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
Mark Jackson
Scarborough GroupDear Mr Jackson
Proposed New Town Development north of Pontyclun
As you will recall 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. We were pleased that you were able to attend this meeting. 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 Staedler 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 wellbeing 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.
The adopted LDP contains a plan called the 'Indicative Concept Plan' which has been agreed with CCW and RCT. This indicates the area on which the town centre apart from the roads can be constructed, which is only the areas of the former Purolite, Staedtler and Leekes, although it is necessary to take an access from the Vale of Glamorgan Roundabout (opposite McDonalds) which passes through the northern part of Pant Marsh.
- not include forms of retail provision which directly compete with the scale and character of retailers in Pontyclun
In order for this to be a successful town centre, there will be a need for a wide variety of retail and business accommodation. The retail units will be aimed predominantly at national multiples. There will however, be units available to a variety of more local retailers also, however we see the New Town Centre as serving a very different function than the shops in Pontyclun and the other surrounding villages.
It is likely that the development will influence businesses in the villages, which can be expected to be positive in some cases and perhaps negative in others. It is impossible to predict exactly what will happen, but with the main part of the town not being due to open until 2016 there will be time to prepare, and for many local businesses there will be new opportunities to be exploited.
- not impede access to Pontyclun village
We do not believe that our proposals would impede access to Pontyclun, but we are happy to discuss any specific issues that the Community may have now, or at any time in the future.
- 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
We do not believe that we are able to provide cycleways due to environmental considerations, but we are in discussion with the council regarding the local footpaths.
- 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.
We are happy to explore the opportunity to do this as and when possible, and to discuss this further with the Community.
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.
This is addressed in response to one of the points above
- 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
The development will improve access from the east as part of Phase 1(the foodstore) linking Glamorgan Vale Retail Park with Cowbridge Road.
Other improvements will come with Phase 2, including a new pedestrian access to the school linking with the town centre.
Other improvements to north (across the A473) and south (through the woodland) are being discussed with the council.
- 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.
An ongoing management regime for Pant Marsh and the woodland will be agreed with the Council as part of the planning permission. Improved access to the marsh itself is not possible due to the need to protect the SINC.
- providing walkways which link the development to Pontyclun train station
Does this mean an enhancement of the existing pavements and pedestrian facilities? We are not sure of what is being suggested here.
- 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
The proposed development is predominantly aimed at the communities in the local area. It is not intended, and neither will it operate, as a regional centre that would attract significant trade from traffic on the M4. The benefit of a Park and Ride site is to commuters, particularly those travelling from the area into Cardiff. A Park and Ride site at Junction 34 will have little noticeable effect on the development.
It is very likely that to provide this facility and road would require land which is outside our control.
Essentially this would be a very expensive undertaking which our advisers tell us would do very little to address problems on the local highways network.
- 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
Drainage will be designed in accordance with Sustainable Urban Drainage System best practice.
Storm water will indeed be held in underground tanks and then allowed to flow gradually back to the watercourses when levels have subsided. In this way the new scheme will actually reduce the flooding impact compared to the existing / previous use of the site.
Ground source heat pumps do not work in the way that this suggestion seems to assume. In such a system the water needs to be drawn from deeper under the ground where temperatures are higher, not from stored rainwater.
- combining renewable energy sources with the highest levels of insulation with the aim of achieveing a carbon neutral development
The development is targeting a BREEAM Excellent (Retail) rating which incorporates a number of the above suggestions.
- designating a proportion of retail facilities for the marketing of products produced within the County Borough
A variety of retail units will be designed so that these are attractive to local traders (though presumably not to the detriment of Pontyclun and surrounding villages).
- the mitigation of climate change through enhanced control of flood risks in the surrounding areas.
The flood attenuation proposals have been agreed with the Environment Agency and reduce the flood impact for the school and the homes at Yny Ddu, amongst other areas.
Apart from one small corner, the site itself is not on the flood plain and so the development itself does not cause a significant change in the flood position.
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.
See previous answers in this regard.
- All surfaces in the development are made of permeable materials and that measures are taken to control the flow of water into the Clun.
See answer above re SUDS. Rainwater will be stored in underground tanks and the runoff will actually be less than the site as previously developed.
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.
- 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 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 develpoment 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.
Advice from our Highways Advisers is as follows:-
The traffic impact of the scheme has been assessed in detail taking into account observed effects elsewhere in terms of traffic attraction, and industry standard traffic models as tools from which judgments about effects can be made.
We are satisfied that the amended road network can accommodate the demand associated with the site and the parking.
