Swansea LDP Examination

Statement Submitted by Swansea Council

Hearing Session 7: 15th February, 2018

Strategic Development Area SD L,

Hafod Copperworks and Tawe Riverside

Contents

Contents ...................................................................................................................... 2

1.0 Introduction ......................................................................................................... 3

2.0 Development Proposals and Current Planning Status ........................................ 3

3.0 Delivery and Viability .......................................................................................... 6

4.0 Responses to Issues Raised During Deposit LDP Consultation ......................... 8

5.0 Responses to Questions, Matters and Issues raised by LDP Examination Inspectors ........................................................................................................... 8

6.0 Summary and Conclusions ............................................................................... 11

Appendix A ............ …………………………………………………………………………15

1.0 Introduction

Document Status and Purpose

1.1 This Statement has been prepared by Swansea Council to inform the Examination of the Deposit Swansea Local Development Plan (LDP) and relates to the site known as Hafod Copperworks and Tawe Riverside (the Site). The Statement provides the most up to date information available relevant to the Site, and aims to provide clarity to the Examination Inspectors regarding the soundness of the Deposit LDP are, and highlights any proposed amendments arising from representations made or issues raised by the Inspectors.

1.2 The Site is allocated as a Strategic Development Area (SDA) in the Deposit LDP

under Policy SD L, which sets out mixed use development proposals for the site and includes an indicative concept plan.

1.3 The purpose of this Statement is to provide the Examination Inspectors with the

agreed position of the Council, and any relevant other parties as specified, in relation to:

- details of the current stage of planning proposals for the site - matters of deliverability, phasing and infrastructure - responses to objections submitted during Deposit consultation relating to the

site - any additional minor amendments proposed to resolve objections submitted,

and - its responses to the ‘Matters and Issues’ relating to the site as raised by the

Examination Inspectors

2.0 Development Proposals and Current Planning Status

Development Site and Proposals 2.1 This regeneration area focuses largely on the opportunities presented by the

former Hafod and Morfa Copper Works site, an area of regeneration opportunities along the new Morfa Road distributor Road and Tawe Riverside Park on the East bank of the River Tawe. Maps illustrating the boundary of the site in the context of the surrounding areas are presented in Appendix A of this statement. The regeneration area forms an important linking corridor between the eastern side of the City centre, St Thomas and the Liberty Stadium with significant opportunities for leisure and residential redevelopment and regeneration.

2.2 Hafod and Morfa Copperworks Area - This part of the site is promoted as a

mixed use heritage led development. The development proposals aim to bring the listed Hafod Copper works buildings back into use for appropriate new functions. Development on the adjacent waterfront sites will include residential and commercial pub restaurant and hotel uses. These developments must preserve and enhance the setting of the heritage assets, capitalise on the waterfront

location and provide a high quality living environment with strengthened links to the community.

2.3 Morfa Road Area – The Morfa Road area consists of largely privately owned sites

and regeneration opportunities. A high quality mixed use area of residential, commercial and light industrial uses is promoted for this area focused on Morfa Road as a significant spine street, and also capitalising on the attractive riverside setting. The recently constructed Morfa distributor road has considerably raised the profile of this part of the city and has acted as a catalyst for regeneration and redevelopment along the corridor, significantly changing its character and role. This area has consists of a number of largely privately owned sites, which have been the subject of redevelopment and regeneration proposals, including proposals for residential and student accommodation.

2.5 River Tawe Green Corridor - An established greenspace link and cycleway

pedestrian route along the Eastern bank of the river connects the Hafod/Morfa site and Liberty stadium to St Thomas and the Eastern side of the City centre. The West bank cycleway is partially completed, with further sections proposed pending the delivery of private sector development proposals.

2.6 St Thomas Residential Site – This is a 2.8ha waterfront site at the Eastern

gateway to the City centre, which is promoted for residential use. There has been market interest in this site, and a range of options are under consideration for delivering future development. In the short term the site may be required to support temporary storage facility for construction of priority developments in the Central area.

2.7 Whilst the majority of the text of Policy SD L in the Deposit Plan is maintained as

up to date and appropriate, there are some proposed updates to the policy/supporting text and illustrative Concept Plan that are suggested, which are considered to improve the Policy, having regard to updated . These amendments are itemised in Section 6 of this Statement as Matters Arising Changes (MACs). Each proposed MAC is considered an appropriate amendment to the Plan to reflect updated evidence and current prevailing circumstances.

