This letter has now been sent to RCT and copies have been widely distributed to interested parties. It represents our first response to the proposed development based upon information that is in the public domain from public authorities and the developers.
It has been produced within the remit of doing our utmost to improve the plans.
When the outline planning permission application is submitted further opportunities to respond will present themselves.
It is planned to have another open public meeting at the latest by early October providing interested local people with the opportunity to further develop the case being made.
Pontyclun Residents New Town Working Group
6 Llantrisant Road
Pontyclun
Rhondda Cynon Taf
CF72 9DQ
e-mail:marg.talygarn@btinternet.com
tel. 01433 229301
23 August 2011
Jane Cook
Director of Planning
Rhondda Cynon Taf County Borough Council
Dear Ms Cook
Proposed New Town Development north of Pontyclun
6 Llantrisant Road
Pontyclun
Rhondda Cynon Taf
CF72 9DQ
e-mail:marg.talygarn@btinternet.com
tel. 01433 229301
23 August 2011
Jane Cook
Director of Planning
Rhondda Cynon Taf County Borough Council
Dear Ms Cook
Proposed New Town Development north of Pontyclun
Residents of Pontyclun and Talbot Green have met to discuss the provision in the Local Development Plan of a new retail and leisure area to the north of Pontyclun. A working group has been to consider how this development could best serve the interests of local people. This letter is from that working group and we seek to influence the further progress of the LDP and the consideration of any application for development on the New Town site.
We ask for an opportunity to discuss with you and your colleagues the objectives that we set out in this letter with a view to working together to ensure that the Local Development Plan and any future planning consent maximises the benefits for local people.
When the RCT CBC first began its preparations for the LDP with the publication of its outline strategy the residents of Pontyclun, through their Community Council, objected to the scale of the proposed New Town development which was then outlined as including the whole of the Pant Marsh and the Coed yr Hendy. As far as we are aware there were no further objections during the LDP process and this would have been due to assurances that any development was to be limited to the sites of the former Purolite and Staedtler works.
As we examine the current state of the LDP and read the continuing correspondence with the Planning Inspectors we find that many of our original concerns over scale, environmental protection and transportation remain unresolved.
As the LDP is further developed and any application is considered we suggest the following should be the objectives of the Council, the Planning Inspector, the Countryside Council for Wales and any developer:
- that the existing vitality of the Pontyclun village centre should be enhanced
- that the ‘New Town’ should be designated as Wales First Green Town with design features which support that designation
- that the development should diminish the flood risk of the surrounding area
- that the traffic congestion of the surrounding area should be diminished
- that the development should be part of a network of safe cycling and walking routes
- that the area of the Pant Marsh and the Coed yr Hendy are protected and made accessible so that it is natural green area for visitors to the retail park and for local residents
The existing vitality of the Pontyclun village centre should be enhanced
Whilst the Local Development Plan refers to the retail site as Mwyndy/Talbot Green it is in closest proximity and has most accessibility to the village centre of Pontyclun which is a successful village centre, much valued and used by local residents. Pontyclun has a range of local retailers and local amenities which are small in scale and often commercially fragile.
The LDP designates Pontyclun as a ‘smaller settlement providing a limited range of services to meet local needs’’. It is important that the New Town 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 well being and this is a stated aim of the Local Development Plan. We must be very deliberate in ensuring that any new development enhances rather than undermines local social relationships. It is a feature of almost all large scale retail developments that they individualise the shopping experience and undermine social relationships.
We support the conclusion of the Retail Study undertaken by Nathaniel Lichfield and Partners for RCT CBC in 2008: “By serving predominantly local catchment, accessibility by foot and cycle should be ensured and car parking should be subordinate to the development rather than the dominating impact it has at Talbot Green”.
In order that the new development enhances Pontyclun village it should:
- not exceed the existing brownfield area. We support the Countryide Council for Wales which is continuing to object to the LDP in this respect. We ask that the Council respond to continued questions by the Planning Inspectorate and the CCW by limiting the development to the brown field site. We understand that this would reduce the footprint of the development by 14 hectares
- not include forms of retail provision which directly compete with the scale and character of retailers in Pontyclun
- not impede access to Pontyclun village
- provide attractive walkways and cycleways along the river between the new town and Pontyclun signposting users of the new development to the amenities of Pontyclun
- advertise rail access to the new town via Pontyclun train station. We recognise that there is an ambition to serve the New Town from a new Pontyclun to Beddau train line but this is unlikely to gain funding in the near future and in the meantime it should be noted that the Pontyclun station is only a 10 minutes riverside walk from the site.
