Barratt Homes (South Wales) Ltd. Residential redevelopment at...

Barratt Homes (South Wales) Ltd.

Residential redevelopment at former

Llantarnam Comprehensive School site,

Llantarnam Road

Cwmbran

Planning Statement

May 2016

WYG Planning & Environment,

5th Floor, Longcross Court,

47 Newport Road,

Cardiff

CF24 0AD

Tel: 02920 829200

Email: [email protected]

Document Control

Project: Residential redevelopment at Llantarnam Comp, Cwmbran

Client: Barratt Homes (South Wales) Ltd.

Job Number: A094502

File Origin:

Document Checking:

Prepared by: Rob Mitchell Signed:

Checked by: Peter Waldren Signed:

Verified by: Peter Waldren Signed:

Issue Date Status

1 April 2016 Draft

2 May 2016 Final

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Contents Page

1.0 Introduction ....................................................................................................................... 1

1.1 Background ............................................................................................................................ 1

1.2 Planning Statement ................................................................................................................. 1

1.3 Application Submission ............................................................................................................ 2

2.0 Planning Context ................................................................................................................ 3

2.1 Introduction ............................................................................................................................ 3

2.2 Application Site ....................................................................................................................... 3

2.3 Planning History ...................................................................................................................... 4

2.4 The Proposed Development ..................................................................................................... 5

2.5 Pre-Application Discussions ...................................................................................................... 5

3.0 Planning Policy Context ...................................................................................................... 7

3.1 Introduction ............................................................................................................................ 7

3.2 The Development Plan – Torfaen LDP (2013) ............................................................................ 7

3.3 Material Considerations .......................................................................................................... 13

3.4 Supplementary Planning Guidance .......................................................................................... 19

3.5 Summary .............................................................................................................................. 19

4.0 Planning Considerations ................................................................................................... 21

4.1 Introduction .......................................................................................................................... 21

4.2 Previously Developed Land ..................................................................................................... 21

4.3 Principle of residential redevelopment ..................................................................................... 21

4.4 Housing Provision .................................................................................................................. 23

4.5 Design, Access and Layout ..................................................................................................... 25

4.6 Open Space and Landscaping ................................................................................................. 28

4.7 Transport and Accessibility ..................................................................................................... 30

4.8 Ground conditions ................................................................................................................. 32

4.9 Noise ................................................................................................................................... 33

4.10 Ecology ................................................................................................................................ 33

5.0 Summary and Conclusions ............................................................................................... 36

Appendix Contents

Appendix A – Site Location Plan

Appendix B – Site Layout Plan

Residential redevelopment at the former Llantarnam Comprehensive School, Llantarnam, Cwmbran

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1.0 Introduction

1.1 Background

1.1.1 The 21st Century Schools and Education Programme is a collaboration between the Welsh

Government (WG), the Welsh Local Government Association (WLGA) and Welsh local authorities. It

is a long-term, strategic capital investment programme which aims to create a generation of 21st

century schools in Wales. The programme seeks to rationalise education provision across Wales by

focussing resources to ensure schools are provided in the most appropriate places.

1.1.2 As part of this rationalisation, in Torfaen Borough, Llantarnam and Fairwater secondary schools have

been closed and replaced by the newly opened Cwmbran High School1. Planning permission has

recently been granted for Llantarnam Community Primary School; a replacement primary school now

being developed on part of the former Llantarnam Comprehensive School site.

1.1.3 Torfaen Borough Council has agreed the sale the remainder of the former Llantarnam Secondary

school site for redevelopment purposes. The sale of the site will enable continued investment in the

strategic schools programme.

1.2 Planning Statement

1.2.1 WYG Planning and Environment has prepared this Planning Statement in support of a full planning

application for the redevelopment of the former Llantarnam Comprehensive School site to deliver

no.228 residential dwellings (Class C3) with associated open space and landscaping. The application

is submitted on behalf of our client, Barratt Homes (South Wales) (“The Applicant”).

1.2.2 The remainder of this Statement is structured as follows:

Section 2: provides the background to the site, its planning history, and a review of pre-

application discussions;

Section 3: considers the relevant planning policy context;

Section 4: evaluates the proposed development in light of the principal considerations; and

Section 5: provides a summary of conclusions.

1 Opened on the Fairwater School site.


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1.3 Application Submission

1.3.1 The information prepared in support of this planning application follows pre-application discussions

with officers at Torfaen Borough Council. In addition, regard has been paid to the Council’s

Application Checklist in formulating the application package; which includes the following documents

referred to throughout this Statement:

Site location plan, existing and proposed layout plans;

Design and Access Statement;

Phase 1 Habitat Survey (Hawkeswood Ecology);

Bat and Bird Survey (Just Mammals Consultancy);

Geotechnical and Geo-environmental report;

Noise Assessment;

Drainage Strategy;

Landscape Strategy;

Arboricultural Assessment;

Transport Assessment; and

Travel Plan.


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2.0 Planning Context

2.1 Introduction

2.1.1 The purpose of this section is to set out the background to the proposal and to provide the context

for key considerations in the determination of the application. It includes a description of the site

and its surrounds, a review of the relevant planning history, planning policy designations and a

summary of pre-application discussions.

2.2 Application Site

2.2.1 The application site is the former Llantarnam Comprehensive School site at Llantarnam Road,

Cwmbran which measures approximately 6.9ha in total. The site is occupied by mainly brick-built,

two-storey educational (and leisure) buildings, set within surrounding school grounds i.e. amenity

open space, parking and playing fields. The site is located in the Llantarnam area of Cwmbran,

approximately 1.5 miles south of Cwmbran Town Centre and 4.5 miles from Newport City Centre.

Llantarnam Comprehensive school closed permanently in September 2015.

2.2.2 The north of the site is mostly occupied by the main school buildings, a leisure centre pool building,

car parks and internal road. The remainder of the site (primarily to the south) is amenity grassland,

parking area and playing fields. Access/egress is from Llantarnam Road.

2.2.3 The site is previously developed land which sits within the defined Cwmbran settlement boundary.

Immediately to the west of application site are playing fields. To the south-west of the site is

Llantarnam Business Park which is separated from the application site by a copse of mature trees.

Directly adjacent to the site to the east lies mixed two storey residential properties lining Llantarnam

Road. Notwithstanding the nearby mix of uses the surrounding area is predominantly residential in

character. The site lies on an existing bus route which provides linkages across Cwmbran, Newport

and further afield. The nearest bus stops lie directly adjacent to the site on Llantarnam Road

2.2.4 The application site is unallocated in the adopted Torfaen LDP and relatively unconstrained (as

indicated on the adopted Constraints Map). The site’s south-western boundary is a designated Site

of Important Nature Conservation (SINC). The sparse trees on site are not subject to any Tree

Preservation Orders (TPO). A public right of way (PRoWs) crosses the site from east-west and a

further route which has not yet been added to the definitive map runs north to south. The site lies


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within Flood Zone A on the TAN 15 Development Advice Maps and is categorised at low risk of

flooding.

2.2.5 In regard to utilities, the site is currently served by water, electricity, telecommunications and

sewerage disposal, each of which are considered capable of adaption to serve the proposed

development.

2.2.6 A site location plan outlining the application site extent and surrounds is attached at Appendix A

for reference.

2.3 Planning History

2.3.1 In April 2015 planning permission was granted for the part demolition of the comprehensive school

and erection of a primary school, including landscape and engineering, parking and access works

(pp ref: 15/P/00098). In determining the application officers reasoned:

The loss of playground/court will be mitigated by the relocation of pupils to Cwmbran High

School. An assessment of recreational provision confirmed the proposed playing field provision

exceeded minimum requirements. An assessment of community use and recorded demand of

hard surface courts satisfied Fields in Trust (FIT) who did not object to the proposal.

