Client: Melin Homes

Agent: Asbri Planning Ltd.

Asbri Planning Ltd. Reference: 12.209

Description of Development: Demolition of existing school and nursery buildings anddevelopment of 53no. units and associated works

Location of Development: Former Hillside School and Nursery, Upper Hill Street,Blaenavon

Name Signature Date Revision

Prepared by:

Lowri Hughson-Smith

Planner

September

2013-

Approved By:Robin Williams

Managing Director

September

2013-

CONTENTS

1. INTRODUCTION

2. SITE LOCATION AND DESCRITPION

3. PROPOSED DEVELOPMENT

4. PLANNING HISTORY AND PRE-APPLICATION DISCUSSIONS

5. PLANNING POLICY FRAMEWORK

6. APPRAISALS

7. CONCLUSION

APPENDICES

APPENDIX 1 - PLAN INDICATING THE EXTENT OF THE BLAENAVON INDUTRIAL LANDSCAPE WORLD

HERITAGE SITE

APPENDIX 2 – PLAN INDICATING EXTEND OF THE SINC

APPENDIX 3 – PROPOSED SITE LAYOUT (DRWG. NO: AS00 REV. B)

APPENDIX 4 – LOCAL DEVELOPMENT PLAN NORTHERN PROPOSALS MAP

1.0 INTRODUCTION

1.1 This planning statement has been completed on behalf of Melin Homes to accompany a full

planning application for the demolition of existing school and nursery buildings and

development of 53no. units and associated works at former Hillside School and Nursery, Upper

Hill Street, Blaenavon.

1.2 In addition to this planning statement, the application also comprises the following documents

and plans:

Prepared by Rio Architects:

Design and Access Statement

Prepared by Peter Sturgess Ecology:

Phase 1 Habitat Survey

Reptile Survey

Prepared by Hawkeswood Ecology:

Bat Survey Observations Report

Prepared by Treescene:

Tree Report

Prepared by Nicholson Jones:

Drainage Strategy

Prepared by Asbri Transport:

Transport Statement

Prepared by Archaeology Wales:

ASIDOHL Report

Prepared by Davies Surveys Ltd.

Topographic Survey, drawing number: 2346-1

Topographic Survey, drawing number: 2346-2

1.3 The purpose of this planning statement is to provide additional and complementary information

to that contained within the accompanying planning application. This statement in Section 2

describes the site features and context, Section 3 provides details of the scheme and supporting

documentation, Section 4 outlines the planning history and pre-application advice, Section 5

reviews the relevant national and local planning policy and Section 6 provides an appraisal of

the development and draws together the key points and Section 7 will conclude the statement.

2.0 SITE LOCATION AND DESCRIPTION

General Location

2.1 The site is located in the north of the administrative authority of Torfaen County Borough

Council. The application site is located in within the defined settlement of Blaenavon north of

the town centre and immediately adjacent to the Blaenavon conservation area. Blaenavon is

located approximately 9.5km from Pontypool town centre, approximately 7.5km from Bryn

Mawr and approximately 10.5km from the centre of Abergavenny.

Register of Landscapes of Outstanding Historic Interest and World Heritage Site Status

2.2 In 1998 Blaenavon was included on the Register of Landscapes of Outstanding Historic Interest

published by Cadw, CCW and ICOMOS.

2.3 Blaenavon is a World Heritage Site (WHS) designated by UNESCO in 2000 because it was

considered to meet the following criteria of the Operational Guidelines for the Implementation

of the World Heritage Convention:

Criterion (iii): The Blaenavon landscape constitutes an exceptional illustration in

material form of the social and economic structure of 19th century industry.

Criterion (iv): The components of the Blaenavon industrial landscape together make

up an outstanding and remarkably complete example of a 19th century industrial

landscape.

2.4 Blaenavon achieving such status was mainly attributable to it being one of the world’s largest

coal and iron producers. It still has all necessary elements of these industries in situ including

the coal and ore mine, quarries, a primitive railway, furnaces, the homes of the workers and the

social infrastructure of the community i.e. Workmen’s Hall. The boundary of the designated

WHS is included in Appendix 1. The application site is located within area 002 Blaenavon Urban

Extension of the World Heritage Site.

Blaenavon Conservation Area

2.5 The application site is not within the Blaenavon Conservation Area but immediately adjacent to

the north eastern edge.

2.6 The conservation area is designated for its historic character associated with the past industrial

related development and man-made landscapes. Blaenavon is unusual in the Valleys as being a

self-contained and definable settlement not linked by urban valley sprawl and for having key

commercial streets running up the hill slope and not parallel to the valley bottom.

Surroundings

2.7 The site is in the north eastern area of the defined Blaenavon settlement enclosed by Upper Hill

Street to the south east, the Old Queen Street to the south west which leads into King Street to

the west. The northern boundary is demarcated by a footpath that leads from Upper Hill Street

and converges with the southern boundary to the west of the site which is terminated by steps

leading towards Blaenavon town centre.

2.8 The surroundings are primarily residential in character with the majority of boundaries adjacent

to existing residential development, as mentioned above. Beyond the immediate area are the

residential streets of Ellick Street to the north west, New Queen Street, Rhydynos Street, Duke

Street and Lower Hill Street to the south and Lower Woodland Street, Woodland Street and Ty

Fry Close to the north. The residential character is primarily terraced dwellings typical of a

welsh valley coal mining town although there has been more modern development that does

not follow the historic urban grain for example Ty Fry Close which is large, staggered terraced

dwelling not typical of the traditional style. Recent development towards the fringes of

Blaenavon is unsympathetic and significantly dilutes the historic character of the town.

Site Description

2.9 The application site 1.77 hectares and was formerly Hillside School and Nursery which was

completely vacated in April 2012 and since marketed by Torfaen County Borough Council

Estates Department for residential development subject to planning permission. The site

comprises a range of buildings associated with the former education use, a playground and a

Multi-Use Games Area (MUGA) and can be described as three distinct areas; the school

complex, the nursery building and the playground. All three areas are surrounded with be green

areas which are designated as a Site of Importance for Nature Conservation (SINC). A plan

indicating the extent of the SINC is included in appendix 2.

2.10 As typical for Blaenavon, the application site has a sloping topography from north to south from

approximately 361 AOD to 349 AOD with the steepest land located along the southern and

western boundaries. The lowest point (342 AOD) of the site is located on the western boundary

where steps are located that lead onto Old Queen Street.

2.11 The school complex is accommodated on a hard standing located in the south eastern corner of

the application site. The hard standing is on two plateaus to take account of the topography.

All of the buildings are located on the lowest plateau and a small playground is located on the

higher plateau.

2.12 The school buildings are typical of a late 19th/early 20th century school and a simple arts and

crafts style with similar examples throughout the borough. The school complex has two

separate buildings; the large main school building with extensions to the rear located centrally

on the hard standing and a more modest building located adjacent to the southern boundary.

Both buildings are set back from Upper Hill Street by a small grassed area and enclosed by a

dwarf wall and railings along Upper Hill Street.

2.13 The main school building is single storey with a high roof and extensive glazing on the front

elevation. The front elevation is interesting with two projecting gables either end followed by a

turret style front projection adjacent to each gable and two smaller gables with decorative stone

detailing. The front elevation has extensive vertical emphasis glazing that appears to have been

replaced with UPVC windows. Other modern improvements to the building include white

plastic fascia boards and guttering.

2.14 The smaller school building is similar in appearance to the main building including similar

fenestration.

2.15 The nursery building is a demountable building located on a hard standing. The building has low

architectural value with an almost flat felt roof and small vertical windows and not decorative

detailing or historic features.

2.16 None of the buildings at the site or listed by CADW or locally listed.

2.17 Located centrally within the application site, to the rear of the school and nursery buildings, is a

tarmac surfaced playground covering 0.33hectares. There is a MUGA accommodated on the

playground but this is in poor condition and is currently in a state of disrepair. The MUGA was a

facility that was temporarily accommodated on the site. It is clear the playground attracts anti-

social behaviour indicated by a large amount of broken glass and litter.

2.18 The site boundaries vary on all sides. The boundary along Upper Hill Street is the most

prominent boundary characterised by red brick dwarf walls and railings to the front of the

school buildings. As the boundary leads north it is characterised by high wire fencing on a stone

plinth. The eastern boundary as it encloses the nursery buildings and associated grounds is a

lower level wire fence on a stone plinth. As a result of the site’s topography the stone plinth

becomes taller as the site slopes up to the north.

2.19 The northern boundary is characterised by a footpath which for a short stretch off Upper Hill

Street is a private drive leading to four detached properties with a legal right of way, this stretch

of the northern boundary is characterised by trees. Beyond these dwellings the footpath

becomes open and with no formal boundary other than the footpath itself demarcating the

application site from the wider surroundings. The footpath leads to the furthest westerly point

of the site which comprises steps that lead from the site towards Blaenavon town centre to the

south.

2.20 Access to the site can be achieved from various points across the site. The primary site access

point is located along Upper Hill Street to the south east providing a separate vehicular and

pedestrian access adjacent to one another. These accesses are gated only allowing authorised

personnel to the site. Two further access points are also located along the eastern boundary as

leads northwards on Upper Hill Street; one gated access is located north of the school building

solely for pedestrians and one to serve the nursery building for vehicles and pedestrians (this

being the primary access to the nursery when it was in occupation).

2.21 Given the open nature of the application site along the northern and western boundary there

are no formal access points and the site can be entered freely. The site cannot be accessed

from the southern boundary.

3.0 PROPOSALS AND SUPPORTING DOCUMENTS

3.1 The design rationale for the scheme was to create a unique modern, contemporary housing

scheme which lends itself to modern day living but would fully integrate within the historic back

drop if its location. Demonstrating the applicant’s commitment to developing a historically

sympathetic scheme a design competition was held whereby architects were invited to put

forward ideas to fulfil the design vision for the site and Rio Architects were appointed.

3.2 The proposals to develop the application site require the full demolition of the primary school

and nursery building. Full justification of the demolition is provided as part of this application in

the accompanying Justification of Demolition Statement.

