CYNGOR CYMUNED LLANFAIR DYFFRYN CLWYD COMMUNITY COUNCIL
Clerk – Mrs Eirwen Godden35 Maes Cantaba
01824 707151 email@example.com
Date 9 January 2017
Mr Graham Boase
Head of Planning and Public Protection
Denbighshire County Council
DENBIGH LL16 3RJ
Dear Mr Boase
PROPOSED DEVELOPMENT OF 63 HOUSES ON LAND OFF WREXHAM ROAD, LLANFAIR D C BY PURE RESIDENTIAL & COMMERCIAL LIMITED
I refer to previous correspondence sent to you dated 10 and 21 November 2016 regarding the above application and wish to submit the following observations for your consideration.
To date the Community Council has convened two special meetings, 25 October [pre-application] and 14 December 2016 [full application] to consider responses to the proposed development. The application was also discussed at two ordinary meetings of the Council held on 2 November 2016 and 4 January 2017. Members of the public were invited along to all meetings which were well attended generating a full discussion on the proposals.
The main concerns arising from these meetings which need to be addressed are listed as follows:
1.1 Size of development – too large
1.2 Lack of integration with the rest of the village, the need for easy access to and from Parc y Llan and Bron y Clwyd which does not involve crossing the A525. There must, therefore, be pedestrian access into the village other than onto the A525
1.3 Quality of design and technical issues regarding infrastructure, gas, water and drainage
1.4 Clarity on affordable housing and the need for it to be aligned to community demand
1.5 Impact on wildlife/natural environment
1.6 Siting of the open space area.
2 Discussions with the Senior Planning Officer
The Chairman of the Community Council, Councillor John Pugh together with Councillor Keith Moulsdale and the Clerk, Eirwen Godden, met with Sarah Stubbs, Senior Planning Officer on 21 December 2016. The Community Council welcomed the opportunity to discuss items of concern already highlighted with particular reference to the Supplementary Planning Guidance – Planning Obligations dated November 2016 and Policy RD1 [Sustainable Development and Good Standard Design]. The Community Council would also ask that the County Council speaks to the developers about a statement contained in their report on the pre-application consultation [para 3.1]. This gives the impression that the developers may ignore residents’ views.
3 Community Council’s Response
In conclusion, therefore, the Community Council’s observations are listed below:
3.1 Size of Development – The proposed development is too large, residents want a village setting not a town. The need for this many houses in the village is being questioned. A report was commissioned some time ago with regard to a development of 15 houses which did not go ahead. A new up to date survey is required to justify the number of 63 properties now. Although the planning guidance on density could allow more than the 63 proposed, the developer should have regard to the character of the area. RD1 refers and SPG adds more detail.
3.2 Access/Links – There must be pedestrian access into the village other than onto the A525. People feel very strongly that there is no pedestrian access/connection to the present village and that the suggested pedestrian access/exit crossing the A525 is extremely dangerous [RD1 [vii] and [xii] refers]. There could be a pathway link near to the existing pensioners’ bungalows [plan attached]. SPG Section 17 Community Safety para 17.2 makes reference to “measures to improve community safety in the vicinity of developments may include: [inter alia] pedestrian improvements required to address community safety”.
The A525 is a busy road. There are major concerns about increased traffic through the village. Although the 30 mph limit will be moved, a compulsory 20 mph would be preferred for the school approach. RD1 [vii] refers].
A link needs to be established between the development and the village hall as a local hub. The secretary of the village hall committee is due to start a fundraising campaign in 2017 to raise £100,000 needed to upgrade facilities in the hall. Would the developer consider some investment funding for the benefit of the whole community? SPG Section 15 on Community Development, para 15.1 states “community facilities play an important role in meeting the needs of society and lend support to building a cohesive community”. A recent development in the Llangollen area is a good example of collaboration.
3.3 [a] Quality of Design – Quality of design and technical issues regarding infrastructure, gas, water and drainage need to be addressed. The new development should
3.3.1 Respect the site and its surroundings
3.3.2 Make the most efficient use of land
3.3.3 Promote good design
3.3.4 Improve the local economy, especially in more rural areas
3.3.5 Integrate land uses to improve travel efficiency
3.3.6 Not unacceptably affect the amenities of existing residents
3.3.7 Provide safe and convenient access for all
3.3.8 Respect established rights-of-way
3.3.9 Avoid creating traffic danger
3.3.10 Not compromise adjacent land use development
3.3.11 Be sustainable
3.3.12 Avoid flood risk
3.3.13 Offer good quality landscaping where this is achievable
Policy RD1 supports the above aims, including providing safe and convenient access for all groups and individuals, including adequate provision for parking, servicing and manoeuvring.