It is worth noting that a significant proportion of traffic to this site is traffic that is already elsewhere on the network. This site will redirect traffic if those users consider this location to be more convenient than their current destinations. Drivers will act to minimise their inconvenience, and as a result we expect significant shift away from locally based movement into Cardiff to this new town centre instead. A substantial proportion of trips will be from local origins.
There will be an effect on the A4119/A473 junction. The Council¡¦s approach to that is for a tariff payment to be made, and for the Council itself to undertake improvements to this junction at an indeterminate time in the future. At the public consultation there was scepticism from the public as to whether the Council would be able to deliver this within a reasonable time period. As a result, the Developer is now considering undertaking works directly to this strategic junction. If it does so then this will provide benefits not only for access to this new town centre, but to strategic through traffic as well.
It should also be noted that the peak times for shopping trips (weekends) do not generally coincide with the weekday peak times for business / commuter travel (although there will, we acknowledge, be some times when this is not the case).
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 car park charging strategy is not yet set (as the centre will not open until 2016 at the earliest, and charging will depend to a large degree upon the wishes of future tenants).
Any car park charging regime that discourages shoppers (and forces them to park some distance from the shops) will not be commercially viable.
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;
(As stated earlier) the development will improve access from the east as part of Phase 1 by linking Glamorgan Vale Retail Park with Cowbridge Road. Additional improvements will come with Phase 2, including a new pedestrian access to the school which will link with the town centre. Other improvements to the north and south are being discussed with the Council.
The connections do more than just provide access to the site. The design of the site, together with the connections, provides better permeability between communities, reducing severance and promoting interaction within the community.
- providing walkways which link the development to Pontyclun train station;
(As mentioned earlier) does this mean an enhancement of the existing pavements and pedestrian facilities? We are not sure of what is being suggested here.
- 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;
This point is dealt with earlier.
- the number of car parking spaces are significantly reduced;
A certain level of parking is needed to avoid the problems which beset Talbot Green Retail Park and Tesco. The scheme is also designed with multiple entrance points so that the single access problem (and limited storage of Talbot Green Retail Park's access road) is avoided.
The number of parking spaces has been set to accommodate demand. Reduction in car parking spaces will result in car parking on adjacent streets, and / or reduce the appeal of the town centre development and impact upon its viability. An under-provision of car parking would also dissuade operators from taking a tenancy in the first place (and the scheme development would not proceed).
- 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
Unfortunately we cannot commit to this suggestion because the provision of the new junction is uncertain. The Council have stated that this grade separated upgrade to the junction may not actually be pursued, and that alternative proposals may come forward.
We appreciate that this is very unsatisfactory for local communities, and we share your concerns; there is little benefit to us in ineffective junctions leading to traffic congestion as this will adversely impact upon the commercial viability of the scheme (i.e. tenants may not be willing to commit to the scheme). We therefore continue to discuss this issue with the Council and seek to 'keep our options open'.
- replace the pedestrian and cycle bridge over the road between Talbot Green and the development
The proposal is to improve the linkages to Talbot Green as part of Phase 2, which will involve the replacement of the bridge with either an 'at-grade' crossing in the traffic light phasing, or with another bridge.
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
-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
There are various proposals being discussed with the Council in relation to links to the north and south. However, much of the existing network is outside our control.
-the funding of these routes should be one of the community facilities provided by the developer.
Discussions are ongoing between RCT and Sustrans regarding funding.
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;
See previous comments
-all recommendations resulting from continuing survey work of the ecology of the Pant Marsh are fully implemented;
This will form part of detailed provisions in the planning submission documents and will be agreed with the Council's own ecologists and relevant statutory consultees. The provisions will be enforced through planning conditions or obligations (as appropriate).
-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;
We understand that the junction improvements are contained within highway land.
- all surfaces in the development are made of permeable materials and that measures are taken to control the flow of water into the Clun;
See previous comments in relation to storm water and flood management.
- the development is designed to bring the green areas into the town and facilitate walking access into the green areas.
There will be a number of public spaces through the scheme, although they will be more 'urban' in design, in-keeping with the purpose and nature of the development. Connections to existing green areas is dealt with elsewhere in our responses to this letter.
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.
The LDP is now adopted, and therefore these amendments cannot (as far as we understand) be amended in this way. Many of the suggested provisions would be too detailed to be included in the LDP, and others simply do not accord with policy and therefore would not be included in the LDP.
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.
The planning application and determination process will allow the application to be commented upon by all interested parties, however we are more than willing to continue open dialogue with all local communities. Clearly however we must take due notice of all affected communities, and not give any unwarranted preferential treatment to Pontyclun.
Yours sincerely
Margaret Griffiths
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