3.3 Once demolition has taken place, it is proposed to develop the site for 53 dwellings. Due to the

site topography the development of the dwellings will be concentrated to the east, and north

and west. The area to be developed is similar to the existing development foot print (i.e.

existing buildings and associated surfaced play yard) resulting in much of the scrub land

remaining untouched.

Housing Layout

3.4 Generally, the scheme primarily comprises terraced dwellings proposed in a vertical alignment

north to south to follow the site’s natural contours and similar to the wider Blaenavon urban

grain. Further west into the site the urban grain becomes slightly less uniform and characterised

by semi-detached dwellings, apartments and detached units however largely replicating the

form of Blaenavon. Please refer to Appendix 3 for Proposed Site Layout.

3.5 The eastern boundary of the site is considered a prime location at the application site since it

immediately adjoins the existing built development of Blaenavon (along Upper Hill Street) and

represents the gateway from the WHS to the wider development.

3.6 It is proposed to develop 16no. dwellings along eastern boundary that abuts the public footpath

to create a strong, hard edge to the development reminiscent of the development style across

Blaenavon. The proposed dwellings in this location will be in terraced form and split into blocks.

On the approach to the application site from the south of Upper Hill Street 3no. linked dwellings

(plots 1-3) are proposed split from a further block of 4no. dwellings (plots 4-7) by the proposed

access road. Further north a pedestrian walkway is proposed which provides a convenient

access to the rear of the properties along Upper Hill Street. North again is a larger block of 6no.

dwellings (plots 8-13) split from a block of 3no. terraced dwellings (14-16) located into the most

north part of the site.

3.7 Collectively plots 1-16 create a terrace street form which serves to replicate the existing urban

form in Blaenavon. The dwellings are almost immediately adjacent to the public footpath which

is the traditional arrangement in Blaenavon. A conscious effort however has been made to

ensure dwellings are set back slightly from the public footpath and this area is demarcated by a

0.9m high stone wall this provides a defensible space for future occupiers and is more akin to

modern day living whilst respecting the historic grain.

3.8 Careful consideration has been made to ensure no parking is located to the front or side of

dwellings along Upper Hill Street to ensure the important eastern streetscene respects nature of

the town that historically did not incorporate car parking within its urban design. The parking

for these dwellings are located to the rear in a parking street.

3.9 A pedestrian access route located centrally along the site frontage (eastern boundary) is

proposed to provide an access to the parking street. This is considered to provide a convenient

route to the rear of plots 4-13 and improves the permeability of the development for

pedestrians.

3.10 Directly to the rear of the properties along the frontage of Upper Hill Street the development is

less uniform with 4no. terraced dwellings (plots 23-16) adjacent to two pairs of closely

positioned semi-detached units (plots 19-22) located centrally within the site. The allocated

parking for these units is located to the front and the rear and is generally well located to their

associated dwelling. Opposite these dwellings are two pairs of semi-detached units (plots 33-

36) with parking located to the side. To the south of these is an apartment block which contains

plots 29-32. The street that separates plots 19-23 and 29-36 is a proposed homezone area.

3.11 The apartment block (plots 29-32) is considered a key building within the development as it is

highly visible from the access points to the east and west. It is positioned in a staggered from

the public footpath/highway to add interest and make its presence more prominent. The façade

of this building will be finished in different materials to the wider development proposals and

elements of stone are proposed to enhance the stature of this building.

3.12 The homezone area will have a shared surface with some appropriate street planting and

differing surfacing to encourage both pedestrian and vehicles to use the area. The differing

surfacing will encourage lower vehicles speeds and configuration of the road as is curves around

from the north into the homezone area will also ensure vehicles speeds remain low.

3.13 To the north of these dwellings is a pair of semi-detached dwellings (plots 16-17) which are

orientated towards the parking street to the rear of plots 1-16. To the south are two detached

units orientated to face the end of the homezone. The parking for these units is located to the

site of these dwellings. The orientation of these dwellings is such to ensure overlooking in

parking streets and homezone area.

3.14 To the south of the application site immediately adjacent to the access road is a public open

space located between plots 27-28 and 43- 47, further details of the public open space is

discussed later.

3.15 In the western portion of the application site the dwellings are arranged around a green square

which reflects the Blaenavon ‘Stack Square’ arrangement and will is a key focus within the

development, particularly when approaching the site from the western access to the site.

Access and Highways

3.16 It is proposed the development will have three access points; two vehicular located along Upper

Hill Street and one pedestrian access to the west of the site. The road network within the site is

4.8 metres wide throughout and for the most part lined by a 2 metre foot path either side.

3.17 The two access points off Upper Hill Street are located to the south and north of the eastern

boundary and converge within the site to create a loop formation which loops around two

perimeter blocks resembling the typical form for Blaenavon. A road branches off the loop road

to the south west-west terminating at a turning head in the most westerly point of the site.

3.18 Part of the loop formation stretches around the rear of plots 1-16 that front onto Upper Hillside

School to form the parking street. The parking street is 4.8 metres wide like the wider road

network. The loop road also extends to the centre of the application site where it loops to the

front of plots 19- 26 and 29-36. This area of the proposed highway network is a shared surface

it is proposed this area will be a central homezone area as described above.

3.19 Access to the site is also available from the west of the site. This access is a dedicated

pedestrian route via the existing footpath that lines the north and western boundary of the

application site and links the site to the town centre to the south. This access is enhanced with

landscaping and leads to key areas within the site such as the LAP and the homezone area.

Public Open Space

3.20 It is proposed to develop two public open spaces within the development site. The formal open

space will be in the form of a Local Area Play (LAP) located in the west of the site overlooked by

apartments and proposed dwellings.

3.21 A secondary public open space is proposed to the south of the site, south of the access road.

This ground is restricted from built development due to its topography constraints however it is

suitable for informal open space and it is proposed to include some landscaping and seating

areas. Further details of this area will be discussed during the life of the application and it is

requested the requirement of a Management Plan is conditioned as part of any future planning

application

3.22 A large expanse of the periphery of the site predominantly to the south, west and part of the

northern fringes are undevelopable due to the steep land form. These areas will remain green

areas and will not be developed or landscaped formally but managed and enhanced as an

ecological area. As mentioned at paragraph XX, the site is designated as a SINC and the majority

of this area, despite it being of poor value, will be built upon if this application is successful. The

retention of the peripheral areas will provide opportunities to mitigate against the loss of parts

of the SINC by enhancement of these areas. It is envisaged this will be detailed in an Ecological

Landscape Management Plan the details of which are requested to be conditioned to any future

planning permission.

3.23 The planning layout as described above and included at Appendix 2 was influenced by a number

of surveys and reports completed to inform the planning application. A brief summary of each

report and its findings is included below:

Topographical Survey

3.24 The topographical survey was carried out by Davies Surveys Ltd. and was integral to ascertaining

the developable area of the application site since the land form in Blaenavon is particularly

steep.

3.25 The topographical survey indicated the level difference across the site is approximately 18

metres with the highest point of the site at 361 AOD to the north of the site and the lowest

point at 342 AOD to the south. The steepest land fall is around the periphery of the site to the

south, west and parts of the north and these are essentially undevelopable.

Ecological Assessment

Ecology Survey

3.26 A Phase 1 Extended Habitats Survey was completed by Sturgess Ecology to assess the ecological

features at the application site.

3.27 It identified the western part of the site lies within the Elgam Ravine SINC designated for its

diverse grassland habitat to the north west and includes the locally common Bluebells, Great

Burnet, Pignut and Bitter Vetch. The ecology report noted however that part of the SINC is a

surfaced play yard and is heavily managed by the Local Authority which decreases the ecological

value of it..

3.28 In addition to the grassland, other notable ecological features include:

Existing building on site likely to support bats

Large mature trees

Birds nesting in buildings and scrub

Potential habitat for reptiles

3.29 The report provided key recommendations including, amongst other things, replant or retain at

least 10 broadleaved trees, remove all tipped refuse and install 10 bird boxes within new

buildings.

3.30 The ecological assessment also made recommendations for the following survey works:

Bat survey

Reptile Survey

Re-check for Invasive plants

3.31 Following the recommendations a Bat Survey and Reptile Survey was carried out and the

findings are summarised below.

Bat Survey Observations

3.32 A Bat Survey was carried out by Hawkeswood Ecology and served to update an earlier survey

carried out by them in 2011, both reports have been submitted as part of this application.

3.33 The 2011 report found that the school building supported roosting common pipistrelle bats and

a further survey in 2012 concluded the school has low potential to support hibernating bats.

The updated 2013 report confirmed that common pipistrelle bats are still using the same roost

area as recorded in 2011. The roost is considered likely to be a small, male roost.

3.34 In light of the findings, a European Protected Species Derogation Licence (EPSL) will be required

and the following mitigation measures are likely to be required.

3.35 For Demolition of School Building:

Demolished between end of October and April

A temporary bot box erected

Areas where roost is located stripped by hand

Following removal of roofs the building is left to stand for two days and them

demolition can commence as normal

3.36 Specific Bat Mitigation:

Installation of bat tubes in some proposed dwellings

Appropriate lighting

Reptile Survey

3.37 A Reptile Survey was carried out by Sturgess Ecology. A total of 58 refugia were set out

between the middle of August concluding on the 20th September 2013. The only reptile seen

was a single Slow Worm at the edge of the sports pitch on the 21st August 2013.

3.38 It is unlikely this is the only reptile at the site but given the scarcity of the animal it is likely the

site supports a low population of reptiles. Furthermore the site is considered sub-optimal for

reptiles because it is heavily shaded by dense scrub or has a long history of regular mowing.

3.39 It is recommended that the following mitigation measures are carried out:

Destructive Search

Vegetation Clearance

Long-term habitat management/enhancement

Tree Report

3.40 A tree report was carried out by Treescene who confirmed the majority of the trees on site are

of low value (either U or C category) and can be removed.

