Representation to Deposit Draft of City & County of ...€¦ · between Swansea City Centre and Llanrhidian, via Gowerton and Penclawdd. The route of the service runs along the North

Unit 2 Cross Hands Business Workshops, Heol Parc Mawr, Cross Hands, Carmarthenshire SA14 6RE Email: [email protected] Tel. 01554 527111 Web: www.jcrplanning.com

Representation to Deposit Draft of City & County of Swansea Local Development Plan

Land at Wernffrwd, Llanmorlais, Swansea

On Behalf of

Mr. M. Swiston

Prepared by: Richard Banks Our Ref.: 0232a Date: August 2016

____________________________________

mailto:[email protected]

Representation to Deposit Draft Mr M. Swiston Land at Wernffrwd, Llanmorlais, Swansea August 2016

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1.0 Introduction

1.1 The City & County of Swansea have prepared a Local Development Plan under the

provisions of Section 62 of the Planning & Compensation Act 2004. The Council

have placed the Plan “on Deposit”, as required by the Town & Country Planning

(Local Development Plan) (Wales) Regulations 2005, for a six-week period

commencing 18th July 2016.

1.2 JCR Planning Ltd has been instructed by Mr M. Swiston (hereinafter referred to as

the “Objector”) to prepare Formal Representations to the Deposit Draft of the City &

County of Swansea Local Development Plan (LDP) in respect of land located at

Wernffrwd, near Llanmorlais, Swansea (the “site”).

1.3 The Representation takes the form of a formal objection in that the Objectors do not

consider the Plan to be “sound”, and does not meet the requirements of all of the

tests of soundness. In particular, the Objectors, do not consider the LDP to comply

with the test of soundness, as outlined in paragraph 2.5.11 of Planning Policy Wales

(8th Edition – 2016), which questions “Will the Plan deliver?” (i.e. is it likely to be

effective?)

1.4 The Objector is of the firm opinion that Wernffrwd should be considered as one of the

named “Key Villages” specified under Policy CV1 of the Plan. The proposals put

forward under this submission include for a settlement limits defined about the built

form of the village, and includes a short frontage of residential development, in the

form of two detached bungalows, to mimic the established form of development along

the unclassified road from the junction with the B4286 North Gower Road to the

south, leading down to the Marsh Road about the tidal estuary.

1.5 This Representation Report has been prepared to supplement and provide a detailed

justification for the inclusion of the Wernffrwd settlement within the Plan, and its

contents should be read in conjunction with the accompanying Ordnance Survey

plans.


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2.0 Site Location & Characteristics

2.1 The subject land consists of part of a field frontage off the eastern flank of an

unclassified road which leads off a junction with the B4295 North Gower Road,

leading northwards towards Marsh Road, and the tidal marshes off the Burry Estuary.

The land is used for grazing, being part of a larger well-kept field enclosure, which

fronts the entire eastern flank of the road as it gradually descends to St David’s

Church off Marsh Road. A well maintained hedgebank marks its frontage.

2.2 The unclassified road is known for its winding alignment, with an almost continuous

frontage of dwellinghouses off its western flank. Residential properties are also to be

found off the eastern flank, and adjoining the field enclosure within the Objector’s

ownership. Further residential properties are to be found at the lower, northern

extremity of the village about St David’s Church and fronting Marsh Road.

Predominately they consist of traditional, two-storey, terraced cottages, with

bungalows nested between groupings of terraces.

2.3 The Objector’s submitted land for potential development land consists of a short

frontage of some 65 metres, immediately adjoining established properties known as

“Ersyl” and “Lane Cottage”, and directly opposite the properties known as

“Sunningdale” and Brook Vale”. It extends to a depth, back off the near side of

highway, of some 35 metres, and therefore contiguous with established residential

curtilages in the village.

2.4 The Wernffrwd carriageway allows for two-way traffic, but the extent of field frontage

and hedgebank along the highway at this point, severely restricts carriageway width

to single flows, and which is compounded by the lack of on-street passing places.

It is subject to a 30mph speed limit, but well-lit with public light standards. The

proposals under this submission include for the dedication of the field frontage for

carriageway widening, and further passing places along the field frontage to the north

of the proposed plots.

