Kays & Kears Industrial Estate, Blaenavon, Torfaen

KAYS & KEARS INDUSTRIAL ESTATE, BLAENAVON, TORFAEN PLANNING STATEMENT

Prepared by LRM Planning Limited on behalf of P & P Builders and Roofing Contractors Ltd

June 2021

Report Control

Project: Kays & Kears Industrial Estate

Client: P & P Building & Roofing Contractors Ltd

Job Number: 18.238

File Origin: 18.238/6. Report

Document checking

Primary author: Abi Hawke Initialled: AH

Review by: Sam Courtney Initialled: SC

Issue Date Status Checked for issue

No rev 10/06/20 Complete SC

Contents

1 Introduction ...... 3 2 Site description and context ...... 6 3 Proposed Development ...... 8 4 Planning Policy Framework ...... 10 5 Appraisal ...... 17 6 Conclusion ...... 22

1 Introduction

1.1 This Planning Statement (hereafter PS) accompanies a full application submitted on behalf of P&P Builders for the proposed works relating to a light industrial and office space development (B1, B2 & B8) within a plot of land to the west of Kays & Kears Industrial Estate, Blaenavon.

1.2 The application seeks consent for the construction of seven industrial units level varying between 6.7m and 8.5m in height. The site is designated for employment use in the LDP, under policy EET3. The proposals also include sustainable drainage proposals, landscape planting, car parking, cycle storage/parking, waste storage facilities and associated works.

1.3 The site comprises a parcel of land west of the existing Kays & Kears Industrial Estate and forms a part of a wider scheme which incorporates a parcel of land extending to the south-west. Notably however, this PS in line with the supporting application, focuses on the northern parcel of land.

1.4 This Planning Statement forms part of a suite of drawings and documents produced in support of the proposals. The Planning Statement and accompanying technical reports justify how the proposed scheme demonstrates the site’s suitability to accommodate the proposed development. The full suite of documents submitted comprises:

Document (reference if applicable) Prepared by

Planning application forms LRM Planning Planning Statement (June 2021) LRM Planning Design & Access Statement (June 2021 Childs Sulzmann Architects rev.A) Ecological Assessment (Feb 2021) Ecological Services Drainage Schematic (3264_100A) Blackburn Griffiths Transport Assessment (20085 d1 Rev C) Lime Transport Illustrative Landscape Strategy EDP (edp6922_d014-A) Landscape Visual Impact Assessment EDP (edp6922_r001-A) Archaeology and Heritage Assessment EDP (edp6922_r002-A) Phase 1 Geotechnical and Geo- Terra Firma Environmental Report (Mar 2020) Intrusive Coal Mining Risk Terra Firma Assessment Report (Feb 2021) Tree Constraints Plan Treescene

Tree Survey (Dec 2020) Treescene

1.5 The application is also supported by the following drawings prepared by Childs Sulzmann Architects:

Drawing Reference

Site Location Plan 20-570-001 Rev. B Existing Site Plan 20-570-005 Rev. B Proposed Site Plan 20-570-105 Rev. G GA Ground Floor Plan 20-570-111 Rev. G GA First Floor Plan 20-570-112 Rev. G GA Roof Plan 20-570-113 Rev. B Building B1 Plan 20-570-121 Rev. B Building B2 Plan 20-570-122 Rev. B Building B3 Plan 20-570-123 Rev. B Building B4 Plan 20-570-124 Rev. B Building B5 Plan 20-570-125 Rev. B Building B6 Plan 20-570-126 Rev. B Building B7 Plan 20-570-127 Rev. B GA Site Section A 20-570-201 Rev. A GA Site Section B 20-570-202 Rev. A GA Site Section C 20-570-203 Rev. A Building B1 Elevation 20-570-211 Rev. D

Building B2 Elevation 20-570-212 Rev. C Building B3 Elevation 20-570-213 Rev. D Building B4 Elevation 20-570-214 Rev. D Building B5 Elevation 20-570-215 Rev. D Building B6 Elevation 20-570-216 Rev. D Building B7 Elevation 20-570-217 Rev. D Proposed Visual 1 20-570-251 Proposed Visual 2 20-570-252 Proposed Visual 3 20-570-253 Proposed Visual 4 20-570-254

1.6 The following sections discuss the site and its context; the proposed development; a summary of pre-application discussions; planning policy context; followed by an appraisal of the development; and then offering a conclusion of the application submitted herein.

2 Site description and context

2.1 The subject site is roughly trapezoid in shape and measures approximately 1.5ha, comprising of remediated land, appearing as bare earth and scrub. An access road runs south of the Kays & Kears Industrial Estate from Estate Road towards the subject site, and extends approximately 50m along the site’s southern boundary, at which point, the formal road transitions into a more informal dirt track.

2.2 The site is bound to the east by industrial units of Kays & Kears Industrial Estate. These units provide large, industrial buildings with associated areas of hardstanding. To the north and west, the site is bound by an area of woodland which forms a raised woodland bund around two sides of the site, albeit the slope to the west is more gentle. Beyond these boundaries are a limited number of scattered residential properties which occupy elevated position above the level of the site which sits in a plateau. Immediately to the south is the access road and track which serves the estate beyond this immediately to the south, the is remainder of the allocated site and to the east and south of this is the Gilchrist Thomas Industrial Estate.