Site Promotion and Development Progress

2.8 The Council has assembled the following project team to implement the delivery of development at Swansea Vale, with relevant technical advisors:

- Swansea Council Regeneration Officers- Site master planning, site disposal

and co-ordination of technical studies for the wider site opportunities. - Swansea Council External Funding Team officers working specifically on the

delivery and funding of the Power house project. - Swansea University- Potential collaborators on site delivery options for

Hafod Morfa Copper works - Penderyn Whisky – Potential regeneration partners and re use of a

substantial listed building at the core of the Hafod Morfa Copper works destination.

- The Powerhouse Project is supported by an extensive consultancy team including GWP architects, Atkins and Aecom.

2.9 The Council is progressing work across departments on the following key areas

of regeneration project work:

1. Swansea Council Regeneration Team are currently updating the Tawe Riverside Corridor Strategy (2006) and Hafod Morfa Copper works Masterplan 2014 (SPG07) into one comprehensive Masterplan to support the future regeneration proposals set out in SD L Tawe Riverside and Hafod Morfa Copper works.

2. Swansea Council is working collaboratively with Penderyn Whisky at the

Hafod Morfa Copper works (Power house/ canteen) to refurbish and bring this currently semi derelict listed building back into positive use as a leisure destination. This proposal is the subject of a Heritage Lottery Fund, and consultants have been appointed to work up a detailed scheme for the external elements of the building.

3. A further current project is to progress the restoration of the shell of the grade

II* listed and scheduled Musgrave Engine House. 4. Swansea Council is proposing to market 3 council owned waterfront

development sites at Hafod Morfa Copper works, and capital receipts will be used to provide match funding to support the restoration and reuse of listed buildings including the Powerhouse project and deliver wider infrastructural needs of Tawe Riverside.

5. River access/Pontoons - Provide for river boat travel with pontoons at Morfa

Stadium and Hafod Morfa Copperworks (linking to pontoons at Sailbridge site). Funding bid prepared (FLAG/ Coastal Communities 2018).

6. Kilvey Hill linkages - Discussions with private developer regarding improved

access and sustainable development at Kilvey Hill.

Current Planning Permissions

2.10 The following projects are subject to planning proposals and/site disposals:

– Outline planning permission for student accommodation and commercial units on the Morfa Road frontage has been recommended for approval subject to a S106 agreement on the former Unigate site (with an indicative figure of circa 700 student rooms).

– Pipehouse Wharf sale to Coastal Housing and pre planning discussions on other sites.

– 2.11 The Council is committed to moving forward proposals in a collaborative manner

with key stakeholders, including with:

- Cadw - ongoing engagement with regard to listed and scheduled structures on site and wider area.

- Natural Resources Wales - consultations on flood mitigation options, and - Dwr Cymru Welsh water - currently being consulted on infrastructure

requirements for the Hafod Morfa Copper works site, and additional requirements for Penderyn trade effluent.

Technical Work and Consultation on Infrastructure Needs

2.12 The following areas of technical work undertaken in support of projects within site

boundary.

- Hafod Morfa Copper Works Strategic Flood Consequence Assessment (July 2017). The Hafod Morfa regeneration site falls mainly within Zone A. However part of the proposed waterfront development areas lie within zone C2, but the modelling has demonstrated that a re-evaluation of C2 may be necessary as hydraulic modelling suggests these areas are not entirely liable to flood risk. The FCA also proposes off site flood mitigation measures on council owned land further upstream which are the subject of further discussion with NRW.

- Drainage Infrastructure. Discussions ongoing with DCWW with regard to likely service needs to support residential and commercial uses on the Hafod waterfront sites. The Penderyn whisky distillery use will place additional demands on the drainage network and an appropriate point of connection, and potentially pumping station will be required for this use and wider sites requirements.

- Archaeological Studies - Baseline archaeological studies have been undertaken to inform and de-risk development proposals on the Hafod Morfa waterfront sites (2017).

- Various Building condition and structural studies- to support Penderyn Project. 3.0 Delivery and Viability

3.1 The site is proposed to be allocated for mixed commercial, residential and

employment development. The site is expected to contribute 370 dwellings to the LDP housing requirement.

Housing 3.2 The number of units capable of being constructed during the Plan period amounts

to approx. 370 units with the capability of a greater number being delivered beyond the Plan period. This is considered a reasonable estimate at the current time.