The ‘New Town’ should be designated as ‘Wales First Green Town’ with design features which support that designation
If the New Town is to be successful, it needs to distinguish itself from every other retail park that has developed on the edge of settlements over the past few decades. All too often they have been highly repetitive, relying on the same multiple retailers, and totally reliant car transport for their access.
We suggest that this New Town should distinguish itself by being designed to promote environmental sustainability in line with policy AW12 in the LDP ( Renewable and non Renewable Energy). Its distinguishing features should be designed to diminish the ecological footprint of the development and in so doing they would also add to the commercial viability by providing good reason to use this development rather than any other.
The green features that should be built into this development include:
- development on the existing brownfield only and not on the proposed 14 hectare of the Site of Importance of Nature Conservation.
- provision of a wide network of pedestrian and cycle access to the development which would provide access to the development and provide safe routes to Y Pant school
- protection of the surrounding areas of the Pant Marsh and Coed yr Hendy with design features that bring the green areas into the town and facilitate walking access into the green areas.
- providing walkways which link the development to Pontyclun train station
- providing a ‘Park and Ride facility at Junction 34 which is linked to the development by a dedicated bus lane on the hard shoulder of the A4119
- all l surfaces for walkways, roadways and parking areas should be of permeable materials which capture rainwater into subterranean reservoirs used as an energy source for ground water heat pumps
- combining renewable energy sources with the highest levels of insulation with the aim of achieving a carbon neutral development
- designating a proportion of retail facilities for the marketing of products produced within the County Borough
- the mitigation of climate change through enhanced control of flood risks in the surrounding areas.
The LDP requires that a retail development of this scale should be governed by a ‘master plan’ that informs each particular part of the development. The Council should require that the master plan provides the features that deserve this designation of ‘Wales First Green Town’.
The development should diminish the flood risk of the surrounding area
The area around the proposed new town is an area of significant flood risk. Recent analysis by the Environment Agency indicates that the Pant School , the Pant y Dderwen and the Ynys Ddu housing areas are all now identified as having a one in hundred year risk of flood Projected climate change will increase that risk.
The retail area potentially increases water run-off into the Pant flood plain and increases the risk of flood. A protective bund placed around the development will increase the flood risk to the surrounding areas.
We suggest that:
- The Environment Agency is asked to identify how specific design features in this development could diminish the flood risk of the surrounding area and that such measures are made a condition of any planning consent.
- All surfaces in the development are made of permeable materials and that measures are taken to control the flow of water into the Clun.
The traffic congestion of the surrounding area should be diminished
Road access to this retail development will be along the following routes
- The A4119 from Junction 34 on the M4
This route is already severely congested before 9 am and from 3pm onward. The congestion on this route is already a disincentive to any increased economic activity in the northern Ely and Rhondda valleys. The planned new housing and office development in Mwyndy will increase this congestion. If this retail development were to increase congestion on this route, the wider negative effects would be substantial. As part of this negative effect the ability of residents of Pontyclun to access the M4 would diminish further.
This route is already severely congested before 9 am and from 3pm onward. The congestion on this route is already a disincentive to any increased economic activity in the northern Ely and Rhondda valleys. The planned new housing and office development in Mwyndy will increase this congestion. If this retail development were to increase congestion on this route, the wider negative effects would be substantial. As part of this negative effect the ability of residents of Pontyclun to access the M4 would diminish further.
- The A473 from Llanharan
The planned development of a further 2000 houses in Llanharan will increase traffic flows along this road with further pressure on the junction with the A4119. If retail development adds to the traffic flow along this route it could well be that the proposed new housing development, a key component of the Local Development Plan, will become inaccessible and therefore unsaleable.
The planned development of a further 2000 houses in Llanharan will increase traffic flows along this road with further pressure on the junction with the A4119. If retail development adds to the traffic flow along this route it could well be that the proposed new housing development, a key component of the Local Development Plan, will become inaccessible and therefore unsaleable.
- The A473 from Tonteg
There has been huge investment in this route. However, if the route were to end in increased gridlock with the junction at the A4119 then the benefits of the investment will be lost. It is imperative that the new retail development does not increase the traffic flows through this junction.
-The A4222 from Cowbridge and Llanharry through Pontyclun Village
This route suffers congestion in the periods around school opening and closing. If the retail development adds to traffic flows during these period then it will become difficult to enter or leave Pontyclun.