2.3 In terms of the wider vicinity, the B4248 runs parallel to the north of the site and links Pontygof with Blaenavon. Extending from the B4248, Estate Road passes to the east of Kays & Kears Industrial Estate approximately 270m from the subject site, and merges with the B4246. The B4246 serves Blaenavon and continues south, serving the settlements of Varteg, Talywain and Abersychan.

2.4 Kays & Kears Industrial Estate forms a part of a wider industrial landscape, with Gilchrist Thomas Industrial Estate situated to the south, as noted above, supporting a mix of commercial and employment uses. In this regard, the north-western area of Blaenavon is characterised by this industrial landscape. Beyond this, to the east, Blaenavon offers a predominantly residential landscape. Whereas to the north and west, the landscape comprises parcels of undeveloped grazing land.

Access 2.5 An existing access road branches off Estate Road towards the site, currently serving neighbouring Kays and Kears industrial estate. A footpath runs along the southern boundary of the access road, providing pedestrian access towards the site.

2.6 East and west bound bus stops are located 650m walking distance north of the site, on Garn Road, with services 31 and 62a. The former provides services between Brynmawr and Forgeside, whilst the latter services between Ebbw Vale and Pontypool via Blaenavon.

Landscape and Ecological Designations 2.7 In terms of designations, the Blorenge Site of Special Scientific Interest is located approximately 1.2km away to the east of the development site. The Garn Lakes Local Nature Reserve (LNR) is located approximately 120m to the west of the site. The Cwmavon Corridor LNR is located approximately 1.8km away to the south-east of the site.

2.8 Further, in close proximity to the subject site, lies the Blaenavon Heritage Landscape Special Landscape Area (SLA) which covers most of North Torfaen, and is located just north of the B4248. This presents an area of high landscape value characterised by a strong sense of place 6

with a simple set of defining features.

Heritage 2.9 In regard to heritage, the subject site does not contain any individual assets of heritage value.

2.10 Notably however, the site is located within the Blaenavon Industrial Landscape World Heritage Site (WHS). This designation covers a wide area of Torfaen, encompassing the settlement of Blaenavon. The WHS was designated in 2000 due to the area’s international importance in iron making and coal mining in the 18th/19th centuries.

2.11 Also of importance in this respect are the Air Shafts of the Old Blaenavon Coal Pits located less than 100m from the site’s northern boundary. These are designated as Scheduled Monument. A number of other Scheduled Monuments lie in proximity (1km) of the subject site, including Gard Road Powder House (circa 155m); Engine Pit (circa 350m); Brake Engine on Hill Pits Tramroad Incline (circa 450m); Blaenavon Ironworks (circa 550m); Pwll Du Tramroad Tunnel Southern Approach (circa 620m); Blaenavon Upper Brick Yard (circa 720m); Coity Sandstone Quarry and Incline (circa 910m); and, Coal and Iron Ore Workings West of Abergavenny Road, Blaenavon (circa 925m).

2.12 Blaenavon also presents a large number of Listed Buildings. A total of 44 Listed Buildings are located throughout the settlement, the majority of which relate to the established pertinence of the landscape in relation to coal mining and iron making. Notably, none of these are sited within 500m of the site.

Flooding 2.13 The Welsh Government Development Advice Map illustrates that the site is within Flood Zone A and is therefore considered to be at little or no risk of flooding.

Planning history and Engagement 2.14 The site itself has not been subject to any recent planning applications. Notably however, it is important to consider Pre-Application Advice which was sought for the wider application site, which also incorporating the southern parcel of land. This request for Advice related to the ‘proposed missed-use development comprising residential and commercial uses along with landscaping, SUDs and associated works on land at Kays and Kears Industrial Estate.’ The response to this proposal offered little encouragement from the LPA for the residential development in particular, thus this application is made in response of the advice received. This application rather seeks to provide a development consisting of light industrial uses and office accommodation only.

2.15 Planning history relating to the industrial units west of the subject site dates back as far as 1984 and primarily relate to ancillary works and extensions to existing units and also change of use of accommodation to provide office use.

3 Proposed Development

Overview

3.1 The proposal seeks to provide a commercial development consisting of light industry and office units providing 3,800sqm of B1, B2 and B8 floorspace, within seven proposed buildings. The buildings are aligned roughly on the north / south and east west axis to create a central courtyard. Building Five, with the largest massing, is centrally located and forms the focal point for the pattern of development, sitting centre to buildings Two, Three, Four, Six and Seven. More specifically, Buildings Two and Seven are located along the southern boundary. Building Six is located along the western boundary, Building Four is located on the northern boundary and Building Three is centrally located west/east facing. Building One is located along the eastern border towards the south.

3.2 In terms of scale and massing, the proposed development is sought to be predominantly two- storey in height with ridge level varying between 6.7m and 8.5m. Building One, on the eastern boundary adjacent neighbouring industrial estate of Kays and Kears measures one-storey internally but with a ridgeline of 6.7m.