3.41 An Ash tree on site located along the northern boundary has been classified as a B2 tree. It is

approximately 18 metres in height. It is proposed to retain this tree as part of the application

proposals and other trees where possible.

Drainage Strategy

3.42 A drainage statement has been completed by Nicholson Jones and outlines the strategy for foul

and surface drainage from the application site. Investigations have confirmed that a drainage

pipe crosses the site and there a 6 metre buffer is required whereby no built structures are

permitted to be built.

3.43 There are no capacity issues with the existing foul sewer and it is likely the foul drainage from

the development will connect to existing sewer subject to the necessary consents from Dwr

Cymru Welsh Water (DCWW).

3.44 The Site Investigation has confirmed that the underlying ground conditions are not suitable for

soakaways and therefore piped discharge off site will be required. Discharge rates will be

attenuated at a rate discussed with DCWW. Storage of the attenuated volume will need to be

located at the lower end of the site and its area and depth to be confirmed.

Transport Statement

3.45 A Transport Statement has been prepared to support the application by Asbri Transport. The

report concludes the development of the site will have an equivalent trip generation to the

previous school and nursery use, albeit a slight increase in the evening trips. Despite this it is

considered the trips generated by the proposed development can be accommodated within the

surrounding highway network.

3.46 The parking provision for the development is 109 spaces which is 9 short of the ‘County

Surveyors Society (CSS) Wales – Wales Parking Standards 2008’ (CSS). It is considered this is

acceptable because:

The site is within easy walking distance to the local amenitieed and town centre

6no. units are for assisted living which are likely to have low car ownership rates

associated with them

The site layout is pedestrian orientated

The development is 100% affordable housing which typically has lower than average car

ownership rates

Blaenavon has lower car ownership than the Welsh average

ASIDOHL Report

3.47 An ASIDIOHL has been carried out by Archaeology Wales to investigate the possible impact of

the proposed development on the historic environment. The assessment indicated the

proposed development would have an impact on two Historic Character Areas within the WHS

including HLCA001 Blaenavon Urban Core and HLCA002 Blaenavon Urban extension.

3.48 The ASIDOHL concludes the overall significant impact of the development, and the effects that

altering the Historic Character Areas concerned and the whole of the historic landscape area is

moderate.

3.49 The ASIDOHL proposes possible measures that could mitigate against the impact of the

development. These include:

Appropriately restore and maintain boundaries particularly where the site is adjacent to

the HLCA001 Blaenavon Urban Core;

Use of material in keeping with the general character of the area

Proposed planting scheme could help screen the development from viewpoint within

are HLCA001 Blaenavon Urban Core.

Design and Access Statement incorporating Code for Sustainable Homes, Pre-Assessment

3.50 The Design and Access statement (DAS) has been completed by Rio Architects to accompany the

application submission. The DAS outlines the design principles of the scheme as:

Create a contemporary development which reflects the historic richness of

Blaenavon

Create a distinctive environment which represents a development of its time

Promote a sense of community

Encourage permeability and connectivity without compromising security

Promote a sense of place

Promote inclusive design

Integrate needs of modern family life and living standards whilst retaining the

character of Blaenavon

Retain and enhance the ecological value of the site

Create a sensitive development which has a positive contribution to Blaenavon and

its future.

3.51 To achieve the principles the DAS assesses the site and its context including the opportunities

and constraints of the site, with particular concern to the heritage considerations given the

historic location. The DAS then outlines the objectives for the site and design parameters

before assessing the proposed site layout against the planning policy guidance and relevant

design guidance specific to the WHS.

3.52 The DAS concludes the represents an opportunity to create a high quality, integrated residential

development compatible with historic town of Blaenavon.

3.53 The DAS incorporates the Code for sustainable Homes Pre-assessment which indicates that the

proposed dwellings will be able to achieve a code level 3 + in accordance with the prescribed

standard set by Welsh Government.

4.0 PLANNING HISTORY AND PRE-APPLICATION ADVICE

4.1 There is no relevant planning history in terms of previous planning applications.

4.2 The site has been identified in the emerging Local Development Plan (LDP) under policy H3 for

64 dwellings (allocation H3/5), an extract of the LDP proposals map indicating the site is

allocation for housing is shown in appendix 4.

4.3 The LDP has now gone through the Examination in Public stage and likely to be adopted before

the end of 2013. No issues concerning the site were raised during this time.

4.4 The proposed development has been subject to extensive pre-application consultation with the

Local Planning Authority (LPA) who have been provided input in to the evolution of the planning

layout and provided advice in regards to the heritage conservation considerations.

4.5 Pre-application meeting with the LPA have been positive to date and Torfaen Planners have

provided comments in terms of preferred design objectives, conservation issues, World Heritage

Site considerations, highways and parking standards. The key issues raised by the LPA were:

A scheme that has a high quality design which respects the historic location

Terrace form development is preferable

A strong frontage to Upper Hill Street

A key building within the development to terminate vistas as you enter the site from

Upper Hill Street and the pedestrian access from the west

Parking should not dominate streetscene and parking to the front or side of dwellings

along Upper Hill Street is not permitted and rear parking courts were an acceptable

solution

4.6 Further pre-application consultation took place with the Design Commission for Wales (DCFW)

and on the 16th July 2013 the application was presented to the DCFW panel. The development

was received well by the DCFW and they made the following observations:

Given the historic environment the proposed development should seek to successfully

link the old with the new

Semi-detached properties are acceptable but will need to reflect the local architectural

character and use simple, good quality materials.

Concern was raised In relation to the public open spaces, particular the POS to the

south, regarding the natural overlooking and natural surveillance

Concern raised in relation to the natural surveillance of the parking courts and some

should be re-planned if possible to increase natural surveillance

Removal of the canopy on the from elevation if possible

The panel preferred simplified, less vertically exaggerated windows

Alternative boundary treatment designs to promote the undevelopable area around the

periphery of the application site and improve the view into the site when approaching

from the west and along the existing footpath to the north

4.7 Following the DCFW comments the LPA were content to allow semi-detached units as part of

the proposals.

4.5 The site layout plan has been developed to take account of the key issues raised by the LPA and

DCFW as far as possible. For example, the layout is dominated by terraced dwellings and

parking is avoided on street and to the side of proposed dwellings where possible, particularly

along Upper Hill Street. A signature building, in the form of an apartment block, is located mid-

way along the access road to add interest as you enter the site from both the east and west and

serves to successfully terminate vistas. The local authority also raised concern that semi-

detached documents may not be an acceptable form of development given the historic urban

grain of the Blaenavon.

4.8 The pre-application consultation was helpful in arriving at a high quality planning layout

appropriate to the relevant stakeholders whilst also meeting the requirements of the applicant.

5.0 PLANNING POLICY FRAMEWORK

5.1 The planning policy framework for the determination of this application is provided by national

planning guidance, together with the Gwent Structure Plan and Local Plan, and the emerging

Torfaen County Borough Council Local Development Plan.

5.2 The Wales Spatial Plan (2008 update), is an over-arching document which sets out a spatial

strategy for Wales which highlights objectives for various parts of Wales which are not specific

to local authority areas. National Planning Policy is contained within Planning Policy Wales

(PPW), published by the Welsh Assembly Government in March 2002. The latest version is

Edition 5 published in November 2012. PPW is supplemented by 21 Technical Advice Notes

(TANs).

5.3 The Development Plan for the purposes of Section 38 (6) of the Planning and Compulsory

Purchase Act 2004 is the Gwent Structure Plan adopted on 1st March 1996 by and the Local Plan

which was adopted on 27th July 2000 as planning policy for the Authority’s area. The emerging

Local Development Plan had previously been progressed to Deposit Stage (January 2012) and is

expected to be adopted by the end of 2013.

5.4 Below, we outline and discuss how the proposal aligns with the above policies and national

guidance and how it also complies with national and local policies and other guidance,

considered relevant to the proposal.

NATIONAL POLICY

Planning Policy Wales (5th Edition – November 2012)

5.6 PPW is the principle document of the Welsh Government which sets out the land-use policy

context for the consideration and evaluation of all types of development. The main thrust of

PPW is to promote sustainable development by ensuring that the planning system provides for

an adequate and continuous supply of land available and suitable for development to meet

society’s needs in a way that is consistent with overall sustainability principles. Paragraph 9.2.8

provides specific advice on the search sequence that should be applied to identifying sites for

housing. The advice states that: -

“In identifying sites to be allocated for housing in development plans, local

planning authorities should follow a search sequence, starting with the re-use

of previously developed land and buildings within settlements, then

settlement extensions and then new development around settlements with

good public transport links.”

5.7 Paragraph 9.2.3 states that:

“Local planning authorities 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.”

5.8 Paragraph 9.3 states that:

“New housing developments should be well integrated with and connected to

the existing pattern of settlements”.

5.9 Paragraph 2.6.2 specifically refers to planning applications where a development plan has not yet

been adopted or approved. It is stated in this context that:

“….in considering what weight to give to the specific policies in an emerging

LDP that apply to a particular proposal, local planning authorities will need to

consider carefully the underlying evidence and background to the policies.

National planning policy can also be a material consideration in these

circumstances.”

5.10 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, at the same time, by the decision maker when:

preparing a development plan

In taking decisions on individual planning applications

5.11 As such, in the case of areas such as the Torfaen County Borough Council where the existing

development plan is time-expired the general ‘Presumption in Favour of Sustainable

Development’ carries more weight.

5.12 In the context of the above reference is also made to Section 2.7 of PPW which states that:

“Where development plan policies are outdated or superseded local planning

authorities should give them decreasing weight in favour of other material

considerations, such as national planning policy, in the determination of

individual applications. This will ensure that decisions are based on policies

which have been written with the objective of contributing to the achievement

of sustainable development.”

5.13 Chapter 6 of PPW related to Conserving the Historic Environment and provides guidance in

relation to development within areas of historic nature.

5.14 Paragraph 6.5.17 relates to Conservation Areas and requires development to preserve or

enhance the character or appearance of a conservation area or its setting. The application site

is not within the conservation area however part is immediately adjacent to the therefore the

impact on the conservation area should be acknowledged.