3.3 The table following provides the agreed trajectory for the site, which accords with

the details set out in the Council’s submitted statement to the Examination on

Phasing and Delivery (ED 006.2 refers). On the basis of a capacity of 370 within the plan period (up to April 2026, and a start on site in 2019, this is anticipated to be as follows:

SHPZ Site Status Capacity 2010-25

2020-21

2021-22

2022-23

2023-24

2024-25

2025-26

Central Tawe Riverside Corridor & Hafod Morfa Copper Works

SD L 370 90 50 50 40 70 70

3.4 Appendix 2 of submitted documented ED006.2 provides further information

regarding development of SD L. Infrastructure Requirements

3.5 The following table provides a summary of the infrastructure requirements relevant to the site:

On and off-site measures including any appropriate reinforcement works to the public sewerage network. Schemes to accommodate growth proposed in Adopted LDP will be considered for inclusion in AMP7. Alternatively, developers can fund necessary reinforcement works themselves identified through the commissioning of a Hydraulic Modelling Assessment. Drainage Infrastructure- point of adequacy and potentially pumping station for wider site.

AT40 Tawe Riverside Link -Completion of Riverside cycleway footpath on the Western river frontage

Flood Mitigation works Alamein Road

River quay wall repairs

Provide for river boat travel with pontoons at Morfa Stadium and Hafod Morfa Copperworks (linking to pontoons at Sailbridge site)

Listed structures – repair /restoration

Maximise access to river corridor as key area of public realm and green infrastructure Linkages to adjacent communities/Kilvey Canal Bridge River Tawe Bridge link at Hafod Morfa Copper works

Enhance East bank of river as a linear park with improved public access

Enhance White Rock as a Heritage Park through landscaping and access works

Upgrades / extensions to existing Primary and Secondary schools in the catchment area.

Measures to protect a public sewer or a number of public sewers crossing allocated Strategic Sites in the form of an easement width or diversion.

3.6 The list of infrastructure requirements has been prepared from current best available evidence and represents the position as at January 2018 in terms of available information from the Council, infrastructure providers and landowners.

3.7 It is sufficiently detailed at present to underpin the proposed allocation of Site

SD L, however the list of requirements cannot reasonably be considered absolutely final as the definitive statement of all requirements, estimated costs, delivery methods and funding sources.

4.0 Responses to Issues Raised During Deposit LDP Consultation 4.1 The Council has submitted the following as Core Documents to the LDP

Examination, which sets out its position in relation to issues raised during the Deposit LDP Consultation, and highlights any changes to the Plan that are considered appropriate having regard to representations made:

- LDP 17 Deposit Consultation Report (July 2017) - LDP 20 Schedule of Non-substantive Amendments to LDP (July 2017) 4.2 The Council’s responses to the representations received in relation to this Site,

and its proposed ‘Non-substantive Amendments’ as set out in the above documents all remain valid. The Council believes that these amendments should be considered at the appropriate hearing session, and they are therefore identified at the end of this statement in the section titled ‘Proposed Matters Arising Changes (MACs)’, which also details any relevant potential MACs arising from this Hearing Statement.

5.0 Responses to Questions, Matters and Issues raised by LDP Examination

Inspectors

5.1 The following paragraphs provide comprehensive answers to the Matters and Issues raised by the Inspectors in the Agendas published in December 2017.

a Are the proposed land uses (including the quantum and density of housing)

appropriate and consistent with extant planning permissions? In addition to the criteria set out in policy SD 2, is the policy clear about what it seeks to deliver as a minimum, and does it provide an appropriate level of detail?

5.2 The land use mix in SD L is based on the regeneration of riverside sites along

the Tawe corridor whilst retaining some existing employment uses. A number of sites have implemented permissions for residential development and in January 2018 an outline planning application for a student accommodation scheme (with an indicative figure of 706 bedrooms) was recommended for approval subject to a S106 agreement on the former Unigate site (ref 2016/1573).

5.3 The policy is clear on the number of homes but deliberately does not define the

quantum of employment land, leisure and community uses in order that this can be explored through the masterplanning and viability process. The sites are

appropriately reflected in the current Concept Plan, and it is anticipated that an Area Regeneration Strategy will be prepared to provide further guidance.

b How much employment floorspace is anticipated to be provided on the site,

and of what type? As per PPW and TAN 23, has a sequential assessment been undertaken?

5.4 The Tawe Riverside corridor is a mixed use residential/commercial and leisure

area, and the role and character of this area has evolved away from its formerly industrial /employment role as regeneration opportunities progress within areas of private and council ownership through the corridor.