3.3 The elevational treatments of the proposed buildings will consist of a palette of two-tone brick, with some metal standing seam cladding and timber cladding also proposed for units within the site. Metal standing seam roof is proposed as well as a PPC metal roller shutter. The intention of the primarily brick palette is to create a strong, attractive aesthetic; provide a more durable building; and to minimise maintenance. Reference has been taken from the local built context to ensure that the local vernacular is respected.

3.4 The proposal also accommodates yard space to accommodate the light industrial nature of the site. Four yard spaces are located along the eastern boundary, and two larger yard spaces are located along the northern boundary.

Access 3.5 The proposal demonstrates legible pedestrian access throughout the site, connecting the buildings and parking spaces with one another. The development proposal additionally considers pedestrian access in relation to the wider landscape, with two pedestrian access points to the south-west of the site providing scope for future expansion.

3.6 In terms of vehicular access, the site benefits from an existing access road serving the Kays & Kears Industrial Estate. This point of access is located to the eastern extent of the southern boundary, and the scheme proposes to extend this infrastructure to the north, into the site, providing a circular route throughout the development.

3.7 The provision of yard spaces has been carefully considered in relation to access and the wider scheme. The majority of yard spaces are located to the south-east of the site in close proximity to the site’s entrance. This minimizes the need for vehicles associated with such uses to travel through the site, thus reducing the impact on users of the wider space. Further, the proposed siting of industrial uses to the east/north-east towards the units of Kays & Kears Industrial Estate ensures visual consistency of the industrial landscape, preventing an immediate and obvious spatial change of use.

3.8 A total of 208 parking spaces are provided which are evenly distributed throughout the site. Main parking areas are located to the north-east (24 spaces), north-west (six spaces) and south (18 spaces) of the site. The remaining spaces are located in front of the proposed buildings. There are a total of 19 spaces for blue-badge holders distributed throughout the scheme.

Landscaping 3.9 The development proposal demonstrates areas of green land, landscaping and vegetation to be integrated throughout the site. Notably, 5m buffers are proposed along the northern and western boundaries to prevent disruption and disturbance to protected habitats and hedgerows. To the south-west, an area of landscaping is proposed. In conjunction with the 5m buffer, this ought to soften the visual impact of development on the wider landscape.

3.10 The proposal indicates that the southern boundary is to comprise an area of vegetation accommodating a number of trees, again to soften the visual impact of development and to ensure that the development relates to the wider rural landscape. Similar landscaping plans are illustrated along the site’s western boundary, with a number of trees located in proximity to the existing units of Kays & Kears Industrial Estate.

Drainage 3.11 Sustainable Drainage (SuDS) has been considered from a very early stage in proceedings. In this regard, design input from consultant drainage engineers have informed the site layout, with space for SuDS at ground level integrated into landscape proposals. A mix of rain gardens with attenuation below the filter layer are proposed, as well as swales along the site boundary, attenuation below the road, and tree and shrub planting address the SuDS guidance on surface water drainage.

4 Planning Policy Framework

4.1 The planning policy context for the determination of this application is provided by national and local planning policy guidance. National guidance is set out within Future Wales: The National Plan 2040, Planning Policy Wales and accompanying Technical Advice Notes (TANs). Local policy comprises the adopted Torfaen County Borough Council Local Development Plan (LDP) (to 2021) and its supporting Supplementary Planning Guidance (SPG) documents.

Future Wales: The National Plan 2040

4.2 Future Wales is Welsh Government’s top-tier national development framework. It is a strategy for addressing key national priorities through the planning system over the next two decades, 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.

4.3 It is a spatial strategy which does not seek to take decisions that are most appropriately taken at the regional or local level, but does provide a strategic direction for all scales of planning and sets out policies and key issues to be taken forward at the regional scale. One of the key aims of the document is to address issues which Welsh Government consider to be a priority at this time, with affordable housing identified as a critically important issue throughout Wales.

4.4 The document follows a sequential structure, with each section building on the previous one as follows, ‘Wales: An Overview’, ‘Setting and achieving our ambitions’, ‘Strategic and Spatial Choices: Future Wales’ spatial strategy’ and ‘The Regions’.

Wales: An Overview

4.5 This chapter provides a broad overview of the country and its intricacies. It is a very high-level overview of the country, however it ‘recognises and supports the important role of businesses of all sizes, from major international manufacturers to micro businesses, in strengthening, diversifying and increasing the resilience of our economy.’

Setting and achieving our ambitions

4.6 A focus of Future Wales is to provide quality development in the right places for the right reasons. 11 Future Wales Outcomes are set out within the chapter, which collectively are a statement of where Wales wants to be in 20 years. Every part of Future Wales is concerned with achieving these Outcomes.

4.7 Each Outcome commences with the prefix ‘A Wales where people live…’ building on the statement to provide a vision of Wales in 2040. Of particular relevance to the proposal are the following outcomes, all following the same prefix:

• A Wales where people live: o 1 ‘…and work in connected, inclusive and healthy places’, o 3 ‘…in distinctive regions that tackle health and socio-economic inequality through sustainable growth’,

o 5 ‘…and work in towns and cities which are a focus and springboard for sustainable growth’, o 6 ‘... in places where prosperity, innovation and culture are promoted’, o 7 ‘…in places where travel is sustainable’, o 9 ‘…in places that sustainably manage their natural resources and reduce pollution’, o 10 ‘…in places with biodiverse, resilient and connected ecosystems’, and o 11 ‘…in places which are decarbonised and climate-resilient’.