2.5 The site is illustrated from an extract of the Ordnance Survey Plan at Figure 1 below,

being edged in red for identification. Figure 2 provides an indication of its setting

within the settlement of Wernffrwd.


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Figure 1

Figure 2

2.6 The subject site’s field enclosures are graphically shown in the following

photographs. Photographs 1 to 3 below provide an illustration of the field frontages

from the public highway, and at lower ground near St. David’s Church.


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Photo 1

Photo 2

Photo 3


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3.0 IDENTIFICATION OF KEY VILLAGES

3.1 The Deposit LDP contains a list of “Key Villages”, totalling 18 in number, spread

across the County, and defined by a settlement boundary about each settlement’s

built form. Policy CV1 allows for appropriate development within such defined

settlement limits provided that:

(i) Is located within the defined settlement boundary, as shown on the Proposal Map;

(ii) Sympathetically integrates with the surrounding natural and built environment, taking into account the unique rural character of the village and the quality of the surrounding landscape and seascape;

(iii) Protects important rural views and vistas; (iv) Does not have a suburbanising effect; (v) Would not result in the loss of natural heritage or valuable green

infrastructure, or otherwise harm heritage assets; and, (vi) Utilises previously developed land and/or redundant buildings where

possible.

3.2 It is noted that several North Gower settlements are identified as Key Villages,

including Llangennith, Llanmadoc, Llanrhidian and Three Crosses. Paragraph 2.10.1

defines a Key Village as one which “consists of at least 25 but no more than 1000

dwellings and is supported by appropriate complementary facilities such as a school,

shop, pub, church, community hall or post office. In addition, the selected villages are

accessible by public transport and have a cohesive structure.”

3.3 An analysis of the LDP preparation reveals that the Council did prepare an Inset Plan

for Wernffrwd, and subsequently published it for public consultation during the Pre-

Deposit Draft stage of the Plan in late 2014. It however, does not appear to have

progressed through to the Deposit Draft and identified under Policy CV1.

3.4 Evidence of new, predominately infill development, confirms that housing land

demand in North Gower remains high and the locality remains very popular given its

coastal location, and availability of a multitude of community facilities. There appears

to be very little available housing opportunities to carry over into the LDP plan period,

and consequently the subject landowner would submit that an additional, minor new

site should be brought forward for inclusion in a properly defined Key Village.

3.5 The Objector maintains that the settlement of Wernffrwd is a cohesive grouping of

dwellings set between the B4295 and Marsh Road, and contains well over the

prescribed threshold of 25 dwellings, as defined above. Accordingly Figure 4 below

provides a submission of a settlement boundary about the settlement form, and

includes part of the Objector’s land off the eastern flank of the principle road.


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Figure 4

4.0 SETTLEMENT SUSTAINABILITY

4.1 Wernffrwd is accessible to the local primary school, local shops, community facilities

and public bus and rail services, as itemised below.

4.2 Public Transport

Wernffrwd lies upon the local public bus network, with residents able to undertake a

short walk onto the B4295 to access local bus stops. Service 116 runs an hourly

between Swansea City Centre and Llanrhidian, via Gowerton and Penclawdd. The

route of the service runs along the North Gower Road (B4295). The Objector’s site at

Wernffrwd is only 3 minutes’ walk from bus stops upon the main road.

Gowerton railway station is some 10 minutes’ drive from Wernffrwd, or accessible on

the 116 bus service. It offers regular services to Swansea, Cardiff and eastward to

London and north to Manchester. Westbound services operate to Llanelli,

Carmarthen and Irish ferry services at Fishguard and Pembroke. The “Heart of

Wales” service operates via Gowerton en-route to Mid Wales and Shrewsbury.


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4.3 Schools and Colleges

Penclawdd Primary school lies some 5-10 minutes’ drive from the site at Wernffrwd.

The school is recorded as having spare capacity to accommodate further pupils from

minor new developments in the locality.

Gowerton Comprehensive School is accessible by public bus and school transport

from bus stops near the Wernffrwd road junction, being a short 10 minutes’ journey.

