Pre-application Consultation
Proposed full planning application for residential development and associated works
Land at Lakeside Avenue, Llandrindod Wells
Thank you for your efforts with discussing the proposed development at Lakeside Avenue, Llandrindod Wells with local residents and ensuring that the consultation is a useful exercise.
In relation to your email 02/02/2022 which contained a number of observations and queries please see our responses below:
Traffic
The main concern of residents is the impact of the new estates on the volume of traffic with the
26 movements at peak hours, in particular, being questioned. Indeed, looking at the Transport
appraisal at 4.2.2 you state that 37 properties would generate 26 movements, then at 4.2.5 you
say 70 properties generate this figure.
Q1 Please could you state which figure is correct and if it is the latter can you confirm that
Powys CC has had a chance to respond to the corrected figure
Response: We have checked this with the Transport Consultant an they have confirmed 37 is an
error – the correct number is 70 and has been used for all calculations and will have provided the basis for the PCC Highways appraisal. This has been corrected in v3 of the Transport Assessment.
In the same report at 1.3.4 you reply on digital sources (Google maps and Streetview) to
determine that there is no need for traffic calming due to available off-street parking. This
however doesn't take into account limited visibility due to road curvature and hidden dips due to
relief. Talking to residents they identified the following;
Many residents have more vehicles than parking spaces and park on road,
In winter a number of the houses with steep drives on the even side of the road park on the road
as its unsafe to use the drives in frosty or snowy conditions,
Several residents reported near misses leaving their properties and most residents expressed
perceived concerns about the speed of cars.
On each of my 3 visits this weekend the number of on-road cars varied between 8 and 12
Q2 Will you consider a speed and vehicle count to determine current usage patterns?
Response: The development team has made multiple visits on the site and have observed the
on-street conditions. The local highway authority (LHA) has provided comments on the pre-
application consultation and they have reviewed the Transport Assessment. The LHA has not
advised that speed and vehicle counts would be necessary to support a planning application.
The main concern of residents is the impact of the new estates on the volume of traffic with the
26 movements at peak hours, in particular, being questioned. Indeed, looking at the Transport
appraisal at 4.2.2 you state that 37 properties would generate 26 movements, then at 4.2.5 you
say 70 properties generate this figure.
Q3 Will you consider extended island type speed reduction levels (due to the age of
residents speed bumps are likely to cause health issues)?
Response: Asbri transport are in open discussion with the LHA to confirm the level and type of
speed restriction they would like to see in the development proposals. The LHA has advised
these can be developed in application discussions.
Also on vehicles in the table on 3.4.4 you columns for max and proposed spaces are the same.
Q4 Could you provide a corrected copy of this table so it is possible to understand where
the reduction of spaces occurs?
Response: The proposed off street parking is in accordance with the relevant Parking Standards,
which are taken to be maximum – in this circumstance it is the intention to avoid on-street
parking. The text has been adjusted to reflect there is no proposed relaxation of the maximum
standards to avoid on-street parking.
At 3.4.10 you make mention of cycle storage but don't explain how this would be facilitated
Q5 please could you expand on this?
Response: The proposed dwellings are capable of accommodating cycle parking within their
curtilage or the dwelling itself and each property has a rear access. The LHA has not raised any
issues with cycle parking.
Sewage
The second most common concern applies to the use of the existing sewage network through
Lakeside. Residents throughout the street but especially above No 18 reported regular visits
from Welsh Water to unblock the main sewer pipes in recent years. One resident with technical
knowledge highlighted that some of the pips used are pitch rather than hard clay in construction
leading to pips becoming oval over time. There was concern that adding 70 properties onto the
network while this persists could lead to significant backing up and more persistent blockage.
Q6 Can you confirm what upgrades you would plan to the existing network if you are over
doubling the load on most of it?
Response: As noted on RCA drawings 20364/P1 & P2, the proposed foul water communicates
with the existing DCWW public sewer network west of No. 47 Lakeside Avenue. This is mapped
as plastic pipework on DCWW information and flows into the Ridgebourne
development. DCWW have been consulted for pre-pre-planning advice and they confirmed that
they have capacity to accept the proposed foul water flows into their public sewer system. The
comments relating to No. 18, etc. would appear to relate to a different part of the public sewer
network which is not affected by, and unrelated, to the proposed residential development.
Furthermore we have now had comments from DCWW relating to the Pre-Application
Consultation (PAC) which confirms “We can accept domestic foul only flows from this development
into the public sewer. No problems are envisaged with the Waste Water Treatment Works for the
treatment of domestic discharges from this site.”
Further down residents report a regular need to rod their drains for backing up at the pumping station as it approaches capacity.