Strategic and Spatial Choices: Future Wales’ spatial strategy

4.8 One of the opening paragraph’s state that “the spatial strategy supports the Future Wales Outcomes. Decisions taken at a national level, including Welsh Government investment choices, will reflect the principles of the strategy and make positive contributions towards the national placemaking objectives.” Cities and large towns are identified as the main development areas through co-locating homes, jobs, and services in these areas, aiming to utilise untapped potential of places and their infrastructure. Among the places identified to achieve this growth, referred to as National Growth Areas is the Valleys, identified in Policy 1, ‘Where Wales will grow’ within the same National Growth Area as the Valleys and Newport. A total of 19 policies are identified within this chapter. These include ‘Strategic Placemaking’, ‘Supporting Urban Growth and Regeneration’, and among others.

The Regions

4.9 Regional planning will play an increasingly important role in the future, and this chapter provides a strategic vision for North, Mid Wales, South West and South East regions, focusing on large scale projects and less on housing, it is therefore of lesser relevance to the proposal. The South East is the most populous region, and includes the Valleys, a priority area for the Strategic Development Plan.

Planning Policy Wales 4.10 Planning Policy Wales (PPW) is the principal national planning policy document which sets out the land use policies of the Welsh Government against which development proposals should be assessed. The latest version is the eleventh edition, published in February 2021.

4.11 In a bid to ensure placemaking is prioritised, and to aid in implementing the Well-being of Future Generations Act, policy topics within PPW has been grouped under five themes, comprising: People and Places: Achieving Well-being through Placemaking; Strategic and Spatial Choices; Active and Social Places; Productive and Enterprising Places; and, Distinctive and Natural Places, respectively. The subsequent sub-headed chapters are supplemented by detailed and interwoven policy, which seek to work together in delivering sustainable places.

4.12 PPW promotes action at all levels of the planning process which is conducive to maximising its contribution to the well-being of Wales and its communities. In this regard it seeks to achieve WG’s well-being goals. All statutory bodies in Wales carrying out a planning function must exercise those functions with the principles of sustainable development as defined in the Well- being of Future Generations Act. Accordingly, paragraph 1.18 of PPW states emphatically that ‘legislation secures a presumption in favour of sustainable development’.

4.13 Figure 4 of PPW covers the Key Planning Principles of WG in seeking to achieve “the right development in the right place”. Development proposals must seek to deliver development that addresses these outcomes, albeit paragraph 2.20 recognises that not all of these outcomes can necessarily be achieved under every development proposal.

Strategic and Spatial Choices

4.14 It is indicated within PPW that the first stage of the assessment of proposals must take place in respect of Strategic and Spatial Choices. In this regard it is stated that “Effective strategic placemaking requires early collective consideration of placemaking issues at the outset… when developing specific proposals”.

4.15 Paragraphs 3.3 to 3.18 of PPW highlights the importance of good design in “creating sustainable places where people want to live, work and socialise”. To achieve good design development, proposals need to meet the five overarching aims of design which comprise of access, character, community safety, environmental sustainability, and movement.

4.16 PPW seeks to ensure that proposals achieve a broad balance between housing, community facilities, services, and employment opportunities in both urban and rural areas should be promoted to minimise the need for long distance commuting. Major generators of travel demand, such as housing, employment, retailing, leisure and recreation, and community facilities should be sited within existing urban areas or areas which are, or can be, easily reached by walking or cycling, and are well served by public transport.

4.17 PPW indicates at paragraphs 3.61 to 3.63 that development should be located so that it can be well serviced by existing or planned infrastructure.

Active and Social Places

4.18 A key theme of PPW is creating places that are active and social, this includes sustainable transport provision for housing development. The opening paragraphs to this chapter include the following aspiration of PPW:

“New development should prevent problems from occurring or getting worse such as the shortage of affordable homes, the reliance on the private car and the generation of carbon emissions.”

4.19 PPW places importance on locating development so as to minimise the need to travel and increasing accessibility by modes other than the private car.

Productive and Enterprising Places

4.20 PPW guides that productive and enterprising places are those which promote economic, social, environmental and cultural well-being by “providing well-connected employment and sustainable economic development”. Further, it is indicated that “increased economic activity across all sectors and at all scales” will contribute to prosperity of settlements.

4.21 PPW further indicates that by “building on the existing economic strengths of places” and “promoting sufficient employment and enterprise opportunities”, places can become more equal and

deliver prosperity for all.

Distinctive and Natural Places

4.22 This chapter of PPW covers a range of topics, including cultural heritage matters, natural assets, and environmental quality. The opening statement of the chapter states that:

“Development proposals should be formulated to look to the long-term protection and enhancement of the special characteristics and intrinsic qualities of places...Problems should be prevented from occurring or getting worse. Biodiversity loss should be reversed, pollution reduced, environmental risks addressed and overall resilience of ecosystems improved.”

4.23 PPW appreciates the importance of the historic environment stating that it “comprises all the surviving physical elements of previous human activity and illustrates how past generations have shaped the world around us. It is central to Wales’s culture and its character, whilst contributing to our sense of place and identity. It enhances our quality of life, adds to regional and local distinctiveness and is an important economic and social asset.”