Gower College Swansea has a primary campus at Belgrave Road, a 15 minutes’

drive from the subject site at Wernffrwd.

4.4 Local Shops, Public Houses & Community Facilities

Local shops are to be found at Penclawdd, specifically at Belle Vue and Station

Road, including the CKs supermarket, butchers, cafes, hairdressers and post office,

being a 5-10 minutes’ drive from Wernffrwd

Public houses are to be found at Crofty and Llanrhidian, and all within a 15 minutes’

walk of the site.

Wernffrwd does contain a community facility – St. David’s Church – and thus

fulfils another qualifying criteria for inclusion as a Key Village under Policy

CV1.

4.5 Employment Opportunities

Employment opportunities at Crofty Industrial Estate and Station Road in Penclawdd

are only a few minutes’ drive from Wernffrwd.

Garncoch Industrial Estate at Gorseinon and employment units at Penllergaer, both

at Gorseinon Road and Parc Penllergaer, are located within a 15-20 minutes’ drive of

Wernffrwd, as is Swansea West Industrial Estate at Fforestfach.

The Mardy Trading Estate at Kingsbridge is only 15 minutes’ drive from the site.

Trostre Industrial Estate near Llanelli is also only a 20-25 minutes’ drive from

Wernffrwd

The subject site is therefore easily accessible to a wealth of jobs opportunities in the

locality, and accords with the relevant criteria of PPW advice.


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5.0 ACCESSIBILITY TO PUBLIC INFRASTRUCTURE

5.1 Highway Provision

Vehicular and pedestrian access can be directly formed onto the Objector’s land at

Wernffrwd.

Figure 1 of this Statement illustrates for an indicative site layout of 2 detached

bungalows or dormer bungalows across a short site frontage.

The section of highway is quite restricted in width at this point as a result of the rural

nature in the carriageway. The site frontage as existing prevents improvements

unless it is incorporated into a road widening scheme, as shown in the submitted site

layout at Figure 1.

The carriageway could be widened to 5.5 metres in width, with further vehicular

passing places formed further north within the Objector’s land ownership, and thus

greatly improving the free flow of traffic for all road users, as well as a safe refuge for

pedestrians using the carriageway.

The proposals will therefore bring about significant highway gains to all motorists and

pedestrians at Wernffrwd The lack of available passing places causing conflict

between road users at present, and cannot be resolved without the dedication of the

field frontage.

5.2 The proposals could provide for one paired access onto the unclassified carriageway,

allowing for satisfactory visibility in both directions. The forward visibility for all road

users at Hendy Road will also be improved as a result of the proposed road widening

scheme.

5.3 Foul Water / Sewerage Provision

The landowners are aware that Gowerton Sewage Treatment Works is undergoing

an improvement programme under AMP6, over the period 2015 to 2020. It is

envisaged that the development of this site can accord with that timescale. Sewer

and mains water connections are available within the Wernffrwd carriageway.

5.4 The site is also located within the catchment of foul water treatment which is finally

discharged into the Burry Inlet. The catchment has experienced difficulties in water

quality for several years, and a Memorandum of Understanding between NRW,

Welsh Water and Swansea and Carmarthenshire Councils has been in operation.

The landowners fully understand that the proposals to discharge additional foul flows

into the public sewerage system may require forms of surface water betterment from

the combined system to compensate for those additional foul flows. The landowners

are already exploring mitigation measures of diverting surface water from existing

properties to contribute towards such a betterment scheme.


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5.5 Surface Water Disposal

Ground conditions at the site appear satisfactory to enable soakaways to be used,

with no evidence of standing water on the site, or areas liable to a high water table.

The site will require attenuation measures to be deployed to ensure a controlled run-

off into existing drainage ditches of the western perimeter. The proposals will seek to

achieve a Sustainable Urban Drainage System (SUDS) as part of a detailed scheme.

5.6 Flood Risk

Figure 5 below provides an extract from the Development Advice Maps (DAM) as

referred to within the Assembly’s Technical Advice Note (TAN) 15: “Development and

Flood Risk”. The site is located in Zone A and therefore not susceptible to either tidal

nor fluvial flooding. The Zone C2 designation associated with the tidal estuary does

not extend northwards beyond St. David’s Church, even within predicated extreme 1

in 1000-year flood events.