Q7 can you guarantee that the additional load from the new build will not make this worse and potentially lead to flooding in properties at the foot of the road?
Response: New foul water flows are not proposed to discharge into the public sewer network associated with the existing Lakeside Avenue Pumping Station – refer to Q6, and therefore, the development will have no impact on this whatsoever. The pumping station itself has been reported to me as often operating at capacity. If this is exceeded the result would be flooding into the Mire and hence into Llandrindod Lake which would be a major incident with significant implications for the businesses that are reliant on the recreational use of the Lake
Q8 can you confirm to me that you have had discussions with Welsh Water where they have confirmed that there is capacity at the station and there are contingencies in place to prevent contamination of the mire and Lake should your development proceed?
Response: New foul water flows are not proposed to discharge into the public sewer network associated with the existing Lakeside Avenue Pumping Station – refer to Q6. Given these concerns, it is almost certainly the case that the LDP reference to adequate foul drainage within the network refers to the far more recent sewers at the bottom end of the field serving the Ridgebourne estate.
Q9 Can you explain why a link was not considered to this network and given the concerns raised here if you will consider a revision to the plans before submission to utilise this network instead of the Lakeside one in order particularly to remove the biodiversity and economic risk of contamination of the lake and wider Arlais catchment?
Response: As noted on RCA drawings 20364/P1 & P2, the proposed foul water communicates with the existing DCWW public sewer network west of No. 47/49 Lakeside Avenue. This is mapped as plastic pipework on DCWW information and flows into the Ridgebourne development. DCWW have been consulted for pre-pre-planning advice and they confirmed that they have capacity to accept the proposed foul water flows into their public sewer system
Biodiversity
A number of residents expressed concerns about the impact on Biodiversity and in particular the limited appraisal to day. I am in contact with a local Wildlife recorder and they have indicated a willingness to undertake a more detailed analysis of the site in early summer if they are allowed access. In addition to the fauna noted in the documentation the small herd of deer that has become established in the area have been sighted on the fields. A number of residents state fox, hedgehogs and badgers frequently use their properties and residents adjoining the south field have reported regular visits from toads and newts
Q10 can you confirm when you state fencing will provide gaps that this includes fencing between the new estate and existing properties and will you consider including wildlife strips on boundaries with the existing estate to facilitate existing animal movements?
Response: A Preliminary Ecological Assessment (PEA) of both field parcels was undertaken on the 16th June 2021 which is an optimal time to conduct ecology surveys. The PEA Report produced assessed the potential of the land within the site boundary to support habitats and species and the implications that any future development proposals could have on them. The only further survey work identified was in relation to badgers and this has been completed by Protected Species Ecology Ltd who are badger specialists. The proposal will include a new badger sett with the existing sett closed. The proposal includes a ‘wildlife corridor’ which will ensure animals in the area can travel northbound of Lakeside Avenue and visa versa. Whilst the comment with regard to provided a corridor adjacent to the existing estate is appreciated this has not be considered suitable for the proposal due to potential impacts on amenity space for new dwellings. Whilst comments on density have generally considered that the proposal is too high density comments received from the LPA at pre-application have advised the density should be circa 27 dwellings per hectare which is the level the proposed scheme achieves. Finally, in this respect, you plan to place bird and bat nesting boxes on some properties but you have not specified the type of bird box nor the properties that they will be cited on
Q11 please could you outline the type and locations?
Response: These details will be provided within the full application submission.
Access I note there is already an informal footway between the estate and Brynteg, the current plans are such that this is likely to now be accessed via the SUDS area and be relatively short.
Q12 as part of this plan would you consider improving the surface and formalising the path by either dedicating it as a PROW or putting in a similar active travel link to facilitate safer access to the lake from that side of town?
Response: PAR homes have confirmed that the pathway will be suitably surfaced to ensure ease of use by existing and future residents.
Q13 On the opposite side concerns have been raised about the impact of the active travel route on existing residents what mitigations will you put in place to support these residents? Response: These comments are noted. The route is a feature that the local highway authority considers to be acceptable and is favoured to ensure a strong connectivity to the surrounding area. Existing residents will also benefit as they too can use the route. Estate plans In general the mix of bedroom numbers is to be welcomed. However, I am concerned that the decision has been made to opt for houses on this site. The adjoining estate is entirely bungalows and a similar hillside site at Woodlands is also bungalows Given the fact these properties are on the skyline.
Q14 Why did you opt not to design a site in keeping with the surrounding housing?
