It is very important that individuals make a submission within the 21 days. The more that are made the more significance is attached to the responses. See the earlier posting on how to make a submission and you may wish to use this letter as a guide.
Even if you agree with the development but think it should be improved it is important that you say you object on x,y,z grounds and that these changes should be made before approval is given.
Pontyclun New Town Working Group
c/o Margaret Griffiths and Len Arthur
6 Llantrisant Road
Pontyclun
CF72 9DQ
Service Director Planning
Pontypridd
CF37 1DU
Representation on Planning Application 11/1330
For the Development of the land adjacent to Cowbridge Road and the A473 between Pontyclun and Talbot Green
The applicant has provided a Design and Access statement which states that the application should result in a town centre which would be
· Active, inclusive and safe
· Well run
· Environmentally sensitive
· Well designed and built
· Well connected
· Thriving
· Well served
· Fair for everyone
The Pontyclun New Town Working Party is objecting to the application because the specific actions set out in application do not meet in several crucial respects many of the above key attributes set out by the applicant.
The Pontyclun New Town Working Party is a group of Pontyclun residents which has worked with the local community to identify their aspirations and fears for the development of this site. Two public meetings have so far been held. 340 responses to a local questionnaire have been received. Meetings have been held with the applicant, with other landowners on the site, with the Countryside Council for Wales
We understand that the Local Development Plan makes provision for retail development on this site. Within the community our survey indicates that there is a majority of people who would welcome increased retail and leisure activity on this site. However a very large majority of residents want a development that meets key concerns that they have. Our objection is based on the fact that the application does not sufficiently meet those concerns.
We are making this representation within the 21 days specified in the notice of application. Nevertheless as the discussion continues within the community we hope that you will be willing to receive further representations from the Working Group after the 21 day period.
1.0 Well Connected
The applicant has stated that the development should be well connected. There is strong evidence that the application does not meet this objective.
Road access from the A4119
The traffic projections provided by the applicant indicate that over 50% of the cars arriving at this development will do so from the A4119. This road, and in particular its intersection with the A473 is already heavily congested.
The attraction of further traffic through this intersection cannot be sustained without substantial gridlock which would blight this development. It would also blight other economic development opportunities within the area of Pontyclun and Talbot Green. Perhaps most significantly gridlock at this intersection would prove to be a major obstacle to economic development in the upper Ely and Rhondda valleys.
The problem of this intersection is admitted in the application. There is a reference to a strategic intention by RCT CBC to develop a grade separated intersection on this highway. This could well provide the necessary highways solution. There are however at least two problems in assuming that this solution can be met. Firstly there is the cost of £19 million which the applicant is not offering to meet. Second such an intersection would be substantial in scale and would be a major incursion into the exsting green field and settlements for which there is no planning consent and to which there would be objections.
The applicant is offering to make the existing roundabout at the intersection of the A4119 and A473 a signalled roundabout and claims that through this improvement the effect of the increased traffic would be more than mitigated. We question that such a substantial highways problem can be solved by such a simple and inexpensive solution. We ask that no planning consent is granted until the claim by the applicant to provide a solution to this problem is independently evaluated by an expert consultancy nominated by the Council but at the applicant’s expense.
Road access along the A4322 and through Pontyclun Village
The applicant estimates that 30% of the traffic to the new development will be through the Pontyclun Village Centre. This road is already congested for large parts of the day. It serves a village retail centre which the Local Development Plan is committed to sustaining. It provides access to the Pontyclun Primary School
Pedestrian access
Recent retail developments in this area have suffered massively from not providing well planned and usable pedestrian access. They have been planned solely for car access and have then suffered from road congestion and a lack of parking.
This application states an intention to provide new and well planned pedestrian access but offers no specific investment into pedestrian access. There is a map with vague sketch arrows in all directions and an admission that specific routes are yet to be identified. Within 800 metres of this development there are substantial recent settlements that need to have a pedestrian link to the development but none are specified. These settlements include Cefn yr Hendy, Tyla Garw, Southgate
Cycle access
The applicant writes excitingly about an ambition to encourage a cycle culture and a modal shift from car to cycle. However no specific actions are identified which might provide safe cycle access and encourage such a modal shift.
