

Ecology 4.4 Bay Ecology have undertaken an ecological appraisal of the site. This comprised a desk study and field work undertaken on the 11th August 2020. The desk study identified that the Tawe Corridor Site of Importance for Nature Conservation (SINC) was located immediately west and east of site. However, the SINC was segregated from site by a cycle path to the west and Heron Drive to the east. Due to the nature of the habitats onsite, physical separation and limited hydrological connectivity between the site and the designation it was considered that any development would have no adverse impact upon them. The desk study identified no records of protected species onsite.

4.5 The site is comprised of a limited range of habitat types predominantly comprised of a limited range of habitats dominated by scrub, poor semi-improved grassland with areas of marshy grassland bordered by a corridor of broadleaf plantation to the west

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 14 of site, a treeline & species poor hedgerow located to the north and an earth bund to the south and east. In terms of the ecological importance of the site the scrub and grassland were of limited botanical interest. However, were considered to be of ecological interest on a local context and were likely to be utilised by a variety of species such as birds, foraging & commuting mammals, amphibians and potentially common reptile species. The more mature boundary woodland located to the west and treelines and species poor hedgerows to the north were of local ecological interest and should be retained where practicable and retained as dark wildlife corridors for commuting mammals and birds.

4.6 The proposed development will result in the loss of the small areas of semi-improved & marshy grassland. However, this habitat loss will be mitigated/offset by the creation of the western boundary SUDS that will include swales and attenuation basins, which will be seeded by 'RE3 River Floodplain / Water Meadow’ mix. The grassland & scrub habitat was considered potentially suitable to support small isolated populations of common reptile species. However, the site represents a relatively isolated feature with limited connectivity along the River Tawe riparian corridor. To facilitate ground investigation and topographical works onsite Bay Ecology produced a sensitive vegetation clearance strategy with regards to the potential presence of common reptile species. During the watching brief no common reptile species were identified during the hand searches of refugia and vegetation. The proposed development layout will create reptile hibernaculum (log piles) along the western boundary in close proximity to the boundary woodland and SUDS.

4.7 The woodland and scrub were considered suitable habitat for breeding birds and it is recommended that these features be retained where practicably possible to maintain these resources. Given the likelihood of birds utilising the woodland and scrub, any proposed site clearance works should be undertaken outside the bird-breeding season (i.e. clearance between September and March inclusive) or preceded by a visual check for nesting birds. Japanese Knotweed was identified onsite and is classed as ‘controlled waste’ and as such it and any soil containing rhizomes must be disposed of safely at a licensed landfill site.

Tree Survey 4.8 A tree survey has been completed by Treescene the survey entailed a visual inspection from ground level of all trees. Trees T7, T8, T11, T14, T25 and T26 are recommended for removal in the Tree Survey due to poor quality (U category). Trees G1 (part), T2, G3 (part), T10, T12, G13, G15, G16, G17 (part), G20 (part), G28, G40, T56, T60, G62, G63 and G64 are proposed for removal to accommodate the development

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 15 layout. These are all C category trees (low quality). Tree loss in relation to the development focuses primarily in the clearance of low quality trees in the interior of the site to create space to accommodate the development. The existing robust tree belts on the northern and western boundaries of the site are retained thus minimising any wider landscape impacts.

Transport Statement 4.9 A transport statement has been produced by Corun to examine the highway and transportation issues associated with a proposed car showroom. Customer vehicular access to the site is proposed via a new priority junction with Heron Drive. The junction will be constructed under a S278 Agreement, subject to planning. The new customer access along Heron Drive is proposed at a point approximately 70m south of the Riverside Business Park access junction with the B4625, and approximately 65m north of the roundabout junction between Heron Drive / Moorhen Close / Mallard Way. The location of this new junction would therefore allow this MfT visibility distance to be achieved in both directions.

4.10 Vehicle access for service, delivery, and car transporting requirements will be provided through the existing priority junction with Moorhen Close. As it is currently blocked off at the junction with Heron Drive, Moorhen Close will be opened, and the existing carriageway and footways refurbished to facilitate access to the site. Swept path analysis for a max legal 16.5m articulated vehicle accessing the proposed site from Moorhen Close is shown in Appendix A of the TS.. This shows that there is sufficient room for a vehicle of this size to manoeuvre within the site, and safely enter and exit the site in a forward gear.