4.24 With regards to World Heritage Sites is recognises the need to protect the Outstanding Universal Value of World Heritage Sites in Wales. The impacts of proposed developments on a World Heritage Site and its setting and, where it exists, the World Heritage Site buffer zone and its essential setting, is a material consideration in the determination of any planning application

Technical Advice Notes 4.25 The following Technical Advice Notes (TANs) are considered to be of relevance in the consideration of these proposals.

• TAN 12 Design (2016) • TAN 18 – Transport (2007) • TAN 23 – Economic Development (2014) • TAN 24 – The Historic Environment (2017)

4.26 TAN 12 relates to Design and was updated in March 2016. It provides advice and information on a number of related areas including the definition of design for planning purposes; design considerations in planning decisions; and local planning authority design policy and advice.

4.27 TAN 18, which was published in March 2007, deals with Transport matters, and advocates locating development where there is good access by public transport, walking and cycling, generally advocating development at sustainable sites.

4.28 TAN 23 focuses on economic development, which by definition of the Note, includes any form of development that generates wealth, jobs and income.

4.29 TAN 24 published in May 2017, covers the Historic Environment. In relation to conservation areas, this TAN largely reflects the key points addressed through Distinctive and Natural Places chapter of PPW as discussed above.

Well-being of Future Generations Act 4.30 The Well-being of Future Generations Act imposes a duty on public bodies to carry out 13

sustainable development in accordance with the sustainable development principles, and to 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. Its content is sought to be delivered through the planning system via the intertwining of the Act through PPW.

Other relevant national legislation

4.31 Given that the site is located within a conservation area, national legislation in this regard applies. This is to be found in the Planning (Listed Buildings and Conservation Areas) Act 1990. The Act sets out protocol that must be followed both by applicants and Local Authorities, in controlling any operational development within conservation areas.

4.32 Section 72(1) of the Act sets out the statutory duty for Local Planning Authorities, in relation to proposals for development located within conservation areas. It states that “with respect to any buildings or other land in a conservation area…special attention shall be paid to the desirability of preserving or enhancing the character or appearance of that area.”

Local Development Plan 4.33 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires that planning application decisions should be made in accordance with the Development Plan unless material considerations indicate otherwise.

4.34 The most relevant policies summarised below.

Policy Relating to

Strategy Policies

S1 Urban Boundaries

S2 Sustainable Development

S4 Place Making / Good Design

S6 Employment and Economy

S8 Planning Obligations

Borough Wide Polices

BW1 General Policy – Development Proposals

Topic Based Policies

EET3 Employment Allocations in the North Torfaen Area

T3 Walking and Cycling Routes

BG1 Locally Designated Sites for Biodiversity and Geodiversity

HE2 Blaenavon Industrial Landscape World Heritage Site

4.35 Policy S1 states that areas identified within settlement boundaries benefit from a “presumption in favour of development, taking into account material considerations”. This seeks to promote the full and effective use of urban land, allowing for development which contributes to the creation and maintenance of sustainable communities.

4.36 Policy S2 relates to Sustainable Development, a key focus throughout the LDP and many other policies. The Policy highlights that proposals must follow a number of principles, including promoting “the efficient use of land” and promoting “sustainable economic and employment growth”. The LDP further reveals that development proposals will be supported where they can assist in the provision of employment opportunities to support the area and assist the improvement of existing community facilities. This Policy also considers the wider society indicating that “social exclusion will be reduced by providing services and facilities in sustainable locations, close to residential areas or town centres, where they are also accessible by sustainable modes of transport and by using accessible layouts and building design”. In summary, “each settlement should have sustainable access to community services and facilities in order to reduce social exclusion”.

4.37 Policy S6 focuses on Employment and Economy, and provides a range of accessible employment opportunities for the residents of Torfaen. The Policy illustrates that a number of employment allocations have made throughout the Borough, each of which is considered “sustainably located and accessible by a range of public transport modes”. Whilst this Policy focuses on allocating suitable employment land, the importance of protecting existing functioning land is also highlighted with the aim of realising opportunities of existing sites.

4.38 Policy S8 highlights the Planning Obligations for Torfaen, stating that all proposals have an impact upon existing infrastructure, services, community and the environment to some extent. In compliance with the Policy, “where appropriate, the Council will seek obligations to mitigate against the effects of development”.

4.39 Policy BW1 provides a comprehensive criteria for new development proposals which covers five key themes: Amenity and Design; Natural Environment; Built Environment; Utilities Provision; and, Design and Highways. Notably, some of these topics will be of greater pertinence to the proposal than others. Of relevance: Amenity and Design focuses on promoting “good quality design in new development, which is also sensitive to the immediate and surrounding environment”; Built Environment highlights the need to contribute to “the preservation and enhancement of the historic built environment wherever possible” nor does the proposal “detrimentally affect the character of the immediate and surrounding built environment”; and, Design and Transport highlights that proposals ensure that “new access roads within the development layout connect the development to a range of services and facilities and are designed to promote the interests of pedestrians, cyclists and public transport”.