The proposal will not have a detrimental impact on nearby occupiers through loss of privacy or

overbearing impact. Noise will be attenuated (secured by condition). The impact of the proposal

will be less than the existing building.

The design of the proposal adopts a modern approach which does not detract from the visual

appearance of the wider predominantly residential area.

The highway’s department raised no objection. The proposal provides adequate parking space.

The proposed access is acceptable to provide access and egress to the site and would not be

harmful to any road users.

2.3.2 In summary, the proposed scheme was considered to enable an improvement to educational

provision. There would be no overriding unacceptable impact on the amenities of surrounding

occupiers and there would be no unacceptable impact on landscape or the ecological value of the

site. Furthermore, the scheme was determined to comply with highways requirements.


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2.3.3 The above granting of permission for a new primary school facilitates educational improvements

across the borough. In a similar manner, the capital receipt of the remainder of the

formercomprehensive school site (which has been determined to be surplus to requirements) will

help to deliver further educational improvements. In addition, a residential redevelopment will

deliver much needed housing (including an affordable element) to the authority’s housing stock on

previously developed land at a highly sustainable location.

2.4 The Proposed Development

2.4.1 As set out in the preceding section the application site is now surplus to educational requirements

and a residential redevelopment is now sought. A full planning application is submitted for the

redevelopment of the former school site for no. 228 residential dwellings (Class C3) with associated

open space and landscaping. The proposed site layout plan is attached at Appendix B for

reference.

2.4.2 Prior notification for the demolition of existing buildings is the subject of a separate application.

2.4.3 The replacement primary school to be constructed immediately to the west of the site (at the site of

existing playing fields) is subject to separate proposals. Notwithstanding this, the proposed access

arrangements are laid out in accordance with the access arrangements permitted under pp ref:

15/P/00098.

2.5 Pre-Application Discussions

2.5.1 A pre-application meeting was held between the applicant, WYG and Council officers (including

development control, forward planning, estates and highways) on 18th September 2015.

Discussions centred on site specific constraints and design requirements. Key points drawn from

officer feedback included:

A requirement for 19-21 metre window distances;

A requirement for a 20 metre buffer zone from dwelling facade to Local Equipped Area for Play

(LEAP) activity zone;

Request for the Local Area of Play (LAP) to be located to the east of the application site;

Preference against the provision of car parking along main access routes through the

application site;


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Any car parking courts to be limited to 8-10 spaces maximum;

Request that no more than 2no. dwellings are served by a single private driveway;

Preference against the positioning of dwellings on the direct access route to the future

Llantarnam Community Primary School site (to the west).

2.5.2 The pre-application advice has helped inform the site layout and design of the proposed

development. The design of the proposals is considered in more detail in the accompanying Design

and Access Statement.


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3.0 Planning Policy Context

3.1 Introduction

3.1.1 Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires that planning applications

be determined in accordance with the Development Plan unless material considerations indicate

otherwise. This section provides an overview of adopted and emerging planning policy, as well as

supplementary guidance produced by Torfaen Council.

3.1.2 The statutory development plan is the Torfaen Local Development Plan (LDP), which was adopted in

December 2013. The LDP is supplemented by guidance provided in the Planning Obligations SPD

and Affordable Housing Delivery Statement which are material considerations in the determination of

the proposed development. This is also true for national planning policy - in the form of Planning

Policy Wales Edition 6 (PPW), the Wales Spatial Plan (WSP), and Technical Advice Notes (TAN).

3.2 The Development Plan – Torfaen LDP (2013)

3.2.1 Section 1.0 of the LDP details the Council’s planned reorganisation of education provision. The

Welsh Government launched its 21st Century Schools Programme in March 2010, based on a

strategic approach to capital investment.

3.2.2 Torfaen Council submitted a Strategic Outline Programme (SOP) 21st Century Schools to the Welsh

Government in October 2010. The programme, if fully realised, aims to transform how teaching and

learning is provided throughout the borough: The Programme includes:

A new post-16 centre;

New or refurbished secondary schools;

8 new primary schools;

4 extended primary schools;

5 refurbished primary schools;

Primary schools with ‘all through’ provision;

Secured future for expanding Welsh medium provision;

Schools of the right size in the right place;

All schools fully inclusive;

All pupils and staff safeguarded;

Technology rich environments;


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Sustainable schools;

A reduction in surplus places; and

The elimination of the £32m maintenance backlog.

3.2.3 In respect of land use issues the LDP notes that implementation of the Programme may require

significant land release.

3.2.4 There are 18 overarching objectives listed in the LDP which, inter alia, include:

1. To promote health and well-being through the provision of development including: community

facilities, leisure and outdoor recreational opportunities which are accessible to all.

2. Ensuring the highest quality designed developments, and deliver safe, healthy and attractive

environments.

3. To provide opportunities for the establishment of a network of quality educational facilities

which serve local communities.

4. To ensure that all new development reflects best practise in sustainable design and location,

construction and operation.

5. To protect, manage and enhance biodiversity and ecological networks across Torfaen.

6. To ensure the allocation of an appropriate quantity and variety of housing sites in sustainable

locations, well served by essential facilities and accessible by a range of transport modes.

7. To develop integrated and efficient transport infrastructure and public transport networks which

are accessible and attractive to all, and encourage a reduction in private car use.

3.2.5 Policy S1 relates to urban boundaries which are identified on the accompanying Proposals Maps.

The boundaries: a) allow for development which would contribute to the creation and maintenance

of sustainable communities and b) define the urban area, within which there is a presumption in

favour of development.

3.2.6 Under Policy S2 development proposals need to demonstrate they have taken account of, inter alia,

the following principles and where relevant that they:

Contribute to the regeneration of existing communities;

Meet sustainable transportation and infrastructure priorities, including reducing the reliance on

the private car and encouraging the use of more sustainable modes of transport;

Conserve and enhance the natural and built environment;


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Promote the efficient use of land;

Maximise the efficient use of existing community infrastructure;

Utilise sustainable construction techniques; and

Are located within the urban boundary.

3.2.7 Development proposals should mitigate the causes of further climate change and adapt to the

current and future effects of climate change through, inter alia, sustainable design which achieves

energy efficiency (Policy S3).

3.2.8 Proposals must have full regard to the context of the local natural and built environment and its

special features through promoting local distinctiveness; delivering a mix of uses; and ensuring

location and layout integrates effectively with local accessibility (Policy S4).

3.2.9 In the adopted Torfaen LDP provision is made for the development of 4,700 dwellings in Torfaen (by

identifying sites for approximately 5,740 dwellings) with approximately 2,275 dwellings to be

delivered in Cwmbran. The Council’s housing figures include an allowance of 289 dwellings on

‘windfall’ sites’ (10 or more dwellings) over the Plan Period 2010-2021 remaining (Policy S5). An

approximate 22% over-allocation has led to the identification of land for approximately 5,740

dwellings.

3.2.10 Policy S7 requires development proposals to ensure the conservation and enhancement of the

natural, built and historic environment with respect to, for example, biodiversity resources; geo-

diversity resources; water environment; and landscape setting.

3.2.11 Policy S8 relates to planning obligations. Obligations will be required on development proposals

through S106 legal agreements where they are necessary to address the impacts of development

and to make the proposal acceptable in land use planning terms, targeted to achieve the key

priorities of, inter alia:

Affordable housing;

Open space, children’s play spaces and formal outdoor recreation facilities;

Investment in educational provision;

Highways and transport infrastructure management and improvements (including walking and

cycling infrastructure and public transport facilities and services); and


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Community facilities; and

Public realm improvements and public art.