5.5 PPW establishes the principle of sequential text in relation to town centre related

uses and TAN 24 at paragraph 1.2.7. sets out the sequential approach that LPAs should follow. TAN 24 states that LPAs “should give first preference to sites within the boundaries of settlements (including planned new settlements and urban extensions)”. SD L is an urban extension, therefore a preferred location within the context of the sequential text.

c Should the policy identify the amount of Affordable Housing expected to be

delivered? 5.6 The proportion of affordable housing required for sites in the Central Strategic

Housing Policy Zone (20%) is clearly set out in Policy H3 and the Council consider that this proportion of affordable housing can be delivered within SD L. It also maintains that the final agreed level of affordable housing to be delivered on-site will be decided following further detailed viability assessments and having regard to all necessary S106 contributions. This will only be concluded at planning application stage and it is therefore not considered appropriate for the site specific policy to define a precise figure this at this stage.

d Are the identified uses and development requirements viable and capable

of being delivered within the plan period, taking into account S106 requirements, necessary infrastructure/mitigation, and other policy requirements, such as District Heating and Cooling (Policy EU 3)?

5.7 Developments will be delivered through private site regeneration opportunities,

and regeneration at the Council owned Hafod Morfa Copper Works as a heritage led mixed use destination. It is likely that the Council owned regeneration and restoration opportunities provided at Hafod Morfa Copper works will require collaborative approach with the private sector and the securing of grant sources to support restoration work and infrastructure needs (Drainage) in order to be deliverable. The specific feasibility and practicability of implementing district heating/cooling for this site has not been assessed.

e Are the placemaking principles the right ones and do they strike a good

balance been clarity and flexibility? Are they appropriately reflected on the Concept Plan?

5.8 The placemaking principles within policy SD L are bespoke to this site; for example regenerating the heritage sites, reference to the Cadw characterisation report, the requirement to engage with the river frontage. Generic placemaking principles for all SD sites are set out in SD2. The SD sites are of sufficient scale to accommodate the placemaking principles whilst creatively addressing constrains. The placemaking principles are strategically represented on the concept plan within the constraints of the plan scale using graphics and numbered annotations. It is anticipated that an Area Regeneration Strategy will be prepared to provide further guidance.

f Should the Cadw characterisation report be referenced and are its key

recommendations reflected on the Concept Plan? 5.9 The Cadw characterisation report is an informal document that has informed the

drafting of the policy. It sets out an evaluation of character that leads to suggestions for building forms and details. It does not provide strategic guidance relevant to the content of the concept plan but should inform architectural proposals as part of the sense of place. Therefore it is proposed to delete the reference from the Policy and add to paragraph 2.8.35. The Council do not consider that this amendment will affect the soundness of the Plan and it is presented as a Matters Arising Change in Section 6.

g Does the policy clearly and accurately identify the infrastructure necessary

to support the increased population (e.g. open space requirements set out in Appendix 4 and priority transport schemes identified in Appendix 5 and in the submitted Infrastructure Delivery Plan [ED006.4])? Are these appropriately shown on the Concept Plan and Proposals Map?

5.10 These measures are considered to be clearly set out in the Infrastructure

Delivery Plan (ED006.4) and are itemised in the Policy and Plan Appendices. In specific terms, a new distributor road, the Hafod Bypass has been recently constructed, the sites are close to a Park and Ride and bus routes to and from the City centre, and there is a linear cycle route along the East side of the Corridor and potential for the completion of one along the western side of the river as well. The policy provides for reinstatement of pedestrian links across the former canal, and improved connections across the river via a new pedestrian-cycle footbridge. Deliverability of these infrastructure elements will be through a combination of section 106 and grant sources (such as ERDF).

5.11 The SD has a wealth of accessible greenspace in terms of the green corridor

itself and the potential for improved access to the adjacent Kilvey Hill. The policy does not specify open space requirements but given the potential phased development by different interests, it is expected that each development will address its own open space requirements both within the site and along the river frontage. However the constraints such as limited site width between Morfa Road and the river mean that pitches cannot be accommodated. The Council acknowledge that the Policy should be clearer in this respect to ensure that sufficient on site open space is delivered plus off site contributions to enhance existing accessible pitches. The requirements will be set out in the

Infrastructure Delivery Plan which will be included as an Appendix to the Plan and appropriate text will be inserted into the Policy amplification. Furthermore, the appropriate cross reference will be included within the amplification to the Policies, IO1, SI 4 and SI 6 set out the open space requirements for new developments. The Council do not propose that this amendment will affect the soundness of the Plan and it is presented as a Matters Arising Change in Section 6.

h Have constraints such as Sites of Importance for Nature Conservation

(SINCs) and the Air Quality Management Area (AQMA) been sufficiently taken into account and are such constraints adequately conveyed within the policy, on the associated Concept Plan and in Appendix 3?