Neither the developer or ourselves can accurately predict the impact of the retail development on these traffic flows. However, we can be certain that the roads do not have the capacity to carry an extra 12000 cars on a peak day. The Development is planning on building car parking for 3000 cars. This anticipates that at peak times there will be sufficient people visiting the retail park to use the 3000 car parking spaces. From this we should also anticipate that there will be a turnover of cars in the car parking spaces. People will on average spend two hours at the retail park. This means that during the day each car parking space will be filled by three to four cars. In total on a peak day there could be an extra 12000 cars on the roads into and around Pontyclun. The proposals for amendments to the roads would not be able to deal with this increase in traffic.
We understand that the developer is intending to charge for car parking at the retail park. There is evidence that where this is the case, people will look for local parking with no charge. The closest residential streets are Pant y Derwen and Ynys Ddu. We are concerned that by charging for car parking people will try to park in these residential areas. Encouraging visitors to use other forms of transport to access the retail park will hopefully discourage this behaviour
The LDP notes that ‘Development throughout the County Borough will be directed to locations that offer a choice of modes of transportation. Particular importance will be placed on ensuring that development both supports and, where necessary, contributes towards the development of a modern integrated transport system.’
To diminish the traffic congestion we propose:
- the provision of a wide network of pedestrian and cycle access to the development which would provide access to the development and provide safe routes to Y Pant school;
- providing walkways which link the development to Pontyclun train station;
- providing a free ‘Park and Ride facility at Junction 34 which is linked to the development by a dedicated bus lane on the hard shoulder of the A4119 with a shuttle service to the retail development;
- the number of car parking spaces are significantly reduced;
- that retail provision in the New Town should not increase existing retail provision on the site by more than 25% until the proposed new grade separated junction at the intersection of the A4119 and the A473 is constructed; and
- replace the pedestrian and cycle bridge over the road between Talbot Green and the development
- the provision of a wide network of pedestrian and cycle access to the development which would provide access to the development and provide safe routes to Y Pant school;
- providing walkways which link the development to Pontyclun train station;
- providing a free ‘Park and Ride facility at Junction 34 which is linked to the development by a dedicated bus lane on the hard shoulder of the A4119 with a shuttle service to the retail development;
- the number of car parking spaces are significantly reduced;
- that retail provision in the New Town should not increase existing retail provision on the site by more than 25% until the proposed new grade separated junction at the intersection of the A4119 and the A473 is constructed; and
- replace the pedestrian and cycle bridge over the road between Talbot Green and the development
The development should be part of a network of safe cycling and walking routes
Sustrans has already submitted plans for cycle and walking routes in this area using former rail routes and other routes. These plans have not been implemented in part through a lack of funding.
We propose that
• that there is further dialogue with Sustrans to identify routes that will encourage cycle and walking mobility in the areas of Pontyclun and Talbot Green areas linking to the existing cycle route to Pontypridd and the proposed route to Tonyrefail
• the funding of these routes should be one of the community facilities provided by the developer.
The area of the Pant Marsh and the Coed yr Hendy are protected and made accessible so that it is natural green area for visitors to the retail park and for local residents
• that there is further dialogue with Sustrans to identify routes that will encourage cycle and walking mobility in the areas of Pontyclun and Talbot Green areas linking to the existing cycle route to Pontypridd and the proposed route to Tonyrefail
• the funding of these routes should be one of the community facilities provided by the developer.
The area of the Pant Marsh and the Coed yr Hendy are protected and made accessible so that it is natural green area for visitors to the retail park and for local residents
Pant Marsh is an area of scientific interest and we are pleased to note that the developers are undertaking surveys of the flora and fauna of the area. We believe that it is important that the development, which is in such close proximity to this area, should be developed in such a way that it will have limited impact on the marsh. There is concern that the development may cause increased amounts of water flowing into a smaller area and therefore changing the nature of the Pant Marsh. It is a beautiful area and we believe that making it more accessible will enhance the attraction of the retail park .
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;
• all recommendations resulting from continuing survey work of the ecology of the Pant Marsh are fully implemented;
• 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;
- all surfaces in the development are made of permeable materials and that measures are taken to control the flow of water into the Clun;
- the development is designed to bring the green areas into the town and facilitate walking access into the green areas.
• the New Town Development should not extend beyond the existing brown field into the Site of Important Nature Conservation;
• all recommendations resulting from continuing survey work of the ecology of the Pant Marsh are fully implemented;
• 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;
- all surfaces in the development are made of permeable materials and that measures are taken to control the flow of water into the Clun;
- the development is designed to bring the green areas into the town and facilitate walking access into the green areas.
Conclusion
In response to the questions still being asked by the Planning Inspector we believe that the LDP should be amended to include the positive suggestions outlined above.
We believe that outline planning permission should not be granted until a master plan is developed that takes into account the suggestions above and that there is further consultation with the residents of Pontyclun.
Yours sincerely
Margaret Griffiths
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