3.2.12 Policy BW1 is a general, borough wide policy. The policy sets out a number of development

requirements under four main headings. With respect to amenity and design:

i) it should not constitute over development of the site in terms of the scale, density, massing and

form of the development;

ii) The design and visual appearance of the proposal must take account of the local context;

iii) the proposal respects the urban fabric of the area in terms of pattern of development and the

setting of the site etc;

iv) includes a landscaping and planting scheme, which enhances the site and the wider context;

v) does not have an unacceptable impact upon the amenities of the occupiers of adjoining or

neighbouring properties;

vi) designs out the opportunity for crime and anti social behaviour; and

vii) promotes inclusive design, both for built development and access within and around the

development.

With respect to the natural environment:

i) The proposal does not result in unacceptable adverse effects in respect of land contamination,

instability or subsidence; air, heat, noise or light pollution; landfill gas; water pollution; or flooding,

from or to the proposal;

ii) The proposal does not result in significant adverse effects on the integrity of a European

designated site or its designated features in the context of the site’s conservation objectives;

iii) The proposal contributes to the conservation and/or enhancement of the strategic biodiversity

network of Torfaen and does not result in a significant adverse effect on the network;

iv) The proposal does not result in the unacceptable loss or harm to features of landscape

importance including trees and woodland that have natural heritage or amenity value; and


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vi) The proposal does not have an unacceptable adverse impact upon the water environment or

pose an unacceptable risk to the quality and quantity of controlled waters (including groundwater

and surface water), and where practicable and reasonable improves water quality.

With respect to the built environment:

i) The proposal does not detrimentally affect the character of the immediate and surrounding built

environment; and

ii) Where practicable, existing construction materials on the site are re-used or recycled

With respect to the provision of utilities:

i) The proposal does not prejudice the existing or proposed level of service provision; and

ii) Development can be served by the existing public foul sewerage system and, if necessary, ensure

satisfactory improvements are provided prior to becoming operational.

With respect to design and transport:

i) The proposal should be designed in accordance with the relevant national and local highway

design guidance and where appropriate, the Council’s adopted parking / cycling provision standards;

ii) New access roads are designed to promote the interests of pedestrians, cyclists and public

transport before the private car;

iii) The proposal takes account of restrictions relevant to the class of road, ensuring movements and

speeds are controlled through appropriate design;

iv) The road network is capable of sustaining additional traffic generated and allows for adequate

servicing, with a Transport Assessment being provided where appropriate; and

v) The proposal is informed by a Green Travel Plan where appropriate.


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3.2.13 Under Policy H4 the Local Plan states that in order to achieve a target of approximately 1,132

affordable homes over the period to 2021, the Council will, on all residential sites over 0.1ha seek to

negotiate the on-site provision of up to 30% affordable housing and / or a payment in lieu of on-site

provision in the Cwmbran East & South Sub market Area by Housing Sub-Market Area.

3.2.14 Policy H5 relates to the provision for recreation, open space, leisure facilities and allotments.

Provision for children’s play areas, outdoor recreation, open space and leisure facilities will be sought

in conjunction with new residential developments based on specified minimum standards.

3.2.15 Policy CF3 relates to community facilities. Proposals resulting in improvements to the quality and

accessibility of community facilities, including schools, will be favourably considered. Development

proposals that would result in the loss of a community and/ or leisure facility will not be permitted

except where, inter alia: a comparable replacement facility can be provided; or the facility is no

longer required by the community it serves; or a reorganisation plan has been approved by the

respective responsible body.

3.2.16 Policy CF5 states development will be permitted on areas of formal and informal recreation space,

children’s play areas and amenity open space subject to it, inter alia: not causing or exacerbating a

deficiency of such space; the space does not have significant amenity value or quality; the need for

the development outweighs the need to protect the space; or the developer makes satisfactory

compensatory provision, which is of equal community benefit, value and quality.

3.2.17 Policy BG1 states development proposals will not be permitted where they would cause significant

adverse effects to local nature conservation designated sites (including the features of a Site of

Importance for Nature Conservation) unless it can be demonstrated that: the development could not

reasonably be located elsewhere and the benefits of the proposed development justifiably outweigh

the nature conservation or geological value of the site; and adequate mitigatory and / or

compensatory provision is made proportionate to; or an enhancement to the value of the ecological

resources or geological site lost.


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3.3 Material Considerations

LDP Evidence Base – Torfaen Housing Land Availability Study (2015)

3.3.1 The latest publicly available Joint Housing Land Availability Study is dated July 2015. It shows that

based on the residual method set out in TAN 1 Torfaen CBC has below 5 years housing land supply

i.e. 4.8 years.

Planning Policy Wales (PPW), January 2016

3.3.2 PPW (Edition 8) sets out the land use planning policies of the Welsh Government. It aims to ensure

the principles of sustainability and sustainable development is at the heart of the planning decision

making processes. Paragraph 4.2.2 states that the planning system provides for a presumption in

favour of sustainable development to ensure that social, economic and environmental issues

are balanced and integrated by the decision-taker when, inter alia, taking decisions on individual

planning applications.

3.3.3 In order to achieve a ‘sustainable development principle’ as advocated by the Well-being of Future

Generations (Wales) Act, the Welsh Government expects all those involved in the planning system to

adhere to, inter alia (paragraph 4.3.1):

• putting people and their quality of life at the centre of decision-making;

• taking a long term perspective to safeguard the interests of future generations, whilst at the

same time meeting needs of people today;

• respecting environmental limits e.g. mitigating climate change, protecting and enhancing

biodiversity, minimising harmful emissions, and promoting sustainable use of natural resources;

• taking account of the full range of costs and benefits over the lifetime of a development;

• working in collaboration with others to ensure that information and knowledge is shared to

deliver outcomes with wider benefits.

3.3.4 in contributing to the Well-being of Future Generations Act goals, planning policies, decisions and

proposals should, inter alia: (paragraph 4.4.3)


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• Promote resource-efficient and climate change resilient settlement patterns, through preference

for the re-use of suitable previously developed land and buildings;

• Play an appropriate role to facilitate sustainable building standards (including zero carbon) that

seek to minimise the sustainability and environmental impacts of buildings;

• Play an appropriate role in securing the provision of infrastructure to form the physical basis for

sustainable communities;

• Maximise the use of renewable resources, including sustainable materials (recycled and

renewable materials and those with a lower embodied energy); and

• Encourage opportunities to reduce waste and all forms of pollution and promote good

environmental management and best environmental practice.

3.3.5 Previously developed (or brownfield) land should, wherever possible, be used in preference to

greenfield sites (para 4.9.1). Paragraph 4.9.2 adds that many previously developed sites in built-up

areas may be considered suitable for development because their re-use will promote sustainability

objectives. This includes sites:

• in and around existing settlements where there is vacant or under-used land, commercial

property or housing;

• in suburban areas close to public transport nodes which might support more intensive use for

housing or mixed use;

• which secure land for urban extensions, and;

• which facilitate the regeneration of existing communities.

3.3.6 Paragraph 4.9.3 states: “if the Welsh Government’s objectives for the more sustainable use of land

and buildings and the re-use of previously developed sites are to be achieved, local authorities and

other stakeholders will need to be more proactive.”

3.3.7 Figure 4.1 of PPW notes the importance in Wales of enhancing the economic, social and

environmental well-being of people and communities i.e. the three pillars of sustainability.


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3.3.8 Development should be located so that it can be well serviced by existing infrastructure (para 4.7.2).

PPW promotes resource-efficient and climate change resilient settlement patterns that minimise

land-take and urban sprawl, especially through preference for the re-use of suitable previously

developed land and buildings (sections 4.6, 4.7 and 4.8).

3.3.9 Previously developed (or brownfield) land should, wherever possible, be used in preference to

greenfield sites (para 4.9.1). The re-use of land promotes sustainability objectives. The Welsh

Government will seek to ensure that: previously developed land is used in preference to greenfield

sites; new housing is well designed; and that the overall result of new development is a mix of

affordable and market housing that retains important landscape features (para 9.1.1).