5.15 As discussed above the application site is located with a World Heritage site and the following

paragraph 6.5.24 of PPW is relevant and states:

“World Heritage Sites are a materials planning consideration to be taken into account

by the local planning authorities in the determination of planning application, and by

the Welsh Government in determining cases of appeal or following call-in. The impact

of development proposals on both the sites and their setting should be carefully

considered.”

5.16 The Development Plan for the purposes of Section 38 (6) of the Planning and Compulsory

Purchases Act 2004 comprises the Gwent Structure Plan adopted in March 1996 and the Local

Plan for County Borough of Torfaen adopted 27th July 2000.

5.17 Torfaen County Borough Council is well advanced in terms of their preparation of the LDP which

has just gone through the Examination in Public and it is expected it will be adopted by the end

of 2013.

Gwent Structure Plan (GSP)

5.18 The GSP covered the period 1991- 2006 and is now effectively ‘time expired’ however in the

absence of the adopted LDP it remains the relevant plan, along with the Local Plan discussed

below, in determining planning applications.

5.19 The following policies of the GSP are identified at relevant:

5.20 Policy H2 relates to housing and requires such development to be located in or immediately

adjoining urban areas in suitable locations. Housing development is preferable on underused or

vacant urban land and appropriate peripheral rounding-off. The over development of land

should be avoided.

5.21 Policy H5 relates to affordable housing and requires housing development on a substantial scale

in both urban and rural areas to incorporate a reasonable mix and balance of house types and

sizes to cater for a range of affordable housing needs. Furthermore, policy H9 encourages the

provision of an appropriate size and mix of dwellings to meet housing needs. Extensive

proposals for both high density housing and large scale low density development would be not

normally be permitted since it would result in unsuitable living conditions and unduly waste land

respectively.

5.22 Policy H10 relates to planning obligations and states it is reasonable and necessary to require

benefits for the community in relation to new development. Such contributions can be sought

in relation to education, community facilities, employment purposes, affordable housing,

infrastructure provision, highway improvements, high standards of landscaping, layout and

design, and other measures to offset the impact of the development on the environment.

5.23 Policy T11 require new roads within private development to be built accordance with the

highway Authority's design guide and policy T14 requires appropriate car parking provision.

5.24 Policy BC2 favours protection and enhancement of conservation areas and areas of historic

merit.

5.25 ENV1 requires new development to make a positive contribution to energy conservation and

policy ENV3 requires drainage, flood risk and ground stability to be considered in new

development.

Local Plan

5.26 Similarly to the GSP, the Local Plan covered up to 2006 and is now effectively ‘time expired’ but

for the moment remains the relevant plan in determining planning applications.

5.27 The relevant policies from the Local Plan have been extracted below:

5.28 Policy G1 is the general policies for new development and requires new development to satisfy

the following criteria:

A. The impact of the proposed development in relation to existing / proposed uses

and the general character of the area. In particular, the following factors will be

considered:-

i. The proposal does not constitute over development of the site in terms of

the density, massing and form of the development.

ii. The design and visual appearance of the proposal, including materials,

respect the existing architecture of the area.

iii. The proposal respects the setting of the site in terms of the proposed

layout, massing and form iv) The proposal respects the urban fabric of the

area in terms of the space around and between buildings.

iv. The proposal does not have an unacceptable impact upon the amenities of

the residents in adjoining or neighbouring properties.

B. The impact of the proposal upon the environment. In particular, the following

factors will be considered:-

i. The proposal is consistent with the principles of sustainable development.

ii. The design for the site ensures that the proposal does not pollute the

environment.

iii. The proposal does not prejudice the topography, landscape and natural

features of both the site and the surrounding area in terms of design and

layout.

iv. The proposal respects the historical /archaeological interest of the site and

does not prejudice the recording or conservation of the archaeology

present on the site.

v. The proposal does not result in the unacceptable loss of, or damage to,

areas identified as being of special nature conservation importance.

C. The proposal does not result in the loss of valuable agricultural land to an extent

that would prejudice the viability of an existing farming operation or deplete the

stock of grades 1, 2 and 3a agricultural land to an unacceptable degree.

D. The proposal does not prejudice the existing or proposed level of service provision.

E The proposal sustains and/or enhances the existing level of community facilities.

E. The proposal has convenient access to and can be readily serviced by the public

transport network.

F. Access to the proposed site can be achieved without detriment to highway safety.

G. The road network is capable of sustaining the additional traffic generated by the

proposal.

H. A landscaping scheme that respects the surroundings and natural features of the

site has been included as part of the proposal.

I. The proposal can be connected to the existing foul sewer network or through other

facilities that do not have a significant adverse impact upon the amenity / use of

land or causes a public health nuisance or water pollution.

J. The site is, or can be adequately serviced without requiring visually intrusive

infrastructure

K. The proposal does not adversely affect the quality or quantity of surface or ground

water resources

L. The proposal does not result in the loss of important urban open space or

woodland.

M. The proposal will not be at risk from flooding nor would increase the risk of

flooding to other areas by virtue of its location or increased surface water runoff.

5.29 Policy G4 requires planning obligations from developers on development proposals to make

provision for related infrastructure, community facilities and environmental and community

benefits where the need for such provision arises from the development.

5.30 Policy G5 requires all development to be considered against the following highway criteria:

A. The proposal can be accessed safely.

B. The proposal is compatible with the existing road network

C. Satisfactory parking provision can be made on the site.

D. The layout allows for adequate servicing throughout the proposal

E. Adequate pedestrian provision can be made, e.g. by the formation of new footways

and footpaths, which integrate and enhance the existing pedestrian network.

F. The proposal is, or can be, easily serviced by public transport.

Where proposals are considered appropriate, the developer will be expected to enter into

planning and/or highway agreements in order to ensure that necessary on and off site

highway works are provided.

5.31 Policy S3 relates to residential development within the designated Urban Boundary on sites not

identified in the local plan will be permitted where the proposal satisfies all of the following

criteria:-

A. The proposal pays due regard to the integrity and character of the area.

B. The proposal is compatible with adjoining uses.

C. The proposal can be accessed without detriment to highway safety and is in

accordance with current adoptable highway standards.

D. Parking provision can be made on the site to a standard approved by the County

Borough Council.

E. The proposal incorporates a landscaping scheme that respects the site’s surroundings

and has the approval of the County Borough Council.

5.32 Policy S4 relates to affordable housing provision as part of new development and it retention in

perpetuity.

5.33 Policy S6 requires the provision of open space, landscaping and play facilities will be sought

within proposals for new residential development.

5.34 Policy L6 permits development on formal and informal recreational open spaces only where it is

no longer required for recreation use and the loss of the area would not result in a shortfall in

the overall provision in the community

5.35 Policy L4 requires development proposals to improve the public rights of way network.

5.36 Policy H7 specifically relates to Bleanavon and does not permit development that would

adversely affect or visually impinge upon the overall integrity of the ‘Landscape of Outstanding

Historical Interest’.

5.37 Policy C1 of the Local Plan identifies the application site (allocation C1/1) for primary School

development. The use of a site for education is no longer required and subsequently surplus to

requirement. This is considered to highlight the Local Plan is now outdated.

Emerging Local Development Plan

5.38 The LDP has not yet been adopted but is far advanced with full adoption expected at the end of

this year. Given the imminent adoption of the LDP it is considered necessary to address these

polices also and they have been extracted below:

Strategic Polices

5.39 Policy S1 states there is a presumption in favour of development within the Urban Boundaries

especially where is contributes to the creation and maintenance of sustainable communities.

5.40 Policy S2 requires new development to be sustainable and demonstrate they fulfil the following

criteria:

a. Contribute to the regeneration of existing communities;

b. Meet Sustainable transportation and infrastructure priorities and promotion of a

sustainable transport hierarchy, including reducing the reliance on the private motor

car and use of more sustainable modes of transport;

c. Protect and enhance the natural and built environment;

d. Promote the efficient use of land;

e. Maximise the efficient use of existing community infrastructure;

f. Utilise Sustainable construction techniques; and

g. Are located within the Urban Boundary unless it is an acceptable development in the

countryside.

5.41 Policy S4 relates to Place Making and good design and requires:

Proposals for all new development must have full regard to the context of the local natural

and built environment and its special features through: -

a. Promotion of local distinctiveness by sympathetic design, material selection and

layout including public art;

b. Delivering a mix of uses to complement existing facilities and aim to address local

deficiencies; and

c. Ensuring that location and layout integrates and contributes to local accessibility.

5.42 Policy S5 relates to housing provision in Torfaen and it states that approximately 675 dwellings

should be provided in North Torfaen, where Blaenavon is located.

5.43 Policy S7 relates the conservation of natural and built heritage and requires development

proposals to ensure the protection and enhancement of the natural and built heritage of

Torfaen, in particular: -

a. Biodiversity resources;

b. Geodiversity resources;

c. Water environment;

d. Landscape setting;

e. Character of the built environment; and

f. Historic assets.

5.44 Policy S8 requires planning obligations to be sought in relation to development specifically in

relation to the following key priorities:

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);

Maintenance and enhancement of the environment, historic assets biodiversity

networks and resources.

Community facilities;

Employment and commercial opportunities;

Waste management facilities and services;

Public realm improvements and public art;

Renewable energy and energy efficiency;

Improvements to the Monmouthshire and Brecon Canal;

Incorporation of Sustainable Urban Drainage Schemes (SUDS); and

Flood defence measures to mitigate the risk of flooding.

Borough Wide Policies

5.45 The relevant borough wide policies include:

5.46 Policy BW1 General Policy which relates to:-

Amenity and Design

Natural Environment

Built Environment

Utilities Provision

Design and Transport

5.47 Policy H3 allocates the application site for 64no. dwellings under allocation H3/5.

5.48 Policy H4 relates to affordable housing and requires 10% provision in North Torfaen.

5.49 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 of 10 dwellings or more, based on a

minimum of: -

a. 2.4 hectares of recreational open space per 1,000 population;

b. 0.4 hectares of on-site open space per 1,000 population;

c. 2.0 hectares of accessible natural green space per 1,000 population; and

d. 20 allotments (250m2 each) per 1,000 households.