There is support for the Sustrans proposal to use the disused rail temporarily as a cycle track pending the introduction of a working rail route to Beddau. This cycle route would be much welcomed but it is not good enough to rely on a temporary solution. Moreover this one cycle route is not sufficient to achieve the ambition of a development based on a new cycle culture. The requirement must be that the Council and the applicant work together to specify safe cycle routes to this development, and at the same time to Y Pant School, over a 5 kilometre radius. Such routes should provide safe cycle links to Pontyclun, Llanharri, Llanharan, Cefn yr Hendy, Miskin, Cross Inn, Beddau, Llantrisant and Talbot Green
2.0 Environmentally sensitive
The Applicant has the stated objective that the development should be environmentally sensitive.
Development on the Greenfield
One of the most effective ways of achieving this objective would be to constrain the development to the existing brown field (the former Purolite and Staedler factory sites) and not include the incursion into the existing Greenfield
We note that the application is to provide 46, 323 m2 of retail space whereas the Local Development Plan includes provision for 23,400 m2. The replacement of the 8000 m2 of the existing Leekes store does not explain the difference between these two figures. Our arithmetic is that the application is for 50% more retail space than that provided for by the LDP. If that is right then the application must be rejected for its detrimental effect on the environment and on the local highway structure. In any case environmental sensitivity requires that the green field is fully protected
Protection of the Pant Marsh and the Coed yr Hendy
The Pant Marsh and the Coed yr Hendy should be protected and made accessible so that it is natural green area for visitors to the retail park and for local residents. We believe that it is important that the development, which is in such close proximity to Pant Marsh and Coed yr Hendy, should be developed in such a way that it will have limited impact on the marsh.
The Pant Marsh is partially protected by its SINC site status (sites of importance for nature conservation).The RTC local biodiversity plan adopted in 2000 covers the protection of priority species and priority habitats. We must do more than pay lip service to our understanding of the importance of maintaining and enhancing biodiversity. It is crucial to our quality and variety of life. Species and habitats are threatened and lost to over development and poor understanding of how we coexist. Floodplain grassland in RCT is now only a tiny fragment of the original Pant Marsh is one such fragment.
To protect and enhance this area we propose that:
- the New Town Development should not extend beyond the existing brown field into the Site of Important Nature Conservation;
- the required improvements to the highway intersection of the A4119 and A473 are not designed so as to reduce the area of the Pant Marsh.
- the development is designed to bring the green areas into the town and facilitate walking access into the green areas.
There is much support in the community for a new supermarket to alleviate the pressure upon and provide competition to the existing Tesco store. In this respect with effective resolution of highways and environmental concerns there would be support for Phase One of the development. However there is no good reason why Phase One should take place on the green field whilst leaving the brown field vacant for a Phase Two development which is less certain to take place on the given timescale. Therefore we oppose the application for Phase One believing that a new supermarket as a Phase One development should take place on the brownfield site.
We note that the developer has provided a habitat management plan for the two areas of Pant Marsh and Coed yr Hendy. However we note that the plan does not state how the management will be financed and who will be responsible. The application should not be supported until this is agreed.
The importance of non-car access to environmental sustainability
We welcome the applicant’s commitment to achieve BREEAM excellent standards of construction as required by the Welsh Government. However, we argue that there is little purpose in reducing the carbon footprint of retail buildings if we do not make access to the retail development equally environmentally sensitive. It is for reasons of environmentally sensitivity that come back to our argument that the incentives to access this retail development by means other than cars are far too weak in the application.
We note that application is for 3000 car parking spaces. This is around 1 car parking space for every 7 m2 of retail space. Whilst the applicant states a desire to develop a modal shift away from car access the detail of the application continues to assume very high levels of car access. A recent large scale retail development around the Olympic site in east London
3.0 Well designed and built
We recognise that there is much in the exemplar illustrations for this outline application that would support an ambition for this development to be well designed and built. We recognise that this is a better design than in most other recent retail developments in South Wales . This is as it should be. The retail profit per m2 in this location is higher than anywhere in the UK
We welcome the illustrations of high quality materials, the design of attractive pedestrian walkways, the interesting design of public spaces. When there is a planning application for Phase 2 the applicant and the Council must not allow any of these design commitments to be sacrificed or bargained away, as so often happens.