The basic design of the majority of the dwellings is not in keeping with present houses in the area. There are many stone faced houses abutting the site and there are no flats in the village [RD1 [i] refers]. The Community Council suggests that the houses alongside the A525 main road should be more in keeping with the rest of the village, that is, built with stone facing.
[b] Gas Services – Rather than have an LPG tank installed on the site it is requested that the proposed development and the whole community is connected to the mains gas service. Some residents have indicated that they are willing to contribute towards the cost. SPG Para 2.1 “seeks to ensure that the development makes an appropriate contribution to the provision of infrastructure to meet the additional social, economic, physical and/or environmental infrastructure requirements arising from the development.”
[c] Drainage – It is felt that the investigation into drainage of the site is flawed and that further investigations need to be undertaken to alleviate the risk of flooding on this site and further towards Ruthin [RD1 [xi] refers]. Please see appendix 1 attached relating to drainage.
3.4 Affordable Housing – needs to be aligned to community demand. Denbighshire County Council’s report on the housing market in the Llanfair D C area dated December 2016 refers. This shows that the social housing waiting list is currently 24 [general needs] and 9 [sheltered accommodation]. Can commuted funds be used to increase the number of affordable homes on the site? An assurance is also being sought that people with links to the area [especially young people] can have preference to affordable housing.
3.5 Natural Environment and Local Wildlife – Not enough account has been taken of comments already submitted. If specific habitat is needed for certain species based on evidence the developer will need to be reminded of this including balances required. It is noted that the archaeological report indicates some Roman remains and that the County Council has suggested to the developer that a geological survey is carried out. However it appears that there is no longer evidence to back this up and that this survey is now unnecessary.
3.6 Location of Open Space – The open space is out of the way and purely for the new development. It would be better placed in the centre of the site, away from the A525 minimising the danger of children, for example, chasing stray balls onto the main road [RD1 [xii] refers]. Consideration should also be given to establishing a quiet area with seating on the plan. The only piece of green area in the village at present is in front of Bron y Clwyd. SPG Para 11.13 states “developers are encouraged to provide safe to use open space on site that caters for the needs of different users and age groups”.
I trust that these comments and recommendations will be taken into account when the application is being determined.
Clerk to the Council Encs 2 Copy to Sarah Stubbs, Senior Planning Officer
LLANFAIR DYFFRYN CLWYD COMMUNITY COUNCIL
Appendix 1 Drainage Matters – Planning Application 20/2016/1137 December 2016
The Community Council welcomes the changes made between the initial drainage design presented in the pre-planning consultations and that submitted with the full planning application. The design presents a more realistic review of the feasibility for complying with Denbighshire policy with regard to avoidance of flood risk.
However, to ensure that a full design is undertaken with an understanding of the hydrology and arrangements for the development, it is recommended that further investigation be carried out to provide data to inform the design.
Whilst the site investigations and ground surveys indicate relatively impermeable conditions it is evident that the site attenuates flows either through retention or by soaking away of surface water. It is recommended that a flow survey be carried out on the site and that flows into and leaving the site be monitored. These would then be used in conjunction with rainfall data to ascertain the true pre-development run-off from the site which would be used to design the SuD.
It is further recommended that the surface drainage on the site be investigated using CCTV. The length of drain between points B and F on the drainage strategy report prepared by Carter Jones is understood to have been constructed in relatively recent times. This was previously an open ditch running along the hedge line. The drain is understood to have been constructed using land tiles with no jointing and there may be connecting land tiles from the field into the drain. Further, the condition of the drain should be ascertained and particularly whether there is ingress of soils or roots. The developer proposes to divert a section of this pipeline to accommodate the housing layout and it should consider the need for rehabilitation of this section of drain to ensure that future need can be met.
From inspection at the site it is suspected that there is an element of foul flow entering the surface drain. This could arise from illegal connection to the surface water system and although this may not be the developer’s responsibility it would be be advisable to work with Dwr Cymru to carry out a survey of the sewers and drains off the site using CCTV to identify any rehabilitation or reconnection that might be required. The sections of drain between points E and B were recently replaced with ribbed plastic pipeline as there had been complaints from adjacent houses about odour from the drain, indicating the potential presence of foul flow.
In undertaking its design the SuD the developer would be advised to consider the operation and maintenance requirements to ensure that provision for desilting and for pump maintenance is included.
The developer should be encouraged to incorporate green infrastructure thinking into the design such as set out in the Scottish design guide “Green Infrastructure Design and Placemaking” [ISBN: 978-1-78045-351-4] which is available on the Scottish Government website: www.scotland.gov.uk