3.3.10 LPAs must ensure that sufficient land is genuinely available or will become available to provide a 5-

year supply of land for housing, judged against the general objectives and the scale and location of

development provided for in the development plan (para 9.2.3).

3.3.11 Paragraph 9.2.11 states policies which seek to make maximum use of vacant urban land for housing

will need to distinguish between sites which need to be retained and areas which are genuinely

suitable for housing development. Where substantial new housing is to be permitted, plans should

include policies to make clear that developers will be expected to provide open space which is

reasonably related in scale and location to the development.

3.3.12 Higher densities should be encouraged on easily accessible sites, where appropriate, but these will

need to be carefully designed to ensure a high quality environment. In particular, local planning

authorities should adopt a flexible approach to car parking standards (para 9.2.12).

3.3.13 New housing developments should be well integrated with and connected to the existing pattern of

settlements (para 9.3.1). In determining applications for new housing, LPAs should ensure that the

proposed development does not damage an area’s character and amenity. Increases in density help

to conserve land resources, and good design can overcome adverse effects, but where high

densities are proposed the amenity of the scheme and surrounding property should be carefully

considered (para 9.3.4). High quality design and landscaping standards are particularly important to

enable high density developments to fit into existing residential areas.

3.3.14 Where development plan policies make clear that an element of affordable housing, or other

developer contributions, are required on specific sites, this will be a material consideration in

determining relevant applications (para 9.3.5).


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3.3.15 Capacity of existing infrastructure, and the need for additional facilities, should be taken into

account in the consideration of planning applications and should seek to maximise the use of

existing infrastructure and consider how the provision of different types of infrastructure can be co-

ordinated (para 12.1.6).

Wales Spatial Plan (2008 Update)

3.3.16 The Wales Spatial Plan (WSP) People, Places, Futures sets a strategic framework to guide future

development and policy interventions. It integrates the spatial aspects of national strategies for

social inclusion and economic development, health, transport and environment, translating the

Assembly Government’s sustainable development objectives into practice.

3.3.17 The WSP identifies how good quality housing will assist in tackling deprivation and contribute to the

development of sustainable communities throughout Wales. The Assembly Government has

identified that ‘a lack of good quality housing affects people’s health and wellbeing and influences

their long-term life chances. The scale of population growth that needs to be accommodated is

challenging, with a projected growth of 330,000 persons across Wales between 2006 and 2031.

Equally important is the need to maintain a mix of tenure and size of housing to ensure balanced

communities’ (Paragraph 10.4).

3.3.18 The Wales Spatial Plan (WSP) sets a strategic framework to guide future development and policy

interventions and is a material consideration in the preparation of the LDP. The Spatial Plan places

Torfaen within the South East “Capital Region‟ of Wales. The Vision for the Capital Region is:

“An innovative skilled area offering a high quality of life - international yet distinctively Welsh. It will

compete internationally by increasing its global visibility through stronger links between the Valleys

and the coast and with the UK and the rest of Europe, helping to spread prosperity within the Area

and benefiting other parts of Wales”.

3.3.19 The document sets out how Wales should develop economically, socially and environmentally over

the next 20 years. The WSP identifies that the South East Wales - Capital Region will function as a

networked City Region, identifying the three sub areas of the Capital Region namely the City Coastal

Zone, Connections Corridor and Heads of the Valleys Plus Area.

3.3.20 Torfaen lies within the Connections Corridor and the Heads of the Valleys Plus Area. Cwmbran is

identified as key settlement in the WSP which must be successful in its own right and where


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appropriate function as service and employment hub for smaller settlements. The LDP Strategy

identifies the above role for Cwmbran.

TANS - Technical Advice Notes

3.3.21 The detailed technical advice within the TANs has also been used to inform the proposed

development. With respect to housing supply advice Technical Advice Note 1 - Joint Housing Land

Availability Studies is clear; where the current study shows a land supply below the 5 year

requirement, the need to increase supply should be given considerable weight when dealing with

planning applications, provided that the development would otherwise comply with national planning

policies (para 5.1).

3.3.22 TAN 5 refers to Nature Conservation and Planning. The document provides advice about how the

land use planning system should contribute to protecting and enhancing biodiversity and geological

conservation.

3.3.23 TAN 12 on Design seeks to equip all those involved in development design with advice on how

‘promoting sustainability through good design’ may be facilitated through the planning system and

the preparation and validation of design and access statements (DAS). The content of the TAN is

referred to in more detail in the DAS accompanying this application.

3.3.24 In regard to transport, TAN 18 states development in rural locations should embody sustainability

principles, balancing the need to support the rural economy, whilst maintaining and enhancing the

environment, social and cultural quality of rural areas.

3.3.25 TAN 22, Planning for Sustainable Buildings, seeks to provide technical guidance on the

implementation of the national planning policy on planning for sustainable buildings through the

planning application process.

Wychavon District Council and SoS vs. Crown House Developments Ltd - High Court

Decision 12th March 2016

3.3.26 This recent important High Court decision confirms that even where there is a conflict between a

proposal and a development plan, the presumption in favour of sustainable development remains a

material consideration. This, in turn, can provide a compelling and credible basis for planning

permission to be granted. This is particularly relevant in the case of development proposals on

unallocated sites.


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3.3.27 While the decision was taken on a development based in England where the NPPF provides the

overarching national planning policy guidance (as opposed to PPW) it remains relevant to Welsh

based decision making.

3.3.28 In this case, an Inspector allowed an appeal for outline planning permission for 32 homes on a site

not allocated in the Local Plan which fell outside a settlement boundary. He concluded that the

development constituted sustainable development having regard to the policies of the Framework

which are an important material consideration. He found that NPPF’s presumption in favour of

sustainable development and the benefits of the development, namely, significantly boosting the

supply of housing, outweighed limited harm (and local policy conflict) that had been identified. The

benefits of the scheme were sufficient, in this instance, to outweigh the local plan policy conflict.

3.3.29 Regarding sustainable development, Mr Justice Coulson said: "It is quite wrong to say that a

presumption in favour of sustainable development does not exist in the NPPF outside paragraph

14....It is the ‘golden thread’ running through the NPPF. The inspector properly had regard to it as

an important material consideration.”

3.3.30 Mr Justice Coulson added said: “Where there is a conflict between a proposal and a development

plan, the policies within the NPPF, including the oft-repeated presumption in favour of sustainable

development, are important material considerations to be weighed against the statuary priority of

the development plan. In my view, it is as simple as that.” The High Court dismissed the application

to quash the appeal and found that the inspector had applied the right test.

3.3.31 This is an important decision for developments proposals on unallocated sites. Many proposals

hinge on whether there is an up-to-date Local Plan and a demonstrable five-year housing supply.

This decision finds that the presumption in favour of sustainable development is not simply activated

only on the basis of the development plan being silent, or absent, or if the relevant policies are out-

of-date. When taken as a whole, the policies of the PPW, including the presumption in favour of

sustainable development, are important material considerations to be weighed against the statuary

priority of the development plan.


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3.4 Supplementary Planning Guidance

Planning Obligations SPG, June 2011

3.4.1 This SPG is intended to improve clarity and transparency for all involved in the development process

and to explain the approach that Torfaen Council will take in respect of the negotiation, drafting,

implementation and subsequent monitoring of planning obligations.

3.4.2 Part one of the guidance sets out the context and general information regarding planning

obligations. Part Two comprises topic specific annexes, referring to those obligations which tend to

occur most frequently i.e. affordable housing, highways, education, community facilities, ecology /

biodiversity, public open space and recreation facilities.

3.4.3 The guidance is to be applied taking into account other relevant material considerations. The SPG is

not intended to replace the negotiation of planning obligations as it is noted each application should

continue to be considered on its individual merits.