5.50 BG1 relates to Locally Designated Sites for Biodiversity and Geodiversity Development proposals

will not be permitted where they would cause significant adverse effects on the resources of the

biodiversity network (including the features of a Site of Importance for Nature Conservation,

Local Nature Reserves, or Regionally Important Geological Sites unless it can be demonstrated

that: -

a. 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

b. Adequate mitigatory and/or compensatory provision is made proportionate to the

value of the ecological resources or geological site lost.

5.51 Policy HE2 relates specifically to the Blaenavon Industrial Landscape World Heritage Site

(BILWHS) and states that development proposals within the BILWHS will only be permitted

where it can be demonstrated that: -

a. The proposal promotes a standard of design in terms of siting, scale, massing and

materials, which is sympathetic to and preserves and enhances the character of the

local area and settlement form;

b. Important views into, within and out of the BILWHS are not prejudiced by the

proposals;

c. The proposal contributes to ensuring the preservation of the ‘Outstanding Universal

Value’ of the BILWHS designation; and

d. The proposal would not adversely affect or visually impinge upon the overall integrity

of the BILWHS and its landscape or historic setting.

All development proposals should be informed by the BILWHS Design Guidance and should

identify how the proposals are consistent with the principles in this document.

Supplementary Planning Guidance

5.52 The following Supplementary Planning Guidance is relevant to this application:

Affordable Housing Delivery Statement

Blaenavon Industrial Landscape World Heritage Site Design Guide

Planning Obligations

Other Relevant Documentation

5.53 The following documentation was also reviewed when developing this scheme:

Blaenavon World Heritage Site Management Plan 2011-2016

7.0 APPRAISAL

7.1 This section aims to identify the main issues relevant to the determination of the application

and assess the scheme against the relevant planning policy framework outlined in section 6.

These matters are considered to be as follows:

The principle of development in terms of land use planning policy and sustainable

development;

The need to address the demolition of existing buildings ;

The impact of the development on the heritage considerations;

The impact of the development on the residential amenity of surrounding properties;

The impact of the development on the ecological features;

The impact of the development in terms of access and traffic generation;

Any other material considerations including landscaping, ecology, drainage, etc

Principle of Development

7.2 The application site is totally within the settlement boundary of Blaenavon and therefore the

principle of development is established.

7.3 It is a brownfield site, used previously as a primary school and nursery, and therefore its

development is supported by PPW at paragraph 4.9 which has a preference for the re-use of

land stating ‘previously developed (or brownfield) land should, wherever possible, be used in

preference to greenfield sites’.

7.4 It is recognised in PPW that the re-use of brownfield sites promotes sustainability objectives

that underpin Welsh planning policy. It particularly promotes, amongst other things, the re-use

of sites within existing settlement and close to public transport nodes which are both

characteristics of the application site.

7.5 PPW at paragraph 4.9.3 actively encourages local authorities to ensure brownfield sites are

promoted for re-development. The application site is local authority owned and has become

surplus to requirements as an educational facility and the site is now being marketed a

redevelopment opportunity subject to relevant planning permission.

7.6 Furthermore, PPW at paragraph 2.7.1 states that where adopted development plans are

outdated LPAs planning officers should give them decreasing weight in favour of other material

considerations particularly national policy since these have been specifically written to achieve

sustainable development. The adopted plans for Torfaen are now outdated and therefore

national policy, which encourages development on brownfield land within settlement

boundaries, should be afforded substantial weight in preference to adopted plans.

7.7 The application site is also allocated for housing in the emerging LDP under policy H3 for 64no.

dwellings (allocation H3/5). The application site, therefore, has undergone a detailed

assessment by TCBC planning officers and has been identified as suitable for housing

development. The LDP has gone through its Examination in Public stage and no issues

pertaining to the application site were raised indicting its appropriateness residential

development.

7.8 Given the advanced stage of the LDP this planning application to development the site cannot

be considered premature. The determination of this application before (or indeed parallel to)

the adoption of the LDP will not go to the heart of the plan and is considered wholly acceptable

in planning policy terms.

7.9 It is acknowledged the LDP is not yet adopted however given its advanced stage and likely to be

adopted before the end of 2013 and its proposals should be given considerable weight when

determining this application.

7.10 As mentioned in section 4 the proposals to re-development Hillside School have been subject to

extensive pre-application consultation with the LPA who have supported the principle of

developing the site for residential purposes.

7.11 It is considered, beyond doubt, that the principle to redevelopment the site is established and in

accordance with national policy, emerging local policy and the LPA’s aspirations for the

application site.

Demolition of Existing Buildings

7.12 A separate justification statement specifically addressing the demolition of the school has been

prepared to accompany this application and indicates that it is not viable to develop the

application site with the retention of the school building. The retention of the school building

prohibits the development of the site.

7.13 The layout cannot successfully accommodate the school building and provide an appropriate

planning layout which fulfills the applicant’s requirements.

7.14 The conversion of the school would result in extensive alterations to the front elevation of the

building which would severely dilute to historic appearance of the school and thus negate the

reasons for retaining the building.

7.15 The conversion of the school does not enable to the need and type of housing required in

Blaenavon be provided. The proposed development will provide 100% affordable housing and

30% intermediate rent/low cost homeownership, which given the low development rates in

Blaenavon over the past 10 years, is invaluable development that the LPA should seek to secure

subject to an acceptable scheme.

7.16 The proposed development presented in this application is a high quality, exemplary scheme

which would complement and enhance the WHS and therefore the loss of the school would not

have an adverse impact on WHS and would or the cultural value of the site.

7.17 It is considered the reasons for demolition should be afforded great weight that out balance the

retention of the school building. This scheme represents a significant opportunity to bring

investment to Blaenavon in the form of a modern, yet historically sympathetic, residential

development.

Heritage Considerations

7.18 The historic setting of the application site has been a key consideration in the preparation of this

application and the prestige of the World Heritage Status of Blaenavon at international, national

and local level is acknowledged by the applicant and the development team. Particular regard

has been paid to Policy H7 of the LP and policy HE2 of the emerging LDP which specifically

relates to Bleanavon and does not permit development that would adversely affect or visually

impinge upon the overall integrity of the area.

7.25 High regard has been paid to the preservation and enhancement of Blaenavon through the

proposed development to ensure it is a worthy addition to the historic landscape and WHS

designation.

7.26 Blaenavon was designated as a WHS in recognition of its exceptional example of a remarkably

complete 19th century industrial landscape demonstrating the original social and economic form

of the town. In light of this, it is acknowledged that the preservation of the town’s character is

imperative to ensure the internationally recognised historic features are not diluted as a result

of this proposal.

7.27 An extensive review of the townscape, existing form and urban grain and materials palette was

undertaken by the development team to understand the heritage context. Moreover the

relevant planning policy and design guidance, outlined in section 5, was reviewed and pre-

application advice sought. Together this has informed the proposed planning layout.

7.28 The review indicated that the Blaenavon core is little altered and has a historically preserved

centre with more recent development as the town extends outwards and is not sympathetic to

Blaenavon’s landscape and is considered to have damaged to the historic nature of the town.

This application is an opportunity to invest significantly into the town and provides an

opportunity to reinforce the positive characteristics of the historic core by bringing a vacant site

back into beneficial use as required by the BILWHS SPG (section 2.2), restore some of the lost

value in the outskirts of the town centre and contribute towards meeting the local housing

need.

7.30 Despite the substantial benefits of the scheme, the importance of the design respecting the

historic integrity of the area is a highly weighted material planning consideration and the

applicant is aware of the obligation to ensure any future scheme is compatible with the historic

landscape.

7.31 The applicant, following close consideration of the BILWHS SPG whilst bearing in mind the

corporate aspirations of Melin Homes, has devised a design rationale for the application site to

create a unique modern, contemporary housing scheme which lends itself to modern day living

but would fully integrate within the historic back drop if its location. The BILWHS at page 21

encourages the vision by stating there is ‘no reason why well designed contemporary buildings

cannot be incorporated within the Blaenavon WHS’ but the broad principles of design should be

taken from the historic residential context and utilise the natural features of the application site.

It states that specific detailed design is hard to define in terms of a contemporary proposal and

pre-application discussions with the LPA made it clear that there was no example of good

modern residential development in Blaenavon and new ideas were welcome.

7.32 The proposed scheme will seek to reinforce the positive characteristics, natural features and

assets of the site to benefit the scheme and its future occupiers and users which is encourages

by the BILWHS SPG. The built form is proposed to follow the land form which will enable

attractive across valley views. The development will create a more usable pedestrian link to the

footpath (right of way) to the north of the site that is currently restricted in use by the kissing

gate to north.

7.33 The peripheral areas of the site which is generally steep in land form will be retained and

managed providing an attractive green space enclosing the site. This will protect the views

along the footpath and the privacy of future occupiers and existing residential dwellings.

7.34 In accordance with the aims of the BILWHS the scheme has considered the opportunities and

constraints of the site and emphasised the opportunities to improve the scheme whilst

benefitting the future occupiers and protecting the existing residents.

7.35 In terms of broad design principles, the scheme been devised to fundamentally reflect the urban

grain of Blaenavon to closely mirror the existing residential layout from an aerial photograph or

across valley perspective. The dwellings proposed are simple in form, without projections and

extensions, located on narrow plots with linear back gardens and positioned in a primarily

perimeter block formation enclosed by the highway. Roof form is uncluttered and shallow

pitched to reflect the typical style in the town. Fenestration will be reminiscent of the typical

terrace house within the town; two window to the upper levels and one to the lower level.

7.36 The proposed materials palette in terms of external walls and roof covering will primarily be

simple and reflective of the surrounding built development.

7.37 Replicating the broad design principles of the architecture in Blaenavon within the proposed

scheme will ensure it fully integrates into the existing urban grain of the historic form as

required by the BILWHS (page 18, 22 & 31).