Figure 5

5.7 Land Stability & Past Mining Activity

There are no known past mining features on the subject land. The locality has had a

history of coal mining, and any development upon the site would take into the need

for a thorough investigation of sub-strata ground conditions when designing

appropriate foundation and road details.

Extract from

DAM map –

Jan 2016

Objector’s

site



6.0 ECOLOGY, TREES AND HISTORIC INTERESTS

6.1 Ecological Interest

The Objector’s part field enclosure comprises wholly-improved pasture. No readily

identifiable habitats for protected species are identified, and the prevailing for flora

and fauna does not exhibit any plant specimens of importance, or rarity to warrant

special justification or further analysis. In short, there is no particular biodiversity

interest in the site.

A Phase 1 Ecological Survey could be commissioned to examine the roadside

hedgerow, with a translocation possible as part of a road widening scheme, and such

a translocation taking place outside the bird nesting season.

6.2 It is noted from the Deposit Draft of the LDP, that there are no special designations,

or “Environmental Constraints” north of the B4295 road. The designation of the tidal

marshes as a Site of Special Scientific Interest and RAMSAR site is over 150 metres

from the site.

6.3 Trees

The above Google Earth image at Figure 2 illustrates that there are no tree

specimens within the Alternative Site. As mentioned above, the proposed roadside

hedgerow can be translocated as part of a road widening scheme.

6.4 Archaeological and Historic Interests

There are no known archaeological records for this part of Wernffrwd, and no

evidence from the Proposals Maps of any Ancient Monuments in the immediate

locality. Neither are there any listed buildings in close proximity to the site.

7.0 LANDSCAPE SETTING

7.1 The indicative site layout plan produced as Figure 1 illustrates for only two detached

dwellings, of identical footprints, across the short site frontage. This density is

comparatively modest, and respective of adjoining frontage plots within Wernffrwd

7.2 The setting of frontage development such as that depicted will give rise to lesser

impact upon the landscape, with the site well screened to public views from the

south, by virtue of sloping ground topography and housing at Wernffrwd nearer the

main road junction, and; to the south by mature vegetation and further established

housing and St. David’s Church as shown in Photo 3 above.



7.3 The proposed layout will enable each plot to be equipped with traditional rear garden

space to a minimum of 10 metres depth, together with off-road car parking on the

form of surfaced driveways. All existing boundary hedgerows can be fully retained or

translocated along the site frontage. New native species hedgerows can be planted

to form rear and north-western side boundaries.

8. CONCLUSIONS

8.1 Wernffrwd is a cohesive settlement, situated between the B4295 North Gower Road

and Marsh Road, which runs parallel with the tidal estuary between Crofty and

Llanrhidian. It contains in excess of 25 dwellings and contains one community facility,

that being St. David’s Church.

The village is within easy walking distance of bus stops providing access to a min

public bus route across North Gower to Swansea City Centre, and employment

opportunities at Penclawdd and Gowerton. The Objector submits that Wernffrwd

should be included as a “Key Village” under the provisions of Policy CV1 of the Local

Development Plan.

8.2 The Objector’s site forms part of a field frontage, and is not located at a prominent

position within the prevailing landscape. Instead it is located at a lowland position, set

against existing housing, and directly opposite similarly proportioned dwellinghouses.

8.3 Careful attention can be devoted to hedgerow translocation and respective ecological

matters, however no habitats for protected species, or biodiversity rich plant life has

been identified.

8.4 The indicative proposals offer the potential for road improvements at Wernffrwd,

through the dedication of the field frontage for carriageway widening to form passing

places. Highway safety will accordingly be improved for all road users.

8.5 The Objector therefore respectfully request that the Council, and the Inspector

appointed to conduct the Public Inquiry to the LDP, give further consideration to the

inclusion of Wernffrwd as a Key Village under Policy CV1 within the LDP, and a

consequential definition of settlement limits to include the Objector’s land as

specified.

Documents

Representation to Deposit Draft of City & County of ...€¦ · between Swansea City Centre and Llanrhidian, via Gowerton and Penclawdd. The route of the service runs along the North