Affordable Housing Delivery Statement (AHDS)

3.4.4 The AHDS was intended as an interim measure, as the Council progressed to the adoption of the

Torfaen Local Development Plan (LDP). It is primarily concerned with setting and achieving an

affordable housing target. It provides guidance on how the affordable housing policies of LDP are

applied, in such areas as site thresholds, percentage requirements, tenure, mix, design, etc.

3.5 Summary

3.5.1 There is a presumption in favour of sustainable development. Based on the most up to date

information available Torfaen Council currently has a below 5 years housing land supply (4.8 years).

3.5.2 The site lies within the defined urban settlement boundary and constitutes previously developed

land. The site lies within an established residential location on an existing bus route. It is

considered to be highly accessible. The site is unallocated in the adopted LDP and is largely

unfettered from environmental constraints.

3.5.3 The application site is surplus to requirements as part of a strategic rationalisation of education

provision in Torfaen Borough. The proposed development is considered to accord with the

prevailing policy context at both national and local level as detailed above with respect to bringing


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back into beneficial use previously developed land and delivering much needed housing at a

sustainable location.

3.5.4 A high quality designed development is proposed which will not cause any undue impact on its wider

surroundings; rather, it will deliver a development which responds to its local context. This,

together with the other relevant planning policy considerations (as outlined above), is considered in

more detail in the following sections.


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4.0 Planning Considerations

4.1 Introduction

4.1.1 Section 38 (6) of the 2004 Planning and Compulsory Purchase Order Act states that planning

applications are to be determined in accordance with the Development Plan unless material

considerations indicate otherwise.

4.1.2 This section considers the principal planning and development matters arising from the proposed

development, drawing on the adopted Development Plan, wider prevailing policy context, pre-

application discussions and other material considerations.

4.2 Previously Developed Land

4.2.1 It is recognised that the entire site would fall within the definition of ‘previously developed land’

(PDL) as set out in PPW. Paragraph 4.9.1 of PPW states that not all previously developed land is

suitable for development however the site has no overriding impediment which would preclude its

redevelopment. Indeed, the site lies vacant and, following the planned demolition of existing

buildings2, will be primed for redevelopment. Bringing previously developed land back into active

use is a key tenet of PPW. Accordingly, the status of the site as PDL is strong material

considerations in favour of permission being granted for the proposed redevelopment.

4.3 Principle of residential redevelopment

4.3.1 With respect to the principle of residential development, the most pertinent development plan

policies are considered to be policies S1, S2, CF3 and S5.

4.3.2 Policy S1 identifies the authority’s urban boundaries which, effectively, define the urban area, within

which there is a presumption in favour of development. The application site is located within the

urban boundary. A presumption in favour of the site’s redevelopment therefore applies. The site

itself is unallocated or ‘white land’ in the adopted LDP. As such there is no land use policy

designation which may otherwise preclude a residential reuse. The Council recognises that to

deliver the objectives of the 21st Century schools land release will be required. The principle of

2 Pursued under a separate prior notification application


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releasing undesignated land for housing development is considered to accord fully with the 21st

Century schools objectives.

4.3.3 Policy S2 relates to the creation of sustainable communities. The development will provide new

homes at an accessible location in close proximity to existing housing, employment, community and

commercial services which are all within walking distance. The proposed development is located

adjacent to transport corridors and thus will minimise the need to travel.

4.3.4 Redeveloping the former school site will both conserve and enhance the built environment by

bringing a vacant, previously developed site back into beneficial use. Indeed, the redevelopment

constitutes an efficient use of land that maximises the use of existing infrastructure. The

redevelopment of the application site will deliver much needed housing to the local housing stock

which in turn contributes to a regeneration of the existing community at Llantarnam. The site’s

accessibility and the reuse of existing access/egress etc means the proposals do not conflict with

wider transportation and infrastructure priorities, including reducing the reliance on the private car.

The site lies on an existing bus route and its redevelopment for housing will encourage the use of

more sustainable modes of transport (this is considered further below). The immediately

surrounding area is, typically, suburban. It is an established residential location, already home to a

substantial population, well served by existing infrastructure and utilities. The proposed

development is considered to represent sustainable development having regard to the three pillars

of sustainability; the social, economic and environment, and accord with policy S2 in all respects.

4.3.5 With respect to policy CF5, the proposed development does not result in the loss of a community

facility. The former school/leisure centre (pool) use has, effectively, been relocated off-site i.e. the

previous uses ceased on site in 2015 and the site now lies vacant – ready for disposal and

redevelopment. Torfaen Council, as Local Education Authority (LEA) (i.e. the ‘responsible body’) has

sanctioned the sale of the application site as part of its wider strategic decision to deliver improved

educational provision elsewhere in the Borough. Therefore, with reference to the tests of policy

CF3, WYG understand: comparable replacement facilities have been provided (i.e. off-site); the

former Llantarnam school facility is no longer required and lastly, this ‘reorganisation plan’ has been

LEA sanctioned.

4.3.6 In respect of the potential loss of community facilities, we recall officers’ position in considering the

primary school proposal approved under pp ref: 15/00098 (as set out in Section 2.0 above). It was

reasoned that the loss of playground/court is mitigated by the relocation of pupils to Cwmbran High


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School. Furthermore, an assessment of recreational provision at this time confirmed the proposed

playing field provision exceeded minimum requirements and an assessment of community use and

recorded demand of hard surface courts satisfied Fields in Trust (FiT) who did not object to the

proposals.

4.3.7 Mindful of the above, the proposed development is considered to accord with policies S1, S2, CF3

and S5 in all respects. Further consideration is provided below.

4.4 Housing Provision

4.4.1 The proposed site layout accompanying the application details the development of no.228 dwellings

on site. The proposed dwellings are of mixed type and tenure and a policy compliant proportion

(68) are proposed to be ‘affordable’ units (i.e. 30%). The proposed type and tenure of the housing

is set out in the table below:

Table 1.0 Proposed House Type Schedule

Unit type No. of Units

Open Market

2 bed house 42

3 bed house 56

4 bed house 62

Sub Total 160

Affordable

1 bed apt 6

2 bed apt 6

1 bed house 8

2 bed house 26

3 bed house 19

4 bed house 3

Sub Total 68

Total 228


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4.4.2 As highlighted in section 3.0 above the most recent Joint Housing Land Availability Study (July 2015)

indicates that Torfaen Borough has a 4.8 year housing land supply. The Council, therefore, does

not currently meet the minimum 5 year supply requirement as set by the Welsh Government.

4.4.3 TAN1 advice is clear; where the current study shows a land supply below the 5 year requirement,

the need to increase supply should be given considerable weight when dealing with planning

applications, provided that the development otherwise complies with national planning policies (para

5.1). As considered in the preceding sections in such instances the recent High Court decision is an

important material consideration for proposals on unallocated sites. As established by this decision a

presumption in favour of sustainable development is not simply activated only on the basis of the

development plan being silent, or absent, or if the relevant policies are out-of-date. The policies of

the PPW, including the presumption in favour of sustainable development, must be weighed against

the statuary priority of the development plan.

4.4.4 The proposed development’s contribution to the Torfaen local housing stock should be given

significant weight when determining the application. The need to increase supply should be

recognised by expediting the site’s development for residential purposes. This is considered

particularly true given the absence of a “downside” to such a course of action – and the need to

deliver the wider strategic objectives of the 21st Century Schools programme. Indeed, the LDP

recognises that implementation of the schools programme “may require significant land release” i.e.

the programme is intended to be partly funded by the capital receipt of the disposal of Council

owned assets such as the application site.