4.40 Policy EET3 highlights the Employment Allocations for the North Torfaen Area, revealing that Kays & Kears Industrial Estate is one of three allocations in the area. North Torfaen has been allocated 8ha of employment land, 6h a of which are located at Kays & Kears Industrial Estate. Notably, the subject site comprises the northern area of this land (approximately 1.5ha). The Policy summarises the allocation as providing “a large strategic WG owned site in the Heads of the Valleys corridor. The A465 dualling makes this are more accessible and the site provides the potential for new employment opportunities in Blaenavon”.

4.41 Policy T3 highlights the walking and cycling routes of Torfaen, illustrating that National Cycle 15

Network (NCN) 492 links Blaenavon Town Centre to Varteg Road Bridge. This route extends from the north-west of Blaenavon and passes west of the settlement, at its nearest point, this route is 1.6km from the site. An established shared cycle route extends from the NCN through Gilchrist Thomas Industrial Estate, to Estate Road. At its nearest point, this is just 650m from the subject site. These routes seek to improve the cycle route network of Torfaen “for leisure and commuting purposes”.

4.42 Policy BG1 relates to Locally Designated Sites for Biodiversity and Geodiversity. The subject site does not sit within any local designations, however a number of designations are in close proximity. The Garn y Erw Meadow SINC is located along the site’s western boundary which extends into the southern parcel of land which comprises a part of the land’s wider allocation. The Blaenavon Heritage Landscape SLA covers much of North Torfaen and lies in close proximity to the site’s northern boundary, and the Cwmavon Corridor LNR is situated just west of the site’s boundary. Considering this, development must not “cause significant adverse effects” to any of these designations.

4.43 Policy HE2 focuses on the Blaenavon Industrial Landscape World Heritage Site (BILWHS) and presents a number of considerations in relation to future development within the WHS. Much of Torfaen is located within the WHS, including the whole of Blaenavon and thus the subject site itself. Notably, development will only be permitted where it can be demonstrated that proposals will not adversely impact the landscape itself, or the character of the WHS. The BILWHS is characterised by the historic landscape which served mineral works and commercial production of coal, iron and steel.

Supplementary Planning Guidance (SPG) 4.44 In addition to the above policies, the following SPG are also considered to be relevant to this application:

• Planning Obligations (September 2016); • Blaenavon Industrial Landscape World Heritage Site Design Guide (April 2011); • Development and its incorporation within the landscape: A Guide for Developers (February 2000); and • Wales Parking Standards (Adopted September 2016).

5 Appraisal Overview

5.1 This section of the Planning Statement aims to identify the main issues relevant to the determination of the application and asses the scheme against the pertinent considerations.

• The principle of the development of this site in land use policy terms

• The design of the proposed development including its impact on local character

• Other material considerations, including flooding, ecology and drainage.

Principle of the development

5.2 The principle of the development is established given that the site is allocated for employment use within the adopted LDP, as indicated on the Proposals Map. More specifically, Policy EET3 indicates that the subject site would be suitable to accommodate a range of employment uses including classes B1 (Business), B2 (General Industrial) and B8 (Storage or distribution). It should be noted however that scope does exist for the inclusion of a wider variety of uses with the policy stating that “employment uses are not restricted to Use Classes B1, B2 and B8 as potential facilities such as major health and education uses may fall within this definition”.

5.3 It is pertinent to also consider the principle of development more specifically in relation to the proposal. Such strategic sites have been allocated to “enhance town centre-based employment and economic uses”, thus it is important to note that the scheme supports the industrial nature of the landscape whilst also introducing scope of other ancillary uses to be considered. In this regard, the principle of development for employment and other business uses is supported by the Development Plan.

5.4 Compliance with Future Wales is demonstrated through the provision a variety of working environments which will accommodate a diverse range of employment types. The site’s location in relation to the residential landscape of Blaenavon supports the focus of connected, inclusive and healthy places objective in regard to ensuring that settlements are well located in relation to employment and services. Further, the development itself is located adjoining the Kays & Kears Industrial Estate, and provision of a new employment site here will further encourage more associated uses. The agglomeration of such uses, both industrial and professional, will provide benefits to both the new and existing employment sites.

5.5 The Valleys area, identified within Future Wales encompasses much of Torfaen and is thus considered a priority area for the Welsh Government. Within such areas, it is revealed that traditional and new economic sectors can be supported by existing and new employment areas. In regard to this proposal, provision of new industrial units and yard space will support the existing users of Kays & Kears Industrial Estate by either offering space for expansion, or introducing new occupants who may be of benefit to the users of Kays & Kears Industrial Estate. The introduction of office space may similarly provide benefits to surrounding users by providing supporting services or attracting a greater population who will support these uses.

5.6 Compliance with PPW is demonstrated, which advocates siting new development within existing urban areas. Further, the development also assists in PPW’s aim to ensure that sites identified

for employment use in a development plan are protected from inappropriate development and encourages development which generate economic prosperity and regeneration.

5.7 Accordingly, as evidenced by the site’s allocation for employment use, the principle of the development is firmly established.

Design of the development

5.8 In terms of design, the proposed development adopts a layout which considers the immediate site constraints together with the wider landscape and heritage considerations to deliver a design which is cohesive with uses in the immediate vicinity.