5.12 Yes, these have been taken into account and the Policy specifically references

the Tawe Riverside SINC. Any proposal which would be assessed against Policy RP 2: Air, Noise and Light Pollution with regard to any potential increase in air pollution from the development or if the development increased the number of individuals within an Air Quality Management Area (AQMA).

5.13 Whilst the concept plan does not show the constraints, it has been prepared

based on this information. The Infrastructure Delivery Plan highlights such constraints and it is the intention to include it as an Appendix to the Plan. The AQMA boundary is illustrated on the Constraints Map.

6.0 Summary and Conclusions 6.1 The deposit LDP policy and allocation relating to Site SD L is founded on robust

evidence and provides an appropriate planning framework to deliver new homes and complementary land uses, in accordance with the overarching vision and objectives of the Plan, as part of a comprehensive development to come forward over the Plan period.

Matters Arising Changes’ to the Deposit 6.2 The Council’s schedule of ‘Non-substantive amendments’[1] to the Deposit Plan

included changes that relate to matters addressed in this statement. In addition, having regard to the preceding Sections of this Statement, the following amendments to the Deposit LDP are proposed which are highlighted as proposed ‘Matters Arising Changes (MACs).

[1] LDP20 Schedule of Non-Substantive Amendments to Swansea Deposit LDP 2017..

Hearing Statement Question

Deposit LDP Section

Deposit Rep Ref

Proposed MAC Reason/Justification Origin of MAC

f SD L Tawe Riverside and Hafod Morfa Copperworks

Remove reference to Cadw characterisation report in second bullet point of Policy as follows: ‘Development proposals should positively reflect the historic industrial riverside character as identified in the Cadw characterisation report’. Add reference to the Cadw Characterisation report in paragraph 2.3.85: ‘The significant remains of the former Hafod and Morfa Copperworks is the focus of this Strategic Development Area. Located in the heart of the lower Swansea Valley opposite the Liberty Stadium, this 5 hectare riverfront site has numerous listed buildings and structures of importance for their industrial history, which represent a significant regeneration opportunity. Any development proposals must positively reflect the historic riverside character as identified in the Cadw characterisation report. Proposals for the heritage led regeneration of the site are being driven by ‘The Hafod/Morfa Copperworks Project’ a partnership project between the Council and Swansea University.’

To remove reference to an unadopted policy document and add to supporting text.

New amendment

Hearing Statement Question

Deposit LDP Section

Deposit Rep Ref

Proposed MAC Reason/Justification Origin of MAC

SD L: Tawe Riverside and Hafod Morfa Copperworks

Amend title of Concept Plan to reflect Policy title: ‘Tawe Riverside Corridor and Hafod Morfa Copperworks’

A typographical amendment. NSA 41

SD L: Tawe Riverside and Hafod Morfa Copperworks

Insert additional criterion: Create a multi-functional Green Infrastructure network throughout the site, taking account of the need to create healthy communities, with a particular emphasis on facilitating active travel, and including appropriate landscaping food growing opportunities, community led gardening spaces, and habitat creation. protect and enhance biodiversity, include appropriate landscaping and opportunities for formal and informal play, recreation and Active Travel retaining existing trees and hedgerows within the public realm, and introduce appropriate landscaping, and habitat creation.

The proposed amendment to the Plan to include reference to “healthy” communities may have merit in ensuring that the Strategic Site delivers on its objectives of creating healthy communities which contribute to well-being. The proposed amendment would not however affect the soundness of the Plan.

NSA 21

SD L: Tawe Riverside and Hafod Morfa

Amend bullet point 5 of Policy as follows:

Developments should face the river frontage and treat the river corridor as a key area of public real and green infrastructure with appropriate environmental

To ensure the Policy reflects the comprehensive environmental enhancement of Morfa Road Corridor, reflecting opportunities that have emerged as a result of new highway infrastructure.

New amendment

Hearing Statement Question

Deposit LDP Section

Deposit Rep Ref

Proposed MAC Reason/Justification Origin of MAC

Copperworks

enhancements and maximised accessibility to it.’

g SD L: Tawe Riverside and Hafod Morfa Copperworks

Insert the following text (in bold) as a final sentence to paragraph 2.3.88: ‘The recent Morfa Road…..and along the waterfront. Due to the constrained nature of the sites in addition to on-site open space provision, the Council will require off-site contributions to enhance existing accessible sports pitches where necessary’.

In order to ensure that sufficient on site open space is delivered plus off site contributions to enhance existing accessible pitches.

New amendment

Appendix A: Site Boundary of SD L