4.4.5 Policy S5 makes provision for the development of 4,700 dwellings in Torfaen (by identifying sites for

approximately 5,740 dwellings) during the plan period. These figures allow for 289 dwellings to be

delivered on ‘windfall’ sites’ (10 or more dwellings). For the purposes of considering policy S5 the

site is unallocated and can be defined as a windfall site. In this respect the site represents an

immediately deliverable site that will deliver 228 mixed tenure units i.e. c.78% of the LPA’s windfall

target. The development is considered to fully accord with policy S5.

4.4.6 Policy H4 states the Council will seek the on-site provision of up to 30% affordable housing in the

Cwmbran East & South Sub Market Area. The submitted scheme proposes the delivery of 30%

affordable provision on site (i.e. 68 units) in accordance with policy H4.

4.4.7 The affordable housing element will be ‘tenure blind’ and ‘pepper-potted’ throughout the site. It is

anticipated the affordable units will be transferred to an RSL upon completion. The applicant is


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willing to secure delivery of the affordable units by entering into a suitably worded S106 legal

agreement.

4.4.8 Accordingly, we consider the housing land supply deficit and full policy compliance with delivering

on-site affordable housing provide significant material considerations which weigh firmly in favour of

the development proposals.

4.4.9 In addition, the proposals will generate social and economic benefits by delivering the proposed unit

mix, types and tenures whilst also generating construction jobs.

4.4.10 It has been demonstrated that the principle of the development accords with adopted development

plan and national planning guidance relating to the creation of sustainable communities. The

development is expected to make a significant contribution towards meeting strategic housing

requirements. Accordingly in accordance with polices S2, S4 and H5 the proposed housing

development is considered acceptable.

4.5 Design, Access and Layout

4.5.1 The planning application is accompanied by a Design and Access Statement which considers the

proposals in the context of prevailing national design guidance as set out in PPW and TAN 1 and

adopted local planning policy; namely policies BW1, S3 and S4 of the LDP.

4.5.2 Under Policy S4 proposals must have full regard to the context of the local natural and built

environment and its special features through promoting local distinctiveness; delivering a mix of

uses; and ensuring location and layout integrates effectively with local accessibility. Policy BW1

provides the following policy criteria on amenity and design against which the proposals have been

considered:

i) it does not constitute over development of the site in terms of the scale, density, massing and

form of the development;

4.5.3 A development is proposed at a density of c.33 dwellings per hectare (dph) which, allowing for on-

site constraints, is considered to represent an appropriate density for this area and constitute an

efficient reuse of brownfield land which accords with sustainability objectives. The proposed units

are predominantly two storeys in height, rising to 3 storeys where practicable. The scale, density

and massing of the development is considered to suitably reflect the surrounding urban fabric. The


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proposed mixed tenures will support and encourage a balanced residential community in accordance

with policy objectives on sustainable design. Additionally inherent in the layout is a design which

seeks to mitigate the causes of climate change through energy efficiency in accordance with policy

S3. Construction techniques are considered further in the accompanying Design and Access

Statement.

ii) The design and visual appearance of the proposal takes account of the local context;

4.5.4 The aim of the development is to create a well-designed, sustainable development which ensures a

harmonious relationship with adjacent land uses and complements the character of the area. In this

way the layout aims to deliver a pleasant living environment for future occupants.

4.5.5 The development is sympathetic to its predominantly residential surroundings and responds to the

area’s context by providing a range of house types in a similar manner to that already found in the

area e.g. 1/2 bed apartments and 2 to 4 bed semi and detached houses with pitched roof and brick/

render elevations.

4.5.6 The layout aims to introduce a range of quality architecture. The palette of materials is restrained

and complementary to those used in the locality, particularly drawing on the design quality

demonstrated in the village area to the south of Llantarnam.

iii) the proposal respects the urban fabric of the area in terms of pattern of development and the

setting of the site etc;

4.5.7 The development proposals have been guided by, and meet, the criteria set out in Building for Life

12 and the applicant’s own ‘Great Places’ initiative, which are intended to create attractive,

functional and sustainable places. Building for Life 12 is led by three partners: Cabe at the Design

Council, Design for Homes and the House Builders Federation. As detailed in the Design and Access

Statement it is structured around three themes – integrating into the neighbourhood, creating a

place, and street and home. Each theme has four questions that have been used as a point of

reference in the preparation of the development proposals.

4.5.8 Great Places is Barratt’s guide designed to dovetail exactly with Building for Life 12. It provides

guidance on how to create designs that will achieve Built for Life accreditation and is a means of

assessing finished schemes.


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4.5.9 Further detail on how the development proposals meet Building for Life 12 and Great Places is set

out in the accompanying Design and Access Statement.

iv) includes a landscaping and planting scheme, which enhances the site and the wider context;

4.5.10 A landscaping scheme has been formulated which, details the landscaping strategy to help

assimilate the development into the site and mitigation for the proposed loss of playing fields.

4.5.11 Accessible open space is conveniently located tin two pockets while existing landscape features,

principally though not exclusively at the boundaries of the site are maintained.

vi) The proposal does not have an unacceptable adverse impact upon the water environment or

pose an unacceptable risk to the quality and quantity of controlled waters (including groundwater

and surface water), and where practicable and reasonable improves water quality.

4.5.12 The drainage strategy is provided in plan for as part of the application package and links into

existing foul and surface water systems. Tests undertaken demonstrate the site is not appropriate

for soakaways and the development, therefore, will have no impact on controlled waters.

Furthermore, the site is not within a flood zone. No unacceptable impact on the water environment

is anticipated.

v) does not have an unacceptable impact upon the amenities of the occupiers of adjoining or

neighbouring properties;

4.5.13 Key urban design principles have underpinned the design which aims to create a simple and legible

layout of streets and spaces that connect well with adjacent areas and neighbouring properties. In

response to the proximity of neighbouring residential dwellings, minimum distances have been

safeguarded e.g. on those with overlooking windows to the south at John Fielding Gardens.

4.5.14 Maintaining the woodland ‘buffer’ of vegetation along the access route to the school and between

the business park will ensure privacy and high levels of amenity are maintained for both existing

residents e.g. at Court Farm Road and future residents at the application site. The careful

consideration of how the proposed units relate to both existing neighbouring properties and each

other ensures the amenity of all occupiers will be safeguarded.


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vi) design out the opportunity for crime and anti social behaviour.

4.5.15 The proposed layout for the site has been carefully designed to deter criminal activity and anti-social

behaviour by minimising opportunities to commit crime or to impact negatively on the quality of life

of future residents. The layout has been formulated to ensure there will often be high levels of

footfall both in and around the site ensuring high levels of natural surveillance in the day and

evening.

4.5.16 The movement framework will provide a network of convenient and direct routes that will be well

used and be well connected to adjacent areas. Access to the rear of dwellings from public spaces

has generally been avoided and parking is in-curtilage or on-street in full view of the dwellings.

4.5.17 The layout provides a legible public realm, which integrates the site effectively with the adjoining

(future) primary school site and balances the needs of pedestrians, cyclists and drivers.

4.5.18 In light of the above key considerations the proposed redevelopment is considered to accord fully

with policies BW1, S3 and S4 of the LDP. Further details are provided in the accompanying Design

and Access Statement.

4.6 Open Space and Landscaping

4.6.1 Policy CF5 is the principal policy providing guidance in respect of development on areas of formal

and informal recreation space etc. Development should not, inter alia: cause/ exacerbate a

deficiency of such space and the space lost should not have significant amenity value. Development

should outweigh the need to protect the space; or the developer must make satisfactory

compensatory provision of equal community benefit, value and quality.

4.6.2 In accordance with the provisions of policy CF5 a comprehensive open space and landscaping

scheme has been formulated which, inter alia, details mitigation for the proposed loss of existing

school playing fields. The development provides sufficient on site open space to serve both future

residents and the wider community. The proposed provision has been formulated following pre-

application discussions with officers and, in terms of quantum, cognisant of requirements as set out

in Torfaen Council’s Planning Obligation SPG.