We note that the larger stores and car parks will be between 18 and 22 metres high. We do not feel that this is consistent with the scale of the adjacent residential and commercial buildings. This development will be significantly higher than any existing buildings. They will detrimental to the eye line from the local hills and will dominate the properties of nearby residents of the area.
The intended height of the development is designed to ensure that the 3000 car spaces can co-exist with the allocated retail space. If this development were less reliant on car access then the physical scale of the development could be much reduced.
The master plan refers to the view of the retail and industrial developments within the area from a number of high points encircling the development. In addition to Breeam we believe that the development could provide residents of apartments above the stores with roof top gardens or the roofs could be designed as green roofs. A living green roof supports wildlife, improves the view, insulates buildings and increases the lifespan of their waterproofing.
4.0 Thriving
The LDP makes provision for 23,400 m2 of extra retail space in anticipation of the extra retail demand expected from the projected extra housing area. The applicant defines the local catchment for this retail development to extend from Tonteg to Tonyrefail and Llanharan. The LDP makes provision for 4700 extra dwellings within this wider geographical area. The retail development justifies itself by the retail demand created by these extra dwellings.
In approving the LDP the Planning Inspector required that Phase 2 of this development should not be in advance of identifiable need. We therefore oppose the applicant’s objective to complete Phase 2 by 2016. A thriving development requires an assurance that the extra demand is in place and this requires evidence that housing suppliers can take up the extra housing provision by this date. The national context for housing developers is a very difficult. Because there continues to be a fear of falling house prices, mortgage providers continue to require historically high deposit to value ratios. The entry of first time buyers into the housing market continues to be at an historic low and this is stagnating all other parts of the housing market. The LDP correctly is based on a projection of housing need but for the foreseeable future demand is unlikely to equate with need.
Because Phase 2 should be deferred until such time that the extra local demand is in place through new housing, the case for locating local Phase 1 on the Brownfield site is all the stronger.
If Phase 2 were to take place in advance of new local demand then the incentive would be to market this development over an ever wider area, diminish demand for other retail centres and attract increased traffic flows along the M4 and increase the traffic congestion on the A4119. This was not the objective of the LDP not was it the intention of the Planning Inspector and the Welsh Government in approving the LDP
5.0 Active, inclusive and safe
The application states that it will meet the objective of being active, inclusive and safe. To do this the development needs to meet the aspirations of all age groups within the community. The master plan includes a cinema and from our survey 60% would like a cinema in the area.
However, 34 per cent of respondents said that they would like to see an arts centre or theatre developed. Forty four per cent would like to see a community centre developed on the site.
The plan does not seek to provide facilities (other than a cinema) that residents of established towns would expect to have use of, for example a theatre, an arts centre, a youth centre, purpose built meeting rooms for community activities.
The master plan includes a civic office and yet we have been informed by councillors and planners that RCT Council does not have the finances to open a civic office on this development site. Should this plan be accepted it is likely that this area would be either left derelict or more likely developed for further retail or office units.
We believe that if this plan is to proceed and is to be considered to provide an inclusive development, that the development of an arts centre, with theatre and meeting rooms should be part of the developer’s contribution to public life in the area.
The Design and Access statement suggests that there are sufficient community facilities in the area. Talbot Green has one rather old community centre and community meeting rooms in Pontyclun are always oversubscribed; there is a local demand for extra community facilities.
6.0 Fair for everyone
The plan states that a sustainable town centre should be fair to everyone and yet this plan could have devastating effects on the villages of Talbot Green and Pontyclun.
The design and access statement makes no mention of the impact of the new retail development on the two village centres. We are going through a severe recession and although the retail assessment refers to two thriving villages, this is far from the truth. We can only assume that the developers would be very wary of making any assertions about the positive impact of the development on the village centres and it is not in their interests to list the negative impacts.