7.38 The appearance of the scheme, however, will have be contemporary style adding a modern

twist to the typical, traditional Blaenavon housing style. This will be achieved by vertical

emphasis windows in modern material coloured dark grey, modern front doors and the

omission of traditional features such as chimney stacks.

7.39 Some feature buildings are proposed throughout the development in modern, sleek materials to

add interest within the scheme but these building will fundamentally take the form as described

above. They will not, therefore, be over dominant in the streetscene and will seamlessly slot

within the historic townscape and proposed development. Examples of the feature buildings are

the apartment block to the rear of the site (plots 48-53) and the apartment block located

centrally at plots 29-32, refer to elevation plans.

7.40 It is acknowledged that the BILWHS SPG specifically requires new development to respond to

the history of the site and its immediate surroundings. The most relevant point of reference of

the WHS to the application site is Upper Hill Street.

7.41 Upper Hill Street is a traditional terrace street following the land form as it slopes from north to

south, dwellings open immediately onto the public footpath and do not have on-plot parking

(although cars park along Upper Hill Street). The LPA made it clear that a strong frontage

reflecting Upper Hill Street is a key feature when developing the application site.

7.42 To respond the LPA aspirations and to accord with the requirement of the BILWHS (page 16) it is

proposed to reflect Upper Hill Street along the eastern boundary of the site and create a strong,

traditional terrace street following the landform. The appearance of the dwellings reflects key

design features of Upper Hill Street including similar fenestration, front door layout and

complementary, sympathetic materials will be proposed. Furthermore, derogation from the

Welsh Government DQR requirements has been requested to omit 600mm canopies from the

front elevations to ensure they respond well the historic surroundings. The proposed dwellings

will also lie almost immediately adjacent to the public footpath with a small area of defensible

space demarcated by a small natural stone wall. During pre-application discussions the LPA

were keen that the proposed dwellings along Upper Hill Street has a small area of defensible

spaces to the front elevation and did not open immediately onto the public footpath.

7.43 It can clearly be seen careful consideration has been taken in regards to the dwellings along the

eastern boundary to ensure they are locally distinctive whilst also mindful of the requirements

of modern living standards.

7.44 Further west into to the site, where the site is less well related to the WHS and less visible from

immediate and landscape views it is proposed to development semi-detached, detached and

apartments. These types of dwelling are not generally typical of the Blaenavon historic core,

although characteristic of the modern development on the outskirts of the town. To ensure

these house types integrate well into scheme the semi-detached dwellings have been

positioned in close proximity to each other to look similar to terraced dwellings thus reflective

of the historic grain of the town. The detached dwellings have been purposely excluded from

the ‘terraced’ streets formation and located to the south of the site off the access road. This

ensures they less visually intrusive as you enter the site and that they do not dilute the urban

grain of the wider development.

7.45 The semi-detached, detached and apartments all have a similar scale and form; two storeys in

height, simple form without projections or extensions and narrow plots. Obviously these

dwellings are larger than the terraced dwellings and have been designed to respond to the

prevailing design and appearance of the traditional larger dwellings in Blaenavon that would

have historically been the manager’s houses and typically resembled a double fronted terraced

house, see elevation drawings.

7.46 Materials have been briefly touched upon above it is considered important to establish the

broad principles in terms of the materials palette for the development. The importance of

materials in linking the development into the appearance of the Blaenavon context is

recognised. The key aesthetic link is with the wider WHS is the proposed dwellings along Upper

Hill Street and this element of the scheme will have sympathetic materials expected for such a

prominent location.

7.47 Other key locations such as the entrance to the west and the focal apartment block located

centrally within the site will also seek to incorporate a sympathetic material palette. Less

prominent areas of the site will also have sympathetic materials but will seek omit the higher

specification materials since they are less visible, will have a neutral impact on the WHS and are

commercially more viable and durable in terms of future maintenance and management. The

BILWHS SPG acknowledges that a large extent of Blanavon has been undesirably altered with

the incorporation of white UPVC windows, unsympathetic dormer extensions etc. and that new

development should avoid such incongruous features. This application will avoid such blights on

the WHS landscape but also seeks to utilise more suitable, practical and modern materials

where appropriate within the development. The approach to materials is compatible with the

BILWHS SPG and it is requested the principles as outlined are accepted and full details of

materials are conditioned to any future planning permission.

7.48 It is acknowledged that the boundary treatments of the site, to both the boundary and

internally, are highly important and integral to ensuring the site integrates well with Blaenavon.

Much discussions was held during pre-application discussions and with the DCFW in regards to

boundary treatments and it was emphasised that high quality materials including some natural

stone dwarf walls with railings were required in the most prominent locations, particularly along

the periphery of the eastern and western boundaries and internally at key locations. This

approach accords with the guidance contained within the BILWHS. It is considered less high

specification boundary treatments could be used for the internal boundaries.

7.49 The proposed dwellings are required to meet the Secured By Design standards and therefore

closed boarded fences would be required for intermediate boundaries.

7.50 The principles in relation to the proposed boundary treatments have been established and it is

requested that full details are conditioned to any future planning permission.

7.51 Another key feature to the development and its integration within the WHS is the treatment of

the public realm. The BILWHS at page 45 requires the public realm to reflect the identity of the

local area. This has been achieved by designing the main area public open space which is

proposed to be a LAP, located to the west of the site, to reflect the traditional Blaenavon ‘Stack

Square’ arrangement. This area is well overlooked by adjacent dwellings which have specifically

arranged internal layouts to encourage active overlooking of the LAP. This area also has a

footpath leading from it which converges with the public footpath to the edge of the site

creating a welcoming, open area when the site is entered from the west.

7.52 A secondary public open space is proposed to the south of the site which again provides a public

open space within the application site which is well overlooked by carefully orientated dwellings

surrounding it.

7.53 It is considered the public open spaces are successfully located within the development creating

a balanced amount of openness and recreational areas within the development without

adversely impacting on the Blaenavon urban form which is historically hard development with

limited green areas.

7.54 The public realm of the homezone area is also key to success of the development and will be

finished in a range of differing hard surfacing with minimal landscaping to create a safe shared

surface and welcoming pedestrian friendly environment to encourage activity within the

development. Despite this not being typical within Blaenavon it has been designed so not to

detract from the typical development pattern within the town.

7.55 It is considered the public realm works are respond well the identity of the area and the

replicate other successful examples within the town and accords with the guidance outlined in

the BILWHS SPG.

7.56 It is recognised that the site is located in close proximity to the conservation area and the given

extensive heritage considerations that have informed the planning layout the conservation area,

without doubt, will be preserved and enhanced in accordance with national planning policy,

policy BC2 of the GSP, policy G1 of the LP and policy S7 of the emerging LDP.

7.57 The design evolution of this scheme has occurred over an extended period of time with the

input from all key stakeholders to arrive a design solution that has acknowledged the historic

context whilst also incorporating a contemporary style to provide a residential scheme fit for

modern living. It is considered beyond doubt that the heritage of Blaenavon will benefit from

the proposed scheme and accords with the relevant adopted planning policies (BC2 of GSP and

H7 of the LP) and the relevant policy within the emerging LDP- policy HE2.

Residential Amenity of Surrounding Properties

7.58 The residential amenity of the future occupiers and existing residential dwellings has been

considered thoroughly throughout the development of this scheme.

7.59 In terms of impact on existing dwellings the two key relationships are identified between the

application site and Upper Hill Street and Old Queen Street.

7.60 The proposed dwellings along Upper Hill Street will achieve distances of between approximately

10.9 meteres and 12.6 metres from the existing development; this does not meet the typical

required privacy distances. It is, however, widely accepted that developing within a typical

welsh valley town such as Blaenavon such proximity on terraced streets is rarely avoided. In

order to replicate the urban grain within Blaenavon, in accordance with the prescribed guidance

in the BILWHS and pre-application advice from the LPA, extended privacy distances are not

possible. Since the development is predominantly replicating the form of terraced house

development privacy distances achieved along Upper Hill Street are replicated throughout the

proposed development and considered acceptable and appropriate to the area.

7.61 The proposed development and Old Queen Street is approximately 31.9 metres apart and Old

Queen Street is at a lower level that the application site. This is a more that acceptable distance

therefore the amenity of Old Queen Street will not be adversely impacted. Moreover, the

majority of the south boundary of the application site will remain undeveloped and remain as is

(aside from landscape management) thus further minimalising the impact of the proposed

development.

7.62 The most imposing relationship along the southern boundary of the site is between the side

gable of plot 1 and no. 31 Old Queen Street. No. 31 Old Queen Street is a public

house/restaurant and the proposed side gable has a window at lower level and higher level

which are into the hallway and landing respectively. It is considered this arrangement is

appropriate.

7.63 The existing dwellings to the north of application site are located extended distances from the

proposed dwellings and are located on higher ground therefore the amenity of these properties

will be unaffected. The across valleys views from these dwellings are preserved as a result of

the land form and the modest dwellings proposed as part of the scheme.

7.64 It is considered the planning layout promotes acceptable residential amenity and safety of

future users of the application site and any potentially adverse issues to residential amenity

have been successfully design out as far as possible. For example, parking streets and public

open spaces are overlooked as much as possible with dwellings orientated towards these areas

and visually permeable boundary treatments proposed. Footpaths into the site to the west and

centrally along the eastern boundary are well overlooked by proposed dwellings. The

development has, as far as possible, avoided hidden and neglected spaces as required by the

BILWHS SPG. Furthermore, the development will meet the Secured By Design standards as

required.

7.65 As previously mentioned, the development seeks to improve the existing right of way network

by providing an easily accessible route onto the existing footpath to the north and west of the

site leading to Blaenavon town centre. This is in accordance with policy L4 of the LP which

require development to improve the public rights of way networks.

7.66 The scheme has also considered future refuse collection arrangements and provided an area to

the rear of the proposed dwellings along Upper Hill Street and ensured the parking street can

accommodate a refuse vehicle. This avoids the any wheelie bins and other refuse containers to

along Upper Hill Street as a result from the proposed development. This was considered key by

the applicant to protect future residential amenity and was raised as an important issue by the

DCFW to preserve the historic character of Blaenavon.