4.6.3 It is pertinent to note that the majority of existing open space at the site is not considered to hold

‘significant’ amenity value. The site provided, until recently, mostly functional open space associated


29

with the site’s previous school use. However this space has now effectively been lost to the public

following the school’s closure. In this respect it is considered the need for the development

outweighs the need to retain the space, especially given the development itself provides what is

considered to be satisfactory, policy compliant compensatory provision which is greater community

benefit (i.e. equipped and fully accessible).

4.6.4 With regard to the loss of playing fields it is pertinent to note the newly opened Cwmbran High

School is equipped with its own dedicated playing fields and in terms of the recently permitted

community primary school adjacent to the site to the west we note Fields in Trust’s comments that

“In terms of the new primary school, it is noted its playing field provision will exceed the minimum

set out in the Schools Premises Regulations so Sport Wales has no concerns in the that regard” with

subsequent comments confirming no need to retain the on-site courts.

4.6.5 Notwithstanding this, a combined Local Area of Play (LAP)/Locally Equipped Area of Play (LEAP) is

proposed at the west of the site totalling c.1,800sqm in accordance with pre-application discussions

and SPG requirements. In addition, a second smaller area of public open spaces measuring

c.280sqm is situated in the northern part of the application site to ensure dwellings in the northern

section are afforded communal amenity space.

4.6.6 In this manner the development will not cause a deficiency of open space provision and satisfactory

compensatory provision has been provided. Furthermore, in this instance it is our view the need for

the development outweighs the need to protect the space. The development therefore is

considered to fully accord with the provisions of policy CF3.

Trees

4.6.7 A tree report, prepared by Treescene Arboricultural Consultants, documents a tree survey carried

out at the application site and accompanies the application. The survey entailed a visual inspection

from ground level of all trees. Each tree was numbered and, where appropriate tagged for future

identification on site.

4.6.8 The survey provides an estimation of height dimensions, trunk/stem diameters, branch spread and

an assessment of a tree’s age classification in terms of it maturity within the site’s landscape. An

assessment of a tree’s physiological condition is also made.


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4.6.9 We consider there is no impediment with respect to trees which may otherwise prevent

development of the site, provided recommended mitigation is implemented and that all proposed

works are carried out in accordance with BS5837. This can secured via a suitably worded condition

attached to any permission.

4.7 Transport and Accessibility

4.7.1 A Transport Assessment (TA) (WYG, April 2016) has been carried out, formulated in consultation

with Torfaen Council as highway authority, and accompanies the planning application.

4.7.2 The TA finds there are existing public transport services accessible via bus stops on Llantarnam

Road adjacent to the site, providing direct services to Newport, Cardiff and Pontypool. A number of

local facilities and services are within walking distance. As a result there is considered to be

considerable potential for trips to and from the site to be undertaken by non-car modes of travel

rather than the private car. Indeed, the site’s sustainability credentials means the development is

liable to a parking reduction under adopted standards (set out below).

4.7.3 In respect of Policy BW 1 the proposed access has been designed in accordance with the relevant

national and local highway design guidance. One of the key objectives of the site development is

the need to maintain vehicular access to the primary school land to the west. The existing vehicular

egress point established on Llantarnam Road will be retained and upgraded to ensure the route is

suitable to accommodate both access/egress requirements of the future students of the primary

school and local residents at the application site e.g. the route has been designed to accommodate

school buses and private vehicles visiting the school. Simply put, the proposed arrangements are

designed so as to ensure the delivering of the proposed development at the subject site does not

prejudice the delivery and operation of the permitted primary school (i.e. the access acceptably

serves both ‘sites’). Indeed, the principle of the access proposals were already established by virtue

of the primary school consent in which highways officers found that “...based on the findings of the

Transport Assessment, it is considered that there are no valid highway or transportation reasons

that should lead me to oppose the application”3. With respect to the former school site’s existing

vehicular access (to south) on Llantarnam Road this is no longer required and will be stopped up.

4.7.4 The submitted TA employs the Council’s own traffic modelling data in its methodology. It assesses

the likely traffic generation associated with the development of no.228 units at the site, its 3 Planning Committee report dated 28 April 2015


31

consequent impact on the existing highway network, parking provision and on-site servicing

arrangements etc. The TA forecasts that the trips generated in the AM and PM peak hours

compare favourably with the traffic previously generated by Llantarnam Comprehensive School.

There is assessed to be a net reduction in traffic on the roads in the vicinity of the site based on the

trips forecast to be generated by the proposed residential development.

4.7.5 Junction assessments have been undertaken for the site access and the Llantarnam Road / Newport

Road signalised junction which indicate that the existing junctions can comfortably accommodate

the forecast traffic generated by the proposed development. In the context of Policy BW 1 the road

network is found to be capable of sustaining the traffic generated by the proposed development.

4.7.6 In promoting the interests of pedestrian and cyclists, the existing Public Right of Way (PRoW) route

419/26/1 will be re-orientated by means of a separate diversion application to ensure the route

follows the newly proposed public footpath through the site from Llantarnam Road leading to the

public open space. No significant diversion of the route is required; rather, a ‘fine-tuning’ to ensure

the definitive route dovetails with the proposed paths/pavements (particularly in the vicinity of plots

42/43 and 163).

4.7.7 A second, separate route between Llantarnam Road and John Fielding Gardens (ref: 419/29/1) has

been reviewed. It is proposed to re-orientate the historic delineation around the proposed

development. This provides a logical progression from John Fielding Gardens with multiple points of

entry into the development. The retention of connections onto Llantarnam Road and John Fielding

Gardens ensures safe access to the range of local facilities located within easy walking distance of

the site.

4.7.8 A parking schedule is set out with the submitted TA which demonstrates that the proposed

development accords with the Council’s adopted parking standards (Planning Obligations: Annex 2

Highways and Transport). As requested by the Council, the majority of residential parking is

provided off-road (within the curtilage of individual properties or within small parking courts) albeit

visitor parking is provided in designated bays in front of the dwellings. Off road spaces are mainly

provided to the rear or side of dwellings. Where properties have garages, these tend to be set back

from the main front building line to ensure they do not dominate the streetscene, are subservient to

the principal dwellings and to allow for driveway parking in front.

4.7.9 The proposed development is considered to accord with Policy BW1 with respect to the provision of

appropriate parking.


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4.7.10 The principal objectives of the submitted Travel Plan are to minimise the number of single

occupancy car journeys made to the site, promote travel by the more sustainable modes of

transport, and manage the overall transport impact of the development in accordance with policy

BW 1. A Travel Plan Co-ordinator (TPC) is intended to be appointed to oversee the implementation

and delivery of the Travel Plan, and to act as a central point for residents of the site.

4.7.11 The proposed development is considered to fully accord with Policy BW 1with respect to transport.

Further details can be found in the accompanying Transport Assessment and Travel Plan.

4.8 Ground conditions

4.8.1 A geotechnical and geo-environmental investigation has been carried out at the site, as detailed in

the report prepared by TUV, which accompanies the application. As set out in the report a review of

historical maps indicates the site area remained undeveloped until the development of the school in

the early 60s. The site has remained largely unaltered since this period.

4.8.2 Ground conditions largely comprise grass onto topsoil, underlain by firm/ firm to stiff gravelly clay to

depths of 1.4m below ground level. This generally overlies medium dense/ dense clayey silty gravel

and sandstone to depths of at least 2.6m below ground level.

4.8.3 Briefly, the investigation finds the site may be developed using standard in-situ suspended slab

foundations. The report also finds no remediation is deemed necessary in the areas investigated

based on the results of contamination testing.