The LDP designates Pontyclun as a ‘smaller settlement providing a limited range of services to meet local needs’’. It is important that this new development does not undermine the ambition set for Pontyclun in the LDP.
The scale of Pontyclun is such that people can expect to meet friends and acquaintances as they use the village centre. There is well researched evidence that the local networks of social relationships sustained by such a village environment is the basis of achieving good health and wellbeing and this is a stated aim of the Local Development Plan. Without the local shops this will not happen.
In order that the new development enhances Pontyclun village we believe that the communities of Pontyclun and Talbot Green should benefit from a percentage of the increase in value of the site. The value of the land being used for this development has been hugely increased by its inclusion within the LDP as prime development land for a retail park. A high percentage of this increase in value should be ploughed back into mitigating the negative effect of this development on local communities. This would need to be discussed with the two communities of Pontyclun and Talbot Green.
Appendices
Appendix 1: Questionnaire
Appendix 1
Proposed New Town Centre – Community Questionnaire
We would be most grateful if you could give your feedback on the proposed new town centre, simply complete the form below by placing in a tick in the relevant boxes. Your feedback will be used to help shape the proposed development to the benefit of the local community.
| 1. Are you aware of the proposed New Town Centre proposals for the Pontyclun, Talbot Green and Llantrisant areas? | ||||||||||||||||||||||
| Yes | No | |||||||||||||||||||||
| 2. What facilities would you like in the Pontyclun/Talbot Green/Llantrisant areas? | | Yes | No | | Yes | No | ||||||||||||||||
| More bars & restaurants | | | More high street shops | | | |||||||||||||||||
| Hotel | | | Offices | | | |||||||||||||||||
| Cinema | | | Supermarket | | | |||||||||||||||||
| Housing | | | Footpaths | | | |||||||||||||||||
| Cycle ways | | | Open spaces | | | |||||||||||||||||
| Parks | | | Theatre | | | |||||||||||||||||
| Outdoor leisure facilities | | | Community centre | | | |||||||||||||||||
| Indoor leisure facilities | | | Arts centre | | | |||||||||||||||||
| 3. Would you be concerned about any of the following should the proposed development go ahead? | | Yes | No | |||||||||||||||||||
| Increased traffic | | | ||||||||||||||||||||
| Parking in and around residential areas | | | ||||||||||||||||||||
| Increase in crime | | | ||||||||||||||||||||
| Reduction in house prices | | | ||||||||||||||||||||
| Loss of the village centre | | | ||||||||||||||||||||
| Empty shops in Pontyclun and Talbot Green | | | ||||||||||||||||||||
| Litter, noise and general nuisance | | | ||||||||||||||||||||
| Environmental damage to current green areas | | | ||||||||||||||||||||
| Flooding | | | ||||||||||||||||||||
| Changing the character of the villages | | | ||||||||||||||||||||
| Other (use this space to add any other concerns) | | |||||||||||||||||||||
| 4. On a scale of 1 – 10 (with one being strongly against, 10 being strongly for) are you for or against the proposals | 1 | 2 | 3 | 4 | 5 | 6 | 7 | 8 | 9 | 10 | ||||||||||||
| 5. In which area do you live? | Pontyclun | | Llantrisant | | ||||||||||||||||||
| Talbot Green | | Llanharran | | |||||||||||||||||||
| Llanharry | | Pencoed | | |||||||||||||||||||
| Other | | | | |||||||||||||||||||
| 6. Age Group | Under 18 | | 18 - 25 | | ||||||||||||||||||
| 25 - 35 | | 35 - 50 | | |||||||||||||||||||
| 50 – 65 | | Over 65 | | |||||||||||||||||||
| 7. Would you like to be kept informed of the progress of the community action group? | ||||||||||||||||||||||
| Yes | No | |||||||||||||||||||||
| If yes, please provide an email address (we are sorry but we are unable to keep in touch by post etc due to costs)............................................................................................................................. | ||||||||||||||||||||||