4.11 The development proposal includes a total of 399 parking spaces, made up of 34 customer parking spaces, 2 (6%) for disabled customers, 2 (6%) parent and child spaces, and 4 (12%) electric vehicle charging spaces. The remaining 365 spaces are allocated to external used display parking (74 spaces) demonstrator parking (16 spaces) compound parking (177 spaces) compound disabled parking (2 spaces) and group storage parking (96 spaces). Staff and servicing parking will be provided within the group storage area (96 spaces). A total of 6 cycle stands are included, which is more than the required standard. To promote the use of electric vehicles to the site, four electric vehicle-charging parking spaces are included within the proposals.

4.12 With the proposed development being located in an already established business park area, and the majority of the proposed development trips expected to route along both the B4625 Swansea

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 16 Vale and A4067 dual carriageway roads, it is concluded that the proposed development will have a minimal impact on the surrounding highway network.

Road Safety Audit 4.13 This report results from a Stage 1 Road Safety Audit undertaken by J Bartlett Consulting Limited. This Safety Audit considers the introduction highway works associated with the development of a car retail site off Heron Way Llansamlet. Proposals include the opening of an existing access off Moorhen Close as well as the introduction of a new Give Way access to Heron Way.

FCA 4.14 An FCA have been produced by JBA consulting as the site is located within flood zone C1. Less vulnerable development can take place within Zone C1 subject to the application of the Justification Test, including a demonstration of the acceptability of the flood consequences. The proposal meets the justification tests set out in table 3-2 of TAN:15. Detailed flood modelling, undertaken in 2019, shows that the site is flood free during the 1% AEP event with an allowance for climate change. During the 0.1% AEP event, the site is predicted to flood to depths of over 1m. An assessment of third party impacts as a result of the development has been undertaken and demonstrates that the result of ground raising across the site has a negligible impact on flood depths off-site. An assessment of the Justification Test and Acceptability Criteria has been undertaken, with all aspects found to be satisfied for the site.

Energy Statement 4.15 This report provides an overview of the design approach which aims to reduce energy consumption and carbon emissions. It has been the intention from project conception to create a building that reduces carbon emissions by passive measures through specifying building elements with high performing U-Values and through using low energy building services that go beyond minimum Building Regulations Part L requirements.

SI Report 4.16 Intégral Géotechnique (Wales) Limited have been appointed as the Geotechnical Engineers to undertake a geoenvironmental and geotechnical desk study of the site. Prior to redevelopment of the site, a comprehensive intrusive site investigation would be required, over the entire site, in order to facilitate a detailed technical and financial appraisal. This would enable the foundation and hardstanding design for any proposed development to be developed using specific data on the ground conditions and enable more accurate costings to be made.

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 17

Design & Access 4.17 A Design and Access Statement has been submitted in support of the application. The statement was prepared by Taylor Design Architects and explains the various facets of design and access in relation to the site alongside outlining planning policy relevant to the proposal. The statement also explains how the proposal complies with the 5 principles of good design identified in TAN12.

Landscape Management Plan 4.18 This document has been produced as a guide for the implementation, maintenance and management of the soft landscaped areas.

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 18 Planning policy context

Introduction 5.1 The planning policy framework for the determination of this application is provided by the content and scope of national planning guidance, together with the Swansea Local Development Plan.

Planning Policy Wales 5.2 National planning policy is contained within the 11th edition of Planning Policy Wales (PPW), published by the Welsh Government in February 2021. PPW is supported by 21 topic-based Technical Advice Notes (TANs), which are also relevant. PPW is the Welsh Government’s principal planning policy document, setting out the context for sustainable land use planning policy, within which Development Plans are prepared and development.

5.3 The primary objective of PPW is to ensure that the planning system contributes towards the delivery of sustainable development and improves the social, economic, environmental and cultural well-being of Wales, as required by the Planning (Wales) Act 2015, the Well- being of Future Generations (Wales) Act 2015 and other key legislation. PPW and future wales set out how the planning system at a national, regional and local level can assist in delivering these requirements through Strategic Development Plans (SDPs) and Local Development Plans (LDPs).