4.8.4 With respect to the built environment Policy BW1 states that, where practicable, existing

construction materials on the site should be re-used or recycled. The geotechnical assessment fins

that where demolition material is used to raise ground levels (subject to re profiled levels for

drainage etc) it may be more cost effective to use raft foundations. This is subject to further

investigation.

4.8.5 A geotechnical assessment has been carried out to ensure the proposal does not result in

unacceptable adverse effects in respect of land contamination, instability and/or subsidence, in

accordance with Policy BW 1. Should further information be required this can be secured by way of

an appropriately worded planning condition attached to any permission granted.

4.8.6 Further details are provided in the Geotechnical and Geo-environmental report.


33

4.9 Noise

4.9.1 A noise report, prepared by Hunter Acoustics Ltd, accompanies the application. It documents a

noise assessment carried out on environmental road traffic noise levels on the residential proposals

and compares them against current planning guidance. Three continuous monitoring positions were

established on site to monitor road traffic levels: at the north, east and south-west of the site. The

noise monitoring allowed a ‘noise map’ to be generated from which levels could be analysed and the

need/appropriateness of mitigation assessed.

4.9.2 Road traffic noise levels modelled across the site are assessed to fall under NECs (Noise Exposure

Categories) A and B of TAN 11 by day and night, with the exception of the boundary of Llantarnam

Road. The assessment finds standard thermal double glazing and trickle ventilation is typically

sufficient to control road traffic noise intrusion NEC A and B sites for the development. It is

recommended plots overlooking Llantarnam Road are subject to additional sound insulation

measures to habitable rooms (including acoustic ventilation). Such measures can be secured by way

of an appropriately worded planning condition.

4.9.3 With respect to Policy BW 1 appropriate mitigation will ensure the proposal does not result in

unacceptable adverse effects in respect of noise. Further details can be found in the accompanying

Noise assessment.

4.10 Ecology

4.10.1 Policy BW1 stipulates that, inter alia, development proposals contribute to the conservation and/or

enhancement of the strategic biodiversity network of Torfaen and not result in a significant adverse

effect on the network. Furthermore, proposals should not result in the unacceptable loss or harm to

features of landscape importance including trees and woodland that have natural heritage or

amenity value.

4.10.2 The site has been subject to a number of ecological studies in recent years. In December 2013 a

phase 1 survey was carried out at the playing fields at the south-east of the site. The survey

consisted of a walk-over survey taking into account habitat features within and adjacent to the site.

The site area surveyed predominantly encompassed the managed sports fields, which were found to

comprise almost totally short-mown species poor grassland, dominated by rye grass.


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4.10.3 The survey include the over mature hedge line which forms the boundary of the south of the site

and is designated as a SINC on the adopted LDP Constraints Plan. The ground fauna at the hedge

line was found to be largely shaded out and affected by tipping from adjacent properties. In respect

of other on site habitats, the site displays two mature trees to the north of the playing fields.

However site boundaries (to the north-east and south-east) consist solely of garden fences.

4.10.4 The survey found limited opportunities for fauna and a site of low biodiversity value, albeit there

was some evidence of moles on part of the playing field and the mature trees in the hedgerow and

to the north of the playing field may provide potential opportunities for breeding birds. The trees in

the hedgerow were found to potentially provide habitat for roosting and foraging and commuting

bats.

4.10.5 In respect of habitat loss the survey found that loss of the amenity grassland at the site would be of

no ecological significance (in a local or regional context) given that the habitat is of no significant

value.

4.10.6 The south western hedge line boundary (SINC) was found to offer the only opportunity for protected

species on site. As such it was recommended the hedge line be retained in the new development

and that any clearance of trees and shrubs be carried out outside the breeding bird season (March

to August). Other habitats (e.g. two mature trees to the north of the playing fields) were assessed

to be of no significance in the local context.

4.10.7 Further details can be found in the Phase 1 Habitat Survey prepared by Hawkeswood Ecology.

4.10.8 A bat and nesting bird survey was subsequently carried out at the site in August 2014 on both the

school buildings and sixth form block. The daytime inspection found no evidence for the presence

of bats, but with the buildings displaying moderate potential for bats, four dusk observations were

carried out in September 2014 (optimal time). No bats were recorded. The school and sixth form

block are not considered to be bat roost locations. The leisure centre was not considered to offer

any bat/bird potential.

4.10.9 In respect of birds, no bird activity was observed during the surveys, however there were indications

locations are used by breeding birds. As such, it is recommended that should any demolition occur

during the bird nesting season (March to mid-August), buildings are checked immediately in advance

of this. Further details can be found in the bat and bird survey prepared by Just Mammals

Consultancy which accompanies this application.


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4.10.10 Most recently an extended Phase 1 Habitat survey was carried out in February 2015 to accompany

the adjacent Primary School application, incorporating an assessment of buildings and trees for

protected species. The survey finds that the site comprises a limited range of habitat (consistent

with the former school use). The existing buildings and amenity grassland was of little to no

ecological value. Himlayan balsam, an invasive plant species, was found to be present on the school

grounds (albeit not within the current application site).

4.10.11 With reference to the recommended mitigation set out in the above surveys, landscaping plans have

taken account of the potential to link the two mature trees at the north of the playing field with the

hedge line SINC at the south west boundary and this is duly proposed in the Landscape Strategy.

The use of native species is also proposed along with bird/bat boxes in order to provide localised

enhancement for these groups. Artificial lighting will be carefully controlled to maintain existing

boundary features as ‘dark corridors’ as far as practicable

4.10.12 Safe working practises will ensure local drains are not subject to pollution from surface water run-off

as well as minimising the potential for any dust contamination. Any demolition should avoid the bird

breeding season for tree/hedgerow removal, unless a assessment is carried out immediately in

advance.

4.10.13 The above mitigation will ensure the proposal complies fully with policy BW 1 with respect to

safeguarding the natural environment and local biodiversity interest.


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5.0 Summary and Conclusions

5.1.1 This Planning Statement sets out the context for the proposals and aims to fully assess the principal

considerations. We provide the following summary of conclusions:

The application site is located at the former Llantarnam Comprehensive school site, situated

within a well established residential location. The former school site is surplus to educational

requirements and now lies vacant.

The application site constitutes previously developed land located within the urban boundary.

It is well serviced by existing infrastructure/ facilities. The site lies along Llantarnam Road

which is an existing bus route. The site is considered to represent an accessible and

sustainable location and in this respect accords with policies S1 and S2. Its redevelopment is

considered to be acceptable in principle.

The site represents an unallocated site. The proposed ‘windfall’ redevelopment will deliver 228

units towards meeting Torfaen Borough’s challenging housing target in accordance with policy

S5;

The proposals do not result in the loss of a community facility; the previous use having been

relocated in 2015. The Council, as LEA, has sanctioned the redevelopment of the site as part of

its wider strategic educational programme. The redevelopment is considered to meet the tests

of policy CF5.

The scale, massing, design and landscaping of the proposed redevelopment constitute an

appropriate and sensitive redevelopment which will enhance the landscape setting in

accordance with Policy BW 1. There is no impediment with respect to trees which may

otherwise prevent development of the site, provided appropriate mitigation is implemented;

The development will not cause a deficiency of open space provision - satisfactory

compensatory provision has been provided. The development is considered to fully accord with

the provisions of policy CF3.

Appropriate mitigation will ensure the proposal does not result in unacceptable adverse effects

in respect of noise in accordance with policy BW1.

Ecological surveys confirm that the site is of low ecological value. With the implementation of

appropriate mitigation there will be no undue impact on the local biodiversity interest e.g. as a

result of the proposed development;

5.1.2 As confirmed in pre-application discussions and set out in the reasons and justification provided in

this Statement, we consider the proposed development accords with prevailing national and adopted


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local development plan policy which weighs firmly in favour of permitting the proposals, with

appropriate conditions.


Appendix A – Site Location Plan


Appendix B – Site Layout Plan

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