7.67 The proposed development has taken account of existing and future residential amenity and

represents a successful design solution to avoid any adverse impacts.

Transportation

7.68 Vehicular access to the site is via two existing access points associated with the former school

use via Upper Hill Street. Pedestrian access is also available via these points and an additional

pedestrian only footpath located centrally along Upper Hill Street. A further pedestrian access

point is proposed via the west of the application site from the existing footpath. The proposed

access will successfully enable person to navigate the site providing a short, more easily

accessible route to the existing footpath from Upper Hill Street.

7.69 It was considered the access along the western boundary represents the western gateway of the

development and the primary connection between the site and town centre the majority of

local amenities in Blaenavon. It is proposed to provide a landscape footpath link from the

existing footpath into the site which visually links to the open space area to the west. This

access will be well overlooked by the proposed dwellings in the vicinity and the boundary

treatments will be of a high quality to ensure use of this access is encouraged.

7.70 The proposed roads within the scheme are 4.8 metres wide which has been agreed as

acceptable in pre-application discussions with Torfaen County Borought Council highways

department. The highway network has been tracked to ensure a refuse vehicle, fire tender and

service delivery vehicle can maneuver the site in accordance with the prescribed standards. It is

acknowledged that large vehicles cannot access the private drive to the rear of plots 37-41

however it is within the required distances for refuse vehicles and fire tenders. It is not

considered detrimental to the overall scheme that on the rare occasion’s service delivery

vehicles will need to access these dwellings that it cannot access this driveway. It is considered

far more detrimental if the scheme had to be redesigned to accommodate exceptional

circumstances such as a one off delivery of a large item to one of these plots.

The proposed highway network is considered acceptable and accords with policy T11 of the GSP

and G5 of the LP and policy BW1 of the emerging LDP.

7.71 In terms of traffic generation it is considered the new development will generate a comparable

level of trips generated by the extant (education) use with a slightly higher level in the evening

peak times. Notwithstanding this increase in evening peak period trips, it is considered that

these trips can be accommodated on the surrounding highway network and is an acceptable

level of traffic generation.

7.72 It is proposed to provide 108 spaces which is 9 short of the adopted CSS guidelines. Pre-

application meetings and discussions with the Council indicate that the highways department is

prepared to accept this shortfall, as increased parking levels would compromise the design and

its compatibility with the historic nature of Blaenavon and the area’s World Heritage Site

designation. In addition, this level of parking provision is justified since the site is within easy

walking distance of the amenities in the town centre, 6no. dwellings are for assisted living and

are likely to have a low car ownership rate associated with them, the site is a pedestrian

orientated design which influences the attractiveness of walking as a travel mode, the proposals

include a large proportion of affordable housing which typically has a lower than average car

ownership rate associated with it and Blaenavon has a lower car ownership rate than the Wales

wide average.

7.73 It is considered the parking provision is minimally below the adopted standards and given the

nature of the site and proposed development, as mentioned above, is justified and therefore

acceptable and accords with policy T14 of the GSP, policy G5 of the LP and the relevant LDP

policies.

Housing need

6.74 The emerging LDP requires 4700 new dwellings over the plan period of 2006 – 2021 and it has

been identified that a total of 550 dwellings are required in North Torfaen, where Blaenavon is

located. Of the 550 dwellings required 231 market and 319 affordable units are required.

6.75 It is acknowledged that Blaenavon housing is predominantly terraced, poorly insulated, has

insufficient parking and lacks level access. There is also a high level of owner occupation in the

area.

6.76 Blaenavon has seen very little new development in recent years with only 11 affordable

dwellings being delivered in the last ten years. The last schemes delivered were 4 units

converted back from office space at Lion Court, 3 homes in Ellick Street, and 4 units in the New

Road Farm scheme, which ceased after phase 1.

6.77 The recent Welfare Benefit and Bedroom Tax reforms have given rise to the need for smaller

accommodation such as 1 and 2 bed units into which people can downsize. There is a significant

under resource of small units and in addition the local authority is experiencing a high number

of people seeking assistance in finding affordable accommodation both socially rented and

intermediate housing. Between July 2012 and July 2013 a total of 1,692 new people registered,

but only 782 properties became available and were advertised. There are currently 2,782

people registered on the common housing register, and of these 377 are in high housing need.

6.78 A local housing needs study was undertaken in August 2013 and identified that there was a lack

of general needs independent living housing for older people and a lack of opportunities for

people to be able to purchase good quality affordable family accommodation in Blaenavon. This

has resulting in many of the younger generation leaving the area and Blaenavon having a high

older person population which currently cannot sufficiently be accommodated for.

6.79 In light of the above it is clear there is a urgent need for affordable housing in North Torfaen and

a wider range of housing choice.

6.80 This application proposes to provide 100% affordable housing of neutral tenure- almost five

times what has been delivered in the area over the last ten years. The tenures will include a

range of low cost home ownership and intermediate rent. The proposed development will

benefit the area and provides just under 20% of the shortfall in housing need in North Torfaen.

Furthermore, the scheme provides arrange of housing choice including terraced, semi-detached,

detached and apartments in a range of tenures.

6.81 This housing provision that scheme proposes accords with the relevant housing polices

(including policy H5 of GSP, S4 of the LP and S8 of emerging LDP). It is also considered the

contribution to this application will make towards the identified shortfall is a material

consideration that should be afforded appropriate weight.

Other Material Considerations

Ecology and Landscaping

6.82 The existing School supports a common pipistrelle bat roost therefore an ESDL is required in

order to demolish the building. It is considered the bat roost can be successfully supported

elsewhere and the demolition of the school will not adversely impact upon the species if the

recommended mitigation measures are implemented. It is proposed to include 4 bat tubes

within the development at plots 18, 19, 37 and 53.

6.83 The site supports a number of nesting birds but it is considered that if site clearance is

undertaken at appropriate times in the season and 10 bird boxes installed within the

development then there will not be a detrimental impact on birds at the site.

6.84 One reptile was found at the site. It is considered if the appropriate mitigation measures are

implemented as outlined in the accompanying reptile survey there will be no adverse impact on

this species.

6.85 It is acknowledged that the western part of the site lies within a SINC designated for its diverse

grassland habitat and therefore the development will result in the loss of part of it.

6.86 The ecology report indicated that within the site the SINC largely comprised of dense scrub and

species poor semi-improved grassland with two small areas of semi-improved grassland. It also

identified that a large part of the SINC is covered in hard surfaced play yard which is considered

of little value to the SINC overall.

6.87 It is acknowledged the development of the site will result in the loss of the semi-improved

grassland and some of the species poor semi-improved grassland however the majority of the

development is concentrated upon the hard surfaced area and therefore will not impact upon

the SINC.

6.88 Despite this it is acknowledged the loss of parts of the more valuable areas of the SINC need to

be mitigated against and to ensure the loss if compensated for it is considered an Ecological

Landscape Management Plan is devised, in collaboration with the applicant, the consultant

ecologist and council ecologist, to manage the retained areas of the SINC which are currently

characterised by dense scrub.

6.89 It is envisaged the Ecological Landscape Management Plan will ensure litter is cleared from the

area and enhance the retained areas by planting of appropriate native species and grassland

habitats of value for nature conservation. It is considered measures of this nature are

appropriate to mitigate against the loss of diverse grassland habitat from the SINC.

6.90 Given the nature of the mitigation required it is considered appropriate that the Ecological

Landscape Management Plan incorporates both ecological and landscaping details in the one

management plan for the purposes of this scheme. It is requested the full details of this plan is

conditioned.

6.91 It has been demonstrated the management of the ecological features and the implementation

of suitable mitigation will not result in the unacceptable loss of habitats and is in accordance

with the relevant planning policy including policy G1 and BG1 of the LP. Furthermore, this

approach accords with the emerging LDP policies particularly policy BG1.

Drainage and Flooding

6.92 The site is not located within or adjacent to an identified flood zone and the proposed

development is not considered to increase risk to flooding.

6.93 The drainage strategy demonstrates the site can successfully drained in terms of both foul and

surface water includes the consideration of Sustainable Urban Drainage Schemes (SUDS) and

therefore complies with the relevant planning policy namely ENV3 of the GSP and policy S8 of

the LP.

Trees

6.94 The tree report has indicated the trees on site are largely of poor value but the most valuable

tree (T29 as identified in the Tree Constraints Plan) will be retained and other trees where

possible. This accords with policy G1 criterion B. iii of the local plan.

Code for Sustainable Homes

6.95 All the proposed dwellings will meet the Code for Sustainable Homes level 3+ in accordance with

the Welsh Government requirement. Sustainable development is also encouraged by local

planning policy including policy G1 and S2 of the LP and the development accords with these

polices.

Planning Obligations

6.96 The applicant is aware, in accordance with the guidance in policy H10 of the GSP and policy G4

and S8 of LP that it is likely that Section 106 contributions will be sought by the LPA to offset and

potential impact the development may have on local infrastructure.

6.97 Discussions in relation to the extent and nature of these contributions have not yet commenced

and will and will be negotiated during the life of the planning application.

7.0 CONCLUSION

7.1 This planning statement has been completed on behalf of Melin Homes to accompany a full

planning application for the demolition of existing school and nursery buildings and

development of 53no. units and associated works at former Hillside School and Nursery, Upper

Hill Street, Blaenavon.

7.2 The site is located in the north of the administrative authority of Torfaen County Borough

Council. The application site is located in within the defined settlement of Blaenavon north of

the town centre and immediately adjacent to the Blaenavon conservation area. Blaenavon is

located approximately 9.5km from Pontypool town centre, approximately 7.5km from Bryn

Mawr and approximately 10.5km from the centre of Abergavenny. Blaenavon is a designated

WHS and the application site lies adjacent to the conservation area.

7.3 It has been demonstrated throughout this statement that the proposed development accords

with all relevant national and local planning policy and meets the aims of the emerging LDP

policies.