5.4 Sustainable development is defined as:

“Sustainable development” means the process of improving the economic, social, environmental and cultural well-being of Wales by taking action, in accordance with the sustainable development principle, aimed at achieving the well-being goals. Acting in accordance with the sustainable development principle means that a body must act in a manner which seeks to ensure that the needs of the present are met without compromising the ability of future generations to meet their own needs. “

5.5 Up-to-date development plans are the basis of the planning system and set the context for rational and consistent decision making. Plans at all levels of the development plan hierarchy must be prepared in accordance with national planning policies. Planning applications must be determined in accordance with the adopted plan, unless material considerations indicate otherwise.

5.6 In achieving the objectives of PPW and accompanying Acts, the use of previously developed land (when suitable for development) is

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 19 preferred to greenfield land. Paragraph 3.55 states; “In settlements, such land should generally be considered suitable for appropriate development where its re-use will promote sustainability principles and any constraints can be overcome.”

5.7 Further to the above, Paragraph 3.56 states; “Planning authorities should work with landowners to ensure that suitably located previously developed sites are brought forward for development and to secure a coherent approach to their development.”

Economic Development 5.8 Paragraph 5.4.1 states that “the planning system should ensure that the growth of output and employment in Wales as a whole is not constrained by a shortage of land for economic uses.”

5.9 In accordance with the above, Paragraph 5.4.4 emphasises that planning authorities, wherever possible, “should encourage and support developments which generate economic prosperity and regeneration.”

5.10 The importance of evidence-based decision making is stressed in Paragraph 5.4.7; “development plans and development management decisions should be based on up-to-date local and sub-regional evidence.”

5.11 PPW highlights that the most effective form of planning for the economy requires “planning authorities to work strategically and co- operatively directing development and investment to the most efficient and most sustainable locations, regardless of which local authority area they are in.”

Future Wales the National Plan: 2040 5.12 Future Wales – the National Plan 2040 is our national development framework, setting the direction for development in Wales to 2040. It is a development plan with a strategy for addressing key national priorities through the planning system, including sustaining and developing a vibrant economy, achieving decarbonisation and climate resilience, developing strong ecosystems and improving the health and well-being of our communities.

Well-being of Future Generations (Wales) Act 2015 5.13 The Well-being of Future Generations (Wales) Act came into force in 2015 and seeks to improve the social, economic, environmental and cultural well-being of Wales. The Act puts in place seven well-being goals in order to make sure that everyone works towards the same vision.

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 20 Technical Advice Note 23: Economic Development (2014) 5.14 TAN 23 defines economic development broadly so that it can include any form of development that generates wealth, jobs and income.

5.15 Paragraphs 1.2.1-2 highlight that the economic benefits of proposals and market needs should be fully considered when determining planning applications:

1.2.1 - The economic benefits associated with development may be geographically spread out far beyond the area where the development is located. As a consequence it is essential that the planning system recognises, and gives due weight to, the economic benefits associated with new development.

1.2.2 PPW advises that planning for economic land uses should aim to provide the land that the market requires, unless there are good reasons to the contrary. Where markets work well, this will help maximise economic efficiency and growth.

5.16 Further to the above, paragraph 1.2.5 states:

Local planning authorities should recognise market signals and have regard to the need to guide economic development to the most appropriate locations, rather than prevent or discourage such development.

5.17 Paragraph 2.1.5 states that where a planning authority is considering a site allocation or planning application that could cause harm to the environment or social cohesion, it should ask three questions in order to help clarity and balance the economic, social and environmental issues. These are:

Alternatives: If the land is not made available (the site is not allocated, or the application is refused), is it likely that the demand could be met on a site where development would cause less harm, and if so where? Jobs Accommodated: How many direct jobs will be based at the site? Special Merit: Would the development make any special contribution to policy objectives?