5.9 In regard to the industrial landscape, the Blaenavon Industrial Landscape World Heritage Site Design Guide SPG indicates that employment sites such as these may “enhance the overall quality and character of the area”, however this may depend on “good streetscape” and “urban design”. The proposed scheme mixes light industry with more professional uses, supporting the local character whilst also introducing a range of complementary uses. The proposal focuses light industry buildings to the west, in proximity to the existing units of Kays & Kears Industrial Estate, whilst more professional uses are located west of this. In respect of the SPG, the site has been designed to incorporate these uses into the landscape and has ensured that new uses are successfully integrated into the streetscene. From the perspective of the access road, buildings along the southern boundary of the site are industrial to the immediate west and then comprise more professional use towards the centre and east. This prevents a sudden change of landscape and provides a change of use which gradually and naturally extends along the road, complimenting the existing streetscene. The buildings along the southern boundary of the site screen the commercial activity within the centre of the site. All the buildings have active frontages around the central roads and parking areas.

5.10 In regard to the wider rural hinterland, it is important to consider the site’s location within the Blaenavon Industrial Landscape World Heritage Site (BILWHS). The proposed site layout incorporates trees and areas of greenery throughout the scheme, interweaving landscaping features amongst the built environment. A landscape buffer runs along the site’s northern, southern and western boundaries, softly merging the development with the rural extent. The proposal demonstrates the provision of trees along the site’s southern boundary and an area of landscaping at the south-western corner. This merges the development with the wider landscape, and strengthens the relationship between the site and the rural area, thus ensuring that “important views into and within the BILWHS are not adversely affected” and “preserves … the character of the local area” thus in compliance with Policy HE2. This further supports The Blaenavon Industrial Landscape World Heritage Site Design Guide SPG which indicates that “elevations should be visually ‘broken up’ to avoid a large or monolithic appearance” and “some planting may be used to help integrate the building with its surroundings”.

5.11 The development will be built to a high quality and the proposed external finishes have been chosen so as to assimilate the proposed industrial units within the historic setting. The Blaenavon Industrial Landscape World Heritage Site Design Guide SPG highlights that industrial/employment buildings ought to use materials and colours which “reflect the natural and muted tones of the surrounding context”. In support of this, the proposal adopts a two-tone brick finish with metal and timber cladding. Consequently, the development would sit well within the WHS with its design echoing the localities’ industrial history and aesthetic and its muted colour palette ensuring that it does not stand out as overly prominent in views across the landscape.

Further, brick offers better durability and indeed more visual appeal than render, when designed correctly. Together, these demonstrate adherence with policy S2 and HE2 of the LDP which seeks to preserve and enhance the built and natural environment through sensitive design and setting.

5.12 The scale of the proposed development is appropriate in that the scheme has been designed to reflect neighbouring uses. Via a combination of siting, scale and context, there are no significant amenity concerns arising.

Heritage

5.13 The proposed development is sited within Blaenavon Industrial Landscape World Heritage Site and there are a variety of scheduled monuments in close proximity to the site. EDP have assessed the nature and magnitude of the impacts of the proposed development upon these heritage assets, in the accompanying Heritage Impact Statement. It is concluded that the site does not contain any designated ‘historic assets’, such as scheduled monuments, listed buildings, or historic parks and gardens, where there would be a presumption in favour of physical retention or preservation in situ.

5.14 The assessment has considered the potential for effects on Outstanding Universal Value of the Blaenavon Industrial Landscape World Heritage Site and the Blaenavon Landscape of Outstanding Historic Interest, area designations that encompasses the site. It is concluded that, aside from a low potential for deeply buried, industrial-era archaeological remains the site makes no contribution to the Outstanding Universal Value of the Blaenavon Industrial Landscape World Heritage Site or the historic character of the Blaenavon Landscape of Outstanding Historic Interest. The emerging development proposals would change the appearance of the site but are intended to adhere closely to the recommendations of the BILWHS Design Guide.

5.15 With regards to the designated historic assets in the vicinity of the site and the potential for effects due to change within their setting, it is concluded that the site makes no contribution to the significance of any such asset and that the development proposals would not change the setting of any asset such that it results in an effect on their significance.

Archaeology

5.16 In terms of the site’s archaeological potential, the assessment undertaken by EDP indicates a low potential for buried remains of low evidential value to be located at the natural ground level beneath the upper layers of made ground. Below-ground impacts from the proposed development would not be of sufficient depth to result in any impact upon archaeological remains. As such, no additional archaeological field work should be required to support a future planning application or by way of mitigation of archaeological impacts.

Highways

5.17 The accompanying Transport Assessment prepared by Lime Transport considers the impact of the development of 3,781m2 of commercial development on the existing Kays and Kear site, Blaenavon. The report reviews the existing conditions and likely transport impact associated with the development. It concludes that the development will not have a significant impact on the transport network and can be accommodate in terms of safety and capacity.

5.18 Vehicle access and visibility have been assessed as acceptable. 208 car parking spaces are 19

provided in accordance with Torfaen County Borough Council parking standards, which adopts Wales Parking Standards 2014.