Response: For a site to be developed in keeping with the character of the surrounding area it is not essential for all house types to remain the same as those in the surrounding area and this can result in negative impacts such as lack of legibility through the site due to repetitive design. The housing mix is considered to complement the existing stock in the area which beyond Lakeside Avenue is varied. Furthermore, if the scheme was entirely bungalows it would not achieve the density sought by the LPA and we would likely receive objections from Planning Officers on the basis that we are not making the most efficient use of land. I plan to look at layout in more detail but for now I do have a couple of specific queries
Q15 The two properties nearest to existing households that are not on the same alignment are N36 and S34 both of these are 2 story dwelling. I welcome they are gable walls so not overlooking but why are they not bungalows that would be at a similar ridge height and would you consider changing them to bungalows for that reason?
Response: These comments will be discussed with the developer and architect. In relation to plot N36 as referenced above this is a gable wall which features only a bathroom window which will be obscurely glazed and as such there is no opportunity to view no. 52 Lakeside Avenue. There is an extensive existing hedgerow along this boundary which is proposed to be retained. This will provide significant screening between the existing and proposed properties. In relation to S34 there are no windows proposed in the facing elevations as such provides no opportunity for overlooking and similarly to the above, the existing hedgerow will be retained providing screening. The separation distance is circa 14m. Likewise S22 and 23 are sited with their frontages opposite a property on Lakeside and whilst set opposite a road will still overlook it.
Q16 Why were bungalows rejected for this location? Response: The separation distances for each of these properties are in excess of 21m and again the hedgerow will provide screening. As such there’s considered to be no issues with privacy and amenity with S22 and S23. For plot N10 the garage falls almost perfectly in line with the rear windows of Brynfa. However if it were located along the line of edge of the access closer to plot 9 it would be largely concealed behind a mature conifer.
Q17 Would you consider making this realignment or undertaking a means of softening the impact on the adjoining property
Response: This area will be reviewed. Climate Change mitigation There are no specific details in the papers so far on climate change mitigations, the narrative talks about some form of onsite water storage but unlike other recent applications there is no visible indications of waterbutts which would reduce the need to water in the gardens nor of the use of heat pumps or solar panels on properties.
Q18 What measures do you plan to put in place to mitigate the for the impacts of climate change and reduce energy demand within these properties?
Response: The proposal will be compliant with latest SuDS standards adopted in Wales to ensure that surface water is sustainably drained. The drainage strategy proposes 2m wide swales with side slopes running adjacent the site roads with a trench below with perforated carrier pipe to collect and convey flow to the outfall. Driveways are to have porous surfaces with tanked clean stone beneath to provide treatment of surface water to reduce pollution. A large attenuation basin is proposed to the north-west of the northern parcel. This will accommodate surface water runoff from the northern parcel and will provide significant biodiversity benefits. The site has a number of abnormal costs due to the engineering that will be required to build the homes and as renewable energies are often a more costly installation, viability will be a factor. Notwithstanding, it should be recognised that following the devolution of Building Regulations in Wales, energy efficiency is now ‘built-in’ to all new dwellings, through lower U-Values for walls, roofs, doors and windows and higher standards of insulation. With such highly insulated, energy efficient dwellings, there is a much lower need for ‘bolt-on’ renewable technologies, such as solar panels. Notwithstanding, applicant is reviewing the potential for the installation of air source heat pumps. Affordable Housing Your initial proposals fall some way short of the local plan allocation for affordable housing as required within local planning guidance which should be 30% of the development. You cite economic factors but the housing market is buoyant in the area and new build of this nature is likely to command a premium and be unaffordable to many local residents. Could you therefore
Q19 outline which properties you have already identified as being designated as affordable based on the masterplan?
Response: this will be completed for the full application.
Q20 Outline how those properties will enter the market in term of tenure?
Response: the homes will be offered to a registered social landlord who will likely manage the homes via social rent.
Q21 If for sale what measure you will put in place to ensure they are available to members of the local community for purchase and no purchased to then rent?
Q22 What measure you will put in place to attempt to guarantee onward use at affordable rates?
Response: this will be secured either via planning conditions or section 106 agreement.
Q23 If you plan to move them into the social rented sector who will be your preferred housing partner?
Response: this is to be discussed. Construction Phase
Q24 What proposals will you be putting forward to planners in respect of access to the site for construction machinery and supply traffic during the construction phase? Specifically, do you expect access to be via the existing estate road or the field gate and track accessed via the Ridgebourne Quarry?
Q25 If accessed from Ridgebourne what mitigation steps to you plan to put in pace for residents directly impacted by construction traffic entering and leaving the site.
Response: No access is proposed via the Ridgebourne. PAR homes will develop a construction environmental management plan which the local planning authority will likely secure via planning condition. This will provide full detail of how the construction phase will be managed.
I hope this is satisfactory and look forward to receiving your response.