Swansea Local Development Plan 5.18 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires that planning application decision should be made in accordance with the authority’s adopted development plan, unless material considerations indicate otherwise. In this instance, the statutory development plan for this application site is provided in the

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 21 Swansea Local Development Plan (2010 – 2025). Swansea LDP comprises the principle documents against which applications are assessed. A review of the Swansea Local Development Plan proposals map shows the site is designated as Strategic Development Area (SD I). The LDP constraints map shows the site is located within flood zone 2 and 3.

5.19 The following LDP policies are considered relevant in the context of the proposed development:

Policy Relating to reference Strategic Policies SD1 Strategic Development Areas SD I Site Specific Policy for Swansea Vale PS2 Place Making and Place Management PS4 Sustainable Employment Strategy Environment policies ER2 Strategic Green Infrastructure Network ER6 Designated Site of Ecological Importance ER8 Habitats and Species Ecological Networks and Features of Importance ER9 for Biodiversity ER11 Trees, Hedgerows and Development Energy policies Renewable and Low Carbon Energy Technology EU2 in New Development EU4 Public Utilities and New Development Regeneration Policies RC10 Employment and Enterprise Development RC12 Officer Development Resource Policies Water Pollution and the Protection of Water RP4 Resources RP5 Avoidance of Flood Risk RP7 Land Instability Sustainable Waste Management for New RP10 Development SI8 Community Safety Transport Policies T2 Active Travel Design Principles for Transport Measures and T5 Infrastructure T6 Parking

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 22 5.20 The site is located within a large allocation falling under Policy Strategic Development Area SD I. The Policy states:

Site I is allocated for a comprehensive, residential led, mixed use development of circa 410 homes during the Plan period, and the completion of the Swansea Vale business park for commercial and employment use with 4 hectares of potential development areas that could accommodate appropriate B1 and B2 uses, with appropriate leisure uses.

Development proposals should accord with the following Placemaking Principles and Development Requirements, which are depicted on the Concept Plan and which should be delivered in an appropriately phased manner and be formally tied into planning consents:

PLACEMAKING PRINCIPLES • Complete the Tregof Village development with further residential development and local centre co-located with the existing community hub. • Create new sustainable neighbourhood as an expansion of Llansamlet, comprising of a number of character areas, that integrates positively with the existing community, community facilities, Active Travel network and public transport facilities. • Provide sensitive infill within the Peniel Green community for a combination of residential development, convenience retail and locally focused business development opportunities. • Provide regional employment opportunities within the existing Riverside and Central business park areas. • Create a multifunctional Green Infrastructure network throughout the site, taking account of the need to create healthy communities, with a particular emphasis on creating a linear park within the site that facilitates Active Travel, retaining trees and strengthening existing hedgerows and including appropriate landscaping, habitat creation and community led food growing opportunities. • Provide a mix of higher densities at key points in the layout and around the Tregof local centre with lower densities on the rural/sensitive edges. • Protect, enhance and manage areas of priority habitats and greenspace, including the nature reserve and Llansamlet Ecology Park. • Developments should positively reflect local aspects of history and local character such as the setting of Llansamlet Conservation Area, setting of St. Samlet’s Church and route of Smiths canal.

DEVELOPMENT REQUIREMENTS • Internal spine street to run broadly North to South through the Llansamlet East development area from Walters Road to Blawdd

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 23 Road, with new roundabout junctions designed to provide appropriate flood free access in accordance with the requirements of TAN 15 Development Flood Risk (2004). • Off-site highway infrastructure improvements as necessary, having regard to requirements arising from the necessary Transport Assessment and detailed transport modelling and the Transport Measures Priority Schedule. • On and off-site measures to provide good quality, safe and attractive walking and cycling routes both to and within the site in accordance with Active Travel Design, including the linkages set out in the Transport Measures Priority Schedule Refs AT 31-east to west Green Corridor link, AT32, AT33, AT34, and off-site Active Travel route to Llansamlet Railway Station and Park and Ride. • Provision of a new Park and Ride facility at Llansamlet. • Provide contributions for existing Primary and Secondary Schools in the catchment area. • Provide a major east west Green Corridor with new and retained trees and hedgerows, appropriate new landscaping, formal and informal play provision, and Active Travel. • Developers will have regard to the risks of flooding and any necessary flood mitigation and resilience measures in the design of new development. • Enabling works to mitigate the effects of flood risk from the Nant Bran and associated watercourses on the eastern side of Swansea Vale (Llansamlet East). • Protect, enhance and manage the Llansamlet Nature Reserve and Llansamlet Ecology Park and manage invasive species across the area in accordance with agreed management plans. • On and off-site measures including any appropriate upgrades to the clean water supply or public sewerage networks.