7.4 The planning layout has taken full account of the historical location of the application site and

the heritage considerations have dictated the design principles of the scheme.

7.5 The application represents a positive development for Blaenavon by proposed a wide range of

differing house types and tenures with a predominance of affordable housing which seeks to

meet an identified housing deficient in the town.

7.6 The scheme has undergone substantial reapplication consultation with key stakeholders

including the LPA, DCFW and local residents; all of which was very positive.

7.7 The scheme requires the demolition of the existing school but the retention of the school is

outweighed by overarching material planning considerations.

7.8 In light of the above, it is considered the proposed scheme represents a well-thought out, high

quality development that would benefit the community of Blaenavon.

APPENDIX 1

APPENDIX 2

APPENDIX 3

APPENDIX 4

Pontypool

North Torfaen

T2/1a

T2/1b

T2/1a

T2/1b

T2/1a

T2/1b

T2/1a

T3/2T3/2

T3/3

T3/4

T3/5

T3/5

T3/4

T3/9

T3/9

T3/9

M4a/1

M4a/2

M4a/3

M3

M3

SAA5

SAA4

H3/1

H3/3

H3/2

H3/5H3/4

H3/6

H3/7

H2/1

H2/7

H2/2

T1/2

EET3/2

EET3/3

EET3/1

EET2/5

CF1

EE2/6

EE2/7

T3/7

T3/10

T2/2

M4b

C1/3

C2/5

C2/6

C2/7

C2/8

See BlaenavonInset Map

See PontypoolInset Map

This area lies withinthe Brecon Beacons

National Park and doesnot form any part of

this LDP

Post

BM 322.39m

PH

Car Park

Office

TCB

Victoria

TCB

PH

Club

Cenotaph Lane

El Sub Sta

Post

Garage

323.7m

316.7m

Shelter

Shelter

Car Park

El Sub Sta

Queen

STREET

Car Park

314.6

m

Club

COMMERCIAL

319.7m

324.9m

GP

PH

Club

PH

LB

PH

Boot

Lane

331.

6m

Hall

Bank

327.

4m

Lion Court

Lion Court

Library

PC

(PH)

Provid

ence

Provid

ence

House

HouseOxford

Cottag

e

NEW

QUEE

NST

REET

Bapt

ist

HIGH

STRE

ET

Chur

ch

Hore

b

PARK

STRE

ET

1 to 17Church View

PRINCE

STREET

Church

Ashfield Houses

Chapel

OLD JAMES STREET

Moriah

Baker Street House

BURFORD STREET / STRYD BURFORD

CourtCongregational

Bethlehem Bethlehem

OLD WILLIAM STREET

MARY STREET

IVOR STREET

BROA

DST

REET

ANNE STREET

CROSS STREET

MARKET STREET

SecondaryBlaenavon

Car Park

School

Secondary School

Blaenavon

PARK

STRE

ET

LION STREET / HEOL Y LLEW

VINCENT STREET

HIGH

STRE

ET

BROA

DST

REET

DUKE

STRE

ET

92

95

90

23

22

29

100

10

2

6

25

24

3431

16

4

12

11

89

18

14

23

13

2

12

94

4

13

17

2

87

1

11

19

17 2

20

24

20a

104

97a98

4

103

110

17

4

21

6

1

3

101

107

2

12

97

28

1

22

6

11

8182

86

29a

2625

1 to 22

80

4

2

4

29

9

19

20to

25

6

11

6

1

1617

12

45

17

43 2

26

29

22

49

69

73

55

2

7

70

6

7to

12

1

58

13 to 18

6866

62

32

27

1716

5

11

40

83

5

10

14

78

85

44

46

5756

63

4142 65

64

1

45

61 61

44

6266

1

55

32

39

69 34

79

70

5

4

76

71

74

3235

77

73

72

36 to 38

13 to 18

PP1

PP2

P10

0A

P100

B

P100C

PS

1

CwmAfon

Und

Line

War

Pipe

Fn

Pond

FB

PC

FB

PC

PC

Meml

TCBLB

Glenview

Llyswen

Bank

Baptist

Glenside

Crane Street

Church

Highde

ne

Garage

El Sub Sta

ShingleThe Mount

TCBLB

Und

EDBdy

Def

TERRACECOEDCAE

CRUM

LIN

STRE

ET

Shelters

TowerClock

Wye

cliff

Brentw

ood

Garth

Register

Stamfor

dHou

se

Brynhfry

d

Office

Surgery

Car Park

135.9m 132.6m

Hall

Hall

Surgery

Delfryn

HallMews House

Shelters

Track

Playground

Blorenge

CAPELSTREET

BM 146.15m

Unicorn Inn

MelroseIvydene

Bungalow

El Sub Sta

Car

Cartref

Car park

Park

TCB's

Club

Bank

TCB's

El Sub Sta

UndW

ardBdy

GranvilleHouse

PO

1to11

1 to 4

CountyCourtOffice

Edmonton

Court

Sub StaEl

137.5m

White

Hart

Hotel

St David's

Presbyterian

Church

BM133.01m

Cinema

Multistorey Car Park

132.9m

Mews

Castle

Melling

Court

El Sub Sta

Car Park

SM

Plas

ElSub Sta

Windyridge

The

Kampala

El

Oak

Kenley

Sunnybank

Bungalow

Club

The Grove

Tall Oaks

TCB

Tank

CRED

Bdy

Hollybanks

Barclay

128.75m

Ael y Bryn

Davaar

The Hollys

BM

Park House

High Trees

The CroftLOWER PARK GARDENS

Shangri-la

Warmley

Greenlands

1 to 12

MyrtleBank

Gables

ROSEMARY

Bank

Bank

LANE

125.9mShelter

Parkside

Flats

Marden

Government Office

Army

CrosswaysClub

Ashton

Crossways

House

Citadel

Salvation

Highbank

Fernbrook

Mirasol

Avoca

166.7m

Ty BrynAlnwick

Wingfield

Hillcroft

Gwynt

Ellsnor

KinfaunsRosem

ereDulce

Domum

Arwel

Vectis

Kendon House

Drew-Arfon

BM136.79m

133.2m

133.8m

Karibu

PARKGARDENS

Highfield

ClaireMontWynrose

Sub Sta

157.0m

Glenrise

The Firs

Hillinda

BroadDevonia

Pond

PC

Graig Villa

Mae

syrh

af

Erle

smer

e

Bandstand

TROSNANT

Ivan

hoe

PEN-Y-GRAIG TERRACE

STREET

Manse

ManseThe

The

The

Labu

rnum

s

Row

ans

The

Ingl

enoo

k

Def CW Und

CH

Garage

PO

Stelvio

ST DAVID'S CL

(PH)

(PH)

Ryec

roft

Bunga

Low

Pembroke

House

TrefloydLyndley

Brompton House

Ashley House

St Cuthbert's

(PH)

CamdenHouse

Travancore

Town Bridge Build

ings

Rosemary Lane

Caerfachnant House

(memorial)

Hall

Chur

ch

GrottoView

Glanant

Playing Field

172.5m

Playing Field

PH

BM15

2.13m

155.4m

Club

175.9m

157.6m

CRUM

LIN

STRE

ET

164.

14m

BM

163.1m

163.7m

ON ROAD

BM15

9.42m

AltonTerrace

Mervyn

Terrace

Subway

167.6m

Warehouse

134.4m

BM 139.40m

ChurchCourtMount Pleasant

Yard

151.5m

146.7m

Builder's

Greenlands

Brook

Brook127.7m

Yard

Gas Depot

Works

Trosnant

Garage

Trosnant

ROAD

FB

125.9m

Ash Yard

NICHOLAS

STREET

LOWER

PARKTERRACE

BevanCourt

Aneurin

126.5m

Graig Villa

CLARENCE

BM 127.31m

CLARENCEROAD

CLARENCE ROAD

Builder's

CLARENCEROAD

117.09m

141.2m

JOHN

STRE

ET

ALBION ROAD

CAPEL STREET

LOWER

BRIDGESTREET

Cycle Track

BM

RiversideCourt

Museum

Plas-y-garn

Allotment Gardens

Park

Cour

t

Pond

A4043

The Globe

151.8m

158.2m

BM159.47m

BM 156.73m

PH

Bank

PH

Bowling Green

Central Mews

Putting Green

P

Glantorvaen House

P

Playground

FairfieldSt James' Hall

Red Cot

PC

Park Cottage

House

Park

Terr

ace

Weir

PontypoolMedical Centre

OSBORNE ROAD

GEORGE STREET

PARKROAD

PENYGARN ROAD

ST DAVID'S

CLOSE

PARKROAD

ROSEMARY

LANE

St Alban's Comprehensive School

CRAN

EST

REET

MARKET STREET

Subway

Surgery

HIGH

STRE

ET

UPPER BRIDGE STREET

PH

COMM

ERCIAL STREET

139.3m

MARKET STREET

PARKROAD

St Alban's

STREET

GLANTORVAEN

Comprehensive School

COMM

ERCIAL

ROAD

Library

Market Square

Tennis Courts

Multistorey Car Park

UPPERPARK

TERRACE

A4043

ST JAMES' FIELD

St James'

Hall

Vicarage

HANBURY ROAD

Juni

orM

ixed

Scho

ol

156.1m

CycleTrack

Mew

sChurch

143.3m

Villa

Church

Trosnant

132.3m

CLAR

ENCE

STRE

ET

UPPER TROSNANT STREET

PH

TROSNANT STREET

Penygarn

PathPath

Car Park

Car Park

50

61

43

58

57a

52

44

5448

57

373941

7

5

4

1

1

6

12

4

1

7

1

2

5

315

9

35

18a

13

14

8

17a

7

17151

18

15 82

74

10

4a

32

1113

25

27

12

12

37

1 to 6

51

11

23

15 11

21

13

33

32

3125

2927

6448

42

45

8

7

3

4

3

1

2

9

7

1

1

7

6

8

1

5

3

2

2

65

4

1

3

16177

63

12 11

30

2571

1

22 23

14

12

1to24

17

14

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