5.19 A junction capacity analysis carried out at four junctions, including Estate Road/B4248 Garn Road priority junction; Site access/Estate Road priority junction; Estate Road/B4246 North Street priority junction; and B4246 Church Road/Commercial Street/Prince Street/Ivor Street traffic signal controlled junction, indicates that there is sufficient capacity to accommodate the likely increase in traffic flows, together with development generated traffic for the 5 and 10 years post-opening future scenarios.

Ecology

5.20 The subject site does not sit within any local designations. Notably, a SINC, SLA and LNR are all in close proximity to the site’s boundaries. The site presents an area of purple moor grass / rush pasture along the northern edge of the site. This is a priority habitat for retention and enhancement, thus the development seeks to retain this habitat and create a 5m habitat buffer separating it from any development of the site. The western boundary also presents an area to be retained, and additional betterment has been put forward by means of tree planting. A habitat management plan will be required for all retained habitats and areas of soft landscaping. A number of mitigation measures have been provided within the Preliminary Ecological Assessment in respect of potential species presence.

5.21 It is noted that the site clearance should be undertaken outside bird nesting season of September to February, and bird boxes are proposed on 25% of the new buildings, with 20% of the buildings having bat boxes, which will be located at least 2m away from artificial light source. A habitat management plan will be required for the retained habitat and areas of soft landscaping on site to ensure they are appropriately managed for wildlife.

5.22 In summary, the accompanying preliminary ecological assessment demonstrates that thorough survey work has been undertaken in respect of the likely use of the site as an ecological habitat. The proposed bird boxes, recommended time constraints to construction works, landscape buffer and suitable planting offer suitable mitigation insofar as it would ensure that no species will be impacted by the proposed development and will ensure adequate compensatory habitat for nesting birds.

Other material considerations

5.23 Drainage – The development proposes to utilise sustainable drainage methods to manage the surface water from the entire site. This will be in the form of planting areas to collect stormwater. An application will be made to the Sustainable Drainage Approving Body (SAB) in due course, but the principles proposed are well advanced based on active and frequent dialogue between SAB and the design team. Foul water is proposed to be discharged into the existing public sewer.

5.24 Arboriculture – All groups of trees on site are assessed as Category C, denoting trees of low quality with an estimated remaining life expectancy of at least 10 years, or young trees with a stem diameter below 150mm. A number of new trees are proposed to be planted on site. Overall, the landscaping proposals will seek to enhance the quality and nature of soft landscaping on the site.

5.25 Landscape – The scheme proposes new development on previously undeveloped land, as such, there will be some moderated effect upon visual receptors within the landscape. The Landscape and Visual Impact Assessment Report indicates that given the principle of commercial/industrial development upon the site, subsequent effects ought to be acceptable by the LPA. Summarily, it is believed that proposals would be in keeping with the existing landscape and would not cause adverse effect on surrounding context.

5.26 Flooding – The site lies in flood zone A, thus there are no constraints in this respect.

6 Conclusion 6.1 This Planning Statement is produced in support of proposals for commercial/employment development comprising light industry and office space at Kays and Kears Industrial Estate, Blaenavon, Torfaen.

6.2 The principle of development is established given the site’s allocation for employment use within the adopted LDP and the site’s location within the settlement boundary. Further the development assimilates into the industrial landscape of this area of Blaenavon. The design facets proposed are befitting of the site’s location within the Blaenavon Industrial Landscape World Heritage Site area. The design of the units has been carefully considered to ensure minimal impact on the heritage area. The development will bring in to use a redundant site within the settlement boundary.

6.3 The LDP’s aim to deliver a competitive, modern and sustainable economy is mirrored within aims of Welsh Government. The proposal evidently seeks to support the function of Kays & Kears Industrial Estate whilst also facilitating its growth and expansion by introducing infrastructure which may support more professional services. In this respect, the proposal seeks to innovate and strengthen the local economy.

6.4 Although the site is located within the World Heritage Site and in proximity to a number of heritage assets, the scale and design of the proposal indicate that these designations will not be adversely impacted by development. This is supported by the site’s allocation for employment purposes and the size of the allocation, which indicates and lends itself to employment development of this scale. Considering this, the LPA deem the site suitable for development.

6.5 There are no technical constraints identified in respect of ecology, landscaping, highways, trees and drainage, with the application supported by a various supporting technical documentation. None of which has identified any harm arising from the proposals to these matters and suitable mitigation has been provided where necessary.

6.6 Wellbeing goals of the Well-being of Future Generations Act (WFGA) are adhered to through this application in that there would be no significant or unacceptable impacts upon the achievement of wellbeing objectives as a result of the application being approved and development being carried out. PPW brings the objectives of the Act into clearer focus in a planning context, thus through compliance with PPW, adherence to the WFGA is demonstrated.

6.7 In conclusion, the proposal offers an opportunity to employment development in a sustainable location which will promote the local economy and encourage a shift to more sustainable modes of transport whilst providing employment opportunity and aiding in meeting the economic requirements of the Blaenavon and Torfaen. The site accords with sustainable development principles through its location within the settlement boundary and its redundant nature. The development is a suitable and positive addition to the streetscene that exhibits adherence to placemaking standards, and there are no known technical constraints to the development of this site. On this basis, it is respectfully recommended that Torfaen County Borough Council put this application forward for approval.

LRM Planning June 2021