5.21 The below map shows preferred uses for individual parcels of land. The site is identified as suitable for employment purposes:

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 24

Supplementary Planning Guidance 5.25 The following SPG are relevant to the proposal:

• Parking Standards (Adopted March 2012) • Swansea Vale Development Strategy (2012) • The Protection of Trees on Development Sites (October 2016)

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 25 Appraisal

Overview 6.1 This section aims to identify the main issues relevant to the determination of the application and assess the scheme against the relevant planning policy framework. These matters are considered to be as follows:

• Principle of Development • The location of the site within flood zone C1 • The impact on the character and appearance of the area • The impact with regard to residential amenity • The impact with regard to Access and Highways • The Impact with regard to Biodiversity • Other material considerations

Principle of Development 6.2 With regard to the principle of development the site is located within Strategic Develop Area SD(I) – Swansea Vale. Site I is allocated for a comprehensive, residential led, mixed use development of circa 410 homes during the Plan period, and the completion of the Swansea Vale business park for commercial and employment use with 4 hectares of potential development areas that could accommodate appropriate B1 and B2 uses, with appropriate leisure uses. Development proposals should accord with principles and requirements set out in policy SD(I).

6.3 This site is designated as employment land in the LDP Concept Plan for Swansea Vale. One of the key placemaking principles set out in the policy is to provide regional employment opportunities within the existing Riverside and Central Business Park areas. The application site is currently undeveloped and serving no purpose. It is identified as being suitable for development via its allocation in the LDP as part of a wider allocation for a range of uses.

6.4 The existing Jaguar / Land Rover dealership in Swansea is constrained and no longer fit for purpose. It is the intention to develop the site in order to provide a state-of-the-art car sales dealership. The end user will be Jaguar Land Rover and therefore the application is not speculative. Once operational, the dealership will employ 100 individuals in FTE positions – a significant economic benefit.

6.5 It is acknowledged in the pre-application response that While the proposed car dealership use (Unique Use Class) does not fall within the B1 or B2 use classes identified in Policy SD I, it is a business/commercial regional employment opportunity in the

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 26 Riverside Business Park which Policy SD I seeks to support, subject to other planning considerations being satisfactory. It is considered in principle that the proposed use would have some merit and would not conflict with the general thrust of LDP Policies which seek to retain employment land for appropriate uses.

The Location of the site within Flood Zone C1 6.6 As defined by the TAN:15 development advice maps the site is located within flood zone C1. Less vulnerable development can take place within Zone C1 subject to the application of the Justification Test, including a demonstration of the acceptability of the flood consequences. The proposal would be considered less vulnerable development. With regard to the justification tests set out in section 6.2 of TAN:15 the proposed complies with section ii as will help the authority to deliver their sustainable employment strategy set out in policy PS4. In terms of section iii whilst the proposal does not strictly comprise brownfield land it is land that has been cleared of much vegetation with infrastructure developed surrounding that informs the intention to develop the site as per the allocation within the LDP. Finally in relation to section iv the flood consequences have been assessed in the FCA produced by JBA submitted in support of the planning application.

6.7 In summary, the site is predicted to be flood free during the 1% AEP plus climate change scenario. When raising ground levels to an average of 10.7 mAOD, the site is predicted to flood to depths of up to 550mm during the 0.1% AEP event. This is within the tolerable limits as set out in A1.15 of TAN-15. There are negligible offsite impacts (an increase of up to 6mm to Moorhen Close and a flood storage area south of the site). It is therefore concluded that the site complies with the requirements of Planning Policy Wales and TAN- 15.

The Impact of the Character and Appearance of the Area 6.8 Within the Swansea Vale Development Strategy one of the aims for the Riverside Business Park is “To develop as a high-quality business park, capitalising on the strategic waterside location and new business-district hub”. The proposal is in keeping with this aim and will provide a contemporary car dealership that will be in keeping with the business park uses albeit not a B use. The pre-application comments received with regard to placemaking and visual amenity highlighted that the building could be orientated to front Heron Drive. The building has been reorientated to have its main frontage onto Heron Drive. The site protects the open space located to the sites western boundary as per the concept plan and retention of a strong band of trees along the western boundary for ecological reasons limits the opportunity to create an active frontage along this

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 27 elevation. As detailed within the green infrastructure strategy the existing green spaces will be retained, enhanced and protected with new buffer zones, where possible so that new Green Infrastructure can connect directly with the wider ecological network. When developing the site layout it was logical to locate SuDS and landscape features close to the western and northern boundaries to develop from the existing landscape whilst the eastern and southern boundaries front the business park and as such is a more natural progression.

6.9 As detailed within the pre-application response concerns were raised due to the nature of the proposal featuring extensive areas of hardstanding needed and that it would likely not be compliant with regard to SuDS. As part of the landscape scheme, a series of swales and detention basins are proposed. The landscape proposals embrace the inclusion of these SUDS features and aims to maximise their potential amenity benefits. Areas of long grass and wildflower meadow are also proposed as part of the SUDS system. The proposed mixes contain a range of flowering species which add to the amenity and attract endangered species such as bees and butterflies.

6.10 Consideration has been given to green roofs, however this has been discounted due to the space on the roof being required for photovoltaics [PV]. The provision of renewable technology is inline with both national and local policy requirements. Future Wales supports and helps deliver the aims of the Economic Action Plan. With a key objective being supporting a low carbon economy and the decarbonisation of industry, and the growth of sustainable and renewable energy. Furthermore the LDP has policy EU2 relating to Renewable and Low Carbon Energy Technology in New Development this identifies that development will be required to maximise the contribution of renewable or low carbon energy technology to meet the energy demands of the proposal, particularly for Significant Energy Consuming Developments. As such whilst the proposal does not provide a green roof the space is being used to ensure the development is resilient in the face of climate change. The green infrastructure included within the development proposal is not at detriment by the lack of green roof as the network being developed, as discussed above, is strong.

6.10 The proposal has therefore been developed to address concerns to ensure an integrated landscaping and drainage strategy for the site. The proposal will retain and enhance both the river corridor and provide connectivity to landscaped areas outside of the site as well as within the site itself. The building itself and wider site is reflective of the use and assimilates with the business park.

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 28

The impact with regard to Residential Amenity 6.11 There are no residential properties in proximity to the site that would be materially affected by the proposed development as such the proposals would not raise any significant concerns in this respect.

The impact with regard to Access and Highways 6.12 A transport statement has been produced by Corun to examine the highway and transportation issues associated with a proposed car showroom. Customer vehicular access to the site is proposed via a new priority junction with Heron Drive. The junction will be constructed under a S278 Agreement, subject to planning. The new customer access along Heron Drive is proposed at a point approximately 70m south of the Riverside Business Park access junction with the B4625, and approximately 65m north of the roundabout junction between Heron Drive / Moorhen Close / Mallard Way. The location of this new junction would therefore allow this MfT visibility distance to be achieved in both directions.

6.13 Vehicle access for service, delivery, and car transporting requirements will be provided through the existing priority junction with Moorhen Close. As it is currently blocked off at the junction with Heron Drive, Moorhen Close will be opened, and the existing carriageway and footways refurbished to facilitate access to the site. Swept path analysis for a max legal 16.5m articulated vehicle accessing the proposed site from Moorhen Close is shown in Appendix A of the TS.. This shows that there is sufficient room for a vehicle of this size to manoeuvre within the site, and safely enter and exit the site in a forward gear.

6.14 The development proposal includes a total of 399 parking spaces, made up of 34 customer parking spaces, 2 (6%) for disabled customers, 2 (6%) parent and child spaces, and 4 (12%) electric vehicle charging spaces. The remaining 365 spaces are allocated to external used display parking (74 spaces) demonstrator parking (16 spaces) compound parking (177 spaces) compound disabled parking (2 spaces) and group storage parking (96 spaces). Staff and servicing parking will be provided within the group storage area (96 spaces). A total of 6 cycle stands are included, which is more than the required standard. To promote the use of electric vehicles to the site, four electric vehicle-charging parking spaces are included within the proposals.

6.15 With the proposed development being located in an already established business park area, and the majority of the proposed development trips expected to route along both the B4625 Swansea Vale and A4067 dual carriageway roads, it is concluded that the

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 29 proposed development will have a minimal impact on the surrounding highway network.

The Impact with regard to Biodiversity 6.16 The site is comprised of a limited range of habitat types predominantly comprised of a limited range of habitats dominated by scrub, poor semi-improved grassland with areas of marshy grassland bordered by a corridor of broadleaf plantation to the west of site, a treeline & species poor hedgerow located to the north and an earth bund to the south and east. In terms of the ecological importance of the site the scrub and grassland were of limited botanical interest. However, were considered to be of ecological interest on a local context and were likely to be utilised by a variety of species such as birds, foraging & commuting mammals, amphibians and potentially common reptile species. The more mature boundary woodland located to the west and treelines and species poor hedgerows to the north were of local ecological interest and should be retained where practicable and retained as dark wildlife corridors for commuting mammals and birds.

6.17 The proposed development will result in the loss of the small areas of semi-improved & marshy grassland. However, this habitat loss will be mitigated/offset by the creation of the western boundary SUDS that will include swales and attenuation basins, which will be seeded by 'RE3 River Floodplain / Water Meadow’ mix. The grassland & scrub habitat was considered potentially suitable to support small isolated populations of common reptile species. However, the site represents a relatively isolated feature with limited connectivity along the River Tawe riparian corridor. To facilitate ground investigation and topographical works onsite Bay Ecology produced a sensitive vegetation clearance strategy with regards to the potential presence of common reptile species. During the watching brief no common reptile species were identified during the hand searches of refugia and vegetation. The proposed development layout will create reptile hibernaculum (log piles) along the western boundary in close proximity to the boundary woodland and SUDS.

6.18 The woodland and scrub were considered suitable habitat for breeding birds and it is recommended that these features be retained where practicably possible to maintain these resources. Given the likelihood of birds utilising the woodland and scrub, any proposed site clearance works should be undertaken outside the bird-breeding season (i.e. clearance between September and March inclusive) or preceded by a visual check for nesting birds. Japanese Knotweed was identified onsite and is classed as ‘controlled waste’ and as such it and any soil containing rhizomes must be disposed of safely at a licensed landfill site.

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 30 6.19 Biodiversity enhancmenets will be provided in the form of bat and bird boxes alongside the habitats created within the site from SuDS features and green infrastructure as shown by the landscape proposal.

6.20 A tree survey has been completed by Treescene the survey entailed a visual inspection from ground level of all trees. Trees T7, T8, T11, T14, T25 and T26 are recommended for removal in the Tree Survey due to poor quality (U category). Trees G1 (part), T2, G3 (part), T10, T12, G13, G15, G16, G17 (part), G20 (part), G28, G40, T56, T60, G62, G63 and G64 are proposed for removal to accommodate the development layout. These are all C category trees (low quality). Tree loss in relation to the development focuses primarily in the clearance of low quality trees in the interior of the site to create space to accommodate the development. The existing robust tree belts on the northern and western boundaries of the site are retained thus minimising any wider landscape impacts.

Other materials considerations Land Conditions 6.21 Intégral Géotechnique (Wales) Limited have been appointed as the Geotechnical Engineers to undertake a geoenvironmental and geotechnical desk study of the site. Prior to redevelopment of the site, a comprehensive intrusive site investigation would be required, over the entire site, in order to facilitate a detailed technical and financial appraisal. This would enable the foundation and hardstanding design for any proposed development to be developed using specific data on the ground conditions and enable more accurate costings to be made.

6.22 A Coal Mining Report for the site has been obtained from the Coal Authority and a copy is included in Appendix C. The Coal Authority states that “The property is in a surface area that could be affected by underground mining in 1 seam of coal at 190m to 210m depth, and last worked in 1870.” The Coal Authority does not caution the potential presence of unrecorded workings, beneath the site. The Coal Authority mining report confirms that “Within, or within 20 metres of, the boundary of the property there are 3 mine entries”. It is recommended that a soil stripping and trial trenching exercise is undertaken in order to confirm the location of Shaft Ref. 267198-011 and 267198-012 prior to development. The off-site shaft would not be considered as a risk to the development. A building exclusion zone should be allowed in the vicinity of the shaft features. Based on the available information it is considered that the site would not be at risk from shallow recorded or unrecorded workings and that further investigation would not be required.

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 31 Drainage 6.23 The proposed drainage strategy shows the intentions with regard to foul and SW drainage. The SW drainage strategy has been developed inline with statutory SuDS standard published by the Welsh Government. The proposal features two primary detention basins located along the western boundary with a network of conveyance channels, permeable paving and graving finish features throughout the areas for car parking. The foul drainage will connect to the existing DCWW network.

Energy 6.24 Policy EU2 requires non-residential developments with a total floorspace of 1000 sq m or more to submit a comprehensive Energy Assessment to determine the feasibility of incorporating low carbon or renewable energy installations into the scheme and/or connect to renewable or low carbon energy technology and district heating networks. Development will be required to maximise the contribution of renewable or low carbon energy technology to meet the energy demands of the proposal, particularly for Significant Energy Consuming Developments. An energy statement has been provides by D&d Consulting. It has been the intension from project conception to create a building that reduces carbon emissions by passive measures through specifying building elements with high performing U-Values and through using low energy building services that go beyond minimum Building Regulations Part L requirements. A roof mounted solar panel array is proposed which will supplement the electricity supply for the development.

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 32 Conclusion

7.1 This Planning Statement accompanies a planning application submitted on behalf of Sinclair Garages Port Talbot Limited for the proposed full planning application for a car sales dealership and associated works at Land Off Heron Drive, Swansea Vale, Swansea.

7.2 The existing Jaguar / Land Rover dealership, located at Enterprise Park, Valley Way is no longer fit for purpose. With no realistic opportunities to expand. Accordingly, a larger site is sought in order to provide a flagship dealership to serve Swansea and West Wales. Once operational, the dealership will result in the creation of circa 100 jobs. It is acknowledged that the proposed use would not comprise a traditional B Class employment use, however, the economic benefits in the form of job creation far outweigh the majority of Class B operations which could utilise the site within the boundaries of its policy allocation. There are around 65 members of staff within the present facility and these are jobs that would be lost if the facility closes. The proposed facility is likely to employ in the region of 100 members of staff. The project is therefore vital in safeguarding existing positions and the creation of 35 additional jobs.

7.3 The authority agrees in their pre-application response that While the proposed car dealership use (Unique Use Class) does not fall within the B1 or B2 use classes identified in Policy SD I, it is a business/commercial regional employment opportunity in the Riverside Business Park which Policy SD I seeks to support, subject to other planning considerations being satisfactory. Therefore, it is considered in principle that the proposed use would have some merit and would not conflict with the general thrust of LDP Policies which seek to retain employment land for appropriate uses.

7.4 The FCA demonstrates the proposal is compliant with regard to TAN:15 and the justification tests. Following the pre-application a significant review of the sites green infrastructure and SW drainage proposals was undertaken. Subsequent to this it is considered that the proposal now presents a strong green approach to the site making use of the existing green spaces north and west.

7.5 In terms of highways impact the proposal is supported by a Transport Statement the scope of which was agreed with the highway authority. This shows the proposal will be acceptable with regard to impacts on the highway network. The site is supported by ecology and tree surveys which shows any impacts can be readily mitigated for

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 33 through a sensitive approach to development and a scheme that has a strong green infrastructure network.

7.6 It is therefore considered that the proposal is compliant with policies each of the relevant policies highlight and as such accords with relevant national and local planning policy and guidance. It is therefore requested that Swansea Council’s Local Planning Authority grant planning permission accordingly.

LAND OFF HERON DRIVE | PLANNING STATEMENT PA G E | 34