Claire Williams and Len Arthur
46 Heol Miskin
Pontyclun
CF72 9DQ
Service Director Planning
Rhondda Cynon Taf County Borough
Council
Sardis House
Sardis Road
Pontypridd
CF37 1DU
Pontyclun New Town Working Group
Representation on Planning
Application 11/1330/13 (addendum and revised plans received August 2012).
Land adjacent to Cowbridge Road
and A473 (inc Leekes Dept Store, former Purolite works and Staedtler factory
site), Talbot Green, CF72 8XU.
Dear Colleagues
Thank you for the opportunity to
respond to the amended application.
We note that the amended
application is almost exclusively responding to the points of negotiation
between the developed and RCT. Consequently, we are very concerned, that an
opportunity has been lost to respond positively, to the many points raised by
the local community, in the first consultation process. This does not reflect
well on the priorities of the developer or RCT and raises serious questions
about the validity of the consultation process.
It is with great regret
therefore, that we find ourselves in the situation of having to repeat all the
points made in our first letter of consultation relating to access, the
environment, the design, thriving local communities, activity and safety and a
fair approach for all. These are detailed in the rest of the letter.
The development does not look
like a town centre, still resembling an out of town shopping park. Moreover, it
appears to be one that is detached from the local community with a lack of
pedestrian and cycle access. In short, it looks like a concrete walled and road
moated privatised space, excluding people when the shops are shut or when they
do not have much money to spend. Our proposals seek to address these points and
we have every expectation that they will now be seriously considered.
What follows is largely a
re-submission of our objection sent to you in December 2011. Additional commentary is included and is
indicated in italics together with the date: 09.2012 in bold.
The applicant has provided a
Design and Access statement which states that the application should result in
a town centre which would be
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 and
with RCT Council officials.
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.
09.2012: The new application
of August 2012 does not appear to refer to this intersection. Taking the two
applications together no acceptable resolution of the effect of increased
traffic on this intersection is offered. On this reason alone it would be
irresponsible to consent to a retail development on the proposed scale.
Road access along the A4222
and through Pontyclun Village Centre
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 and Y Pant Secondary School.
The applicant provides no solution or mitigation for the increased traffic on
this road.
09.2012: Again, it is
disappointing that the revised application offers no suggestion as to how steps
may be taking to ensure that Pontyclun village can retain traffic flows that
all residents ease of access to their homes, schools and services.
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 and
Cross Inn. An encouragement to pedestrian based retailing would link the
existing retail parks (Talbot Green, Tesco Extra and Glamorgan Vale) to this
development; but again the assumption appears to be that the consumer moves
from one site to another by car, increasing road congestion.
09.2012: We very much welcome
the new proposal in the revised application that there should be a pedestrian
path from Cefn yr Hendy, through the Hendy Woods and across the River Clun.
This will allow over a thousand residents pedestrian access to the retail
development and to the Pant School. We are told by Sustrans that making such a
path usable by cyclists also is quite compatible with the path being
complementary to is environmental context.
We remain very disappointed that there is no pedestrian route from this
proposed retail development to that already existing in the Vale of Glamorgan
Retail Park and the Talbot Green Retail Park. A shopper who wishes to make at
purchases at Marks and Spencer, Halfords and Sainsbury would be forced to make
at least three car journeys. A reasonable definition of a ‘town’ is that it is
a public space within which a citizen can walk from store to store. This
application does not conform to such a criterion. It still appears as an
out-of-town retail development, a private space accessed by car., sitting
alongside but rigidly separated from two similar retail developments.
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
09.2012: It is hugely
disappointing that the revised application does not even include a proposal for
the rail line to be a cycle route. It refers in passing to the RCT Council
having as aspiration for such a cycle path but it should be noted that the
Council recently withdrew its planning application for such a route. This cycle
route must be provided as an integral part of this proposed development. It
should have been included in the revised application. Without its inclusion the
application makes not one single proposal for cycle access and on this point
alone the application does not merit approval.
2.0 Environmentally sensitive
The Applicant has the stated
objective that the development should be environmentally sensitive.
Development on the Greenfield
is not justified
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 site.
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 very deliberately constrained car parking to one
parking place to 25 m2 of retail space and then achieved commercial viability
by investing in non-car access.
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. There is no reason at all therefore why the
quality, the design and the scale of this development should not be as required
by the community interest.
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.
09.2012: The original
application focussed all its design commitments and illustrations on the
internal space of the development and on the vista from the A4222. The revised
application offers the public for the first time an illustration of the
development as seen from the A473 and the north. The illustration is truly
horrendous. From this vista the development will be a solid concrete wall over
20 meters high and several hundred meters long. It will invite comparisons with
the Berlin Wall which was actually lower. The proposed design of this northern
wall gives a clear message: “Keep Out unless you have a car and willingness to
pay a parking charge”. It is not the design of a welcoming publicly accessible
‘New Town Centre’.
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
09.2012: Since the original
application all the evidence is that the demand for out-of-town retail of
non-food goods has been falling at a significant rate. This is in part the
result of the recession and may therefore be cyclical and, in addition, there
may be local demand factors offsetting this trend. However, most retail
analysts believe that there is a very important structural change taking place
as consumers switch their purchases to the internet.
It is unfortunate that no reference is made to these changes in the
revised application. It would be irresponsible to provide a Phase 1 consent on
the Greenfield whilst leaving the development of the former factory sites to
the vagaries of a very uncertain and changing retail market.
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.
Our original submission included
a copy of the questionnaire delivered to all residents in Pontyclun and
circulated widely in Talbot Green.
We trust that the points raised
in this letter will be meaningfully considered and responded to by RCT and its
officers. We look forward to your response and our invitation to make a
presentation to the council meeting which will consider the application